also acknowledged that the Mezzanine CIP was silent on the
foreign exchange translation methodology.
 According to Mr. Hibben, “the philosophy of the plan was
that . . . currency exposure was not taken by the participants in
the plan other than to the extent that a U.S. dollar profit
would have been translated at a spot rate of exchange when
the . . . payment from the carried interest plan would have been
made”. Mr. Hibben conceded that he did not really know how
U.S. investments were valued on the books of the Fund.
 Kroll advised using an exit rate foreign exchange methodology, advice which RBCDS accepted and used to calculate Mr.
Manastersky’s entitlements under the Mezzanine CIP from
investments made between 2005 and 2013.
 Ms. Petroff testified that RBCDS accepted the exit rate
methodology in part because it “didn’t want any FX noise to the
participants”, by which she meant that the company did not
want currency swings to go to the participants because that
would not be fair. She also testified that a change to the
exchange methodology that might result in less proceeds to the
participants could not be established without the consent of
the employee participants: “That would be a change that they
would have to agree upon.”
 Ms. Petroff also stated that when RBCDS accepted Kroll’s
exit rate methodology, she did not think of going back to see if it
differed from the calculations RBCDS had used historically for
the exchange rates on U.S. dollar investments.
 At trial, Mr. Manastersky argued that in the absence of an
express foreign exchange methodology in the Mezzanine CIP, it
would be unfair to require a participant such as himself to bear
the risk of exchange fluctuations. RBCDS acknowledged that had
it used the methodology advocated by Mr. Manastersky (as it
had between 2001 and 2004), Mr. Manastersky’s entitlement to
payouts in respect of Funds 1 and 2 would have increased by
 The trial judge accepted Mr. Manastersky’s position and
awarded him $190,789 “in respect of his share of investment
proceeds under the CIP for the period 2005 to 2013, as calculated
using the Plaintiff’s foreign exchange methodology”. Based on his
assessment of the evidence, the trial judge found, at paras. 65 and
66 of his reasons, that
( i) the CIP was silent on the foreign exchange issue;
( ii) participants in the CIP were not expected to bear the risk
associated with fluctuations in foreign exchange;