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Fulcrum Diversified AbsoluteReturn FundProduct Disclosure StatementARSN 601 830 353APIR ETL0424AUIssue Date 22 October 2018

Contents1. Fund at a glance 3

2. ASIC Benchmarks 4

3. Disclosure Principles 5

4. Who is Managing the Fund? 7

5. How the Fund Invests 8

6. Managing Risk 12

7. Investing and Withdrawing 14

8. Keeping Track of YourInvestment 16

9. Fees and Other Costs 17

10.Taxation 20

11.Other Important Information 22

12.Glossary of Important Terms 25

Investment ManagerFulcrum Asset Management LLPPhone: +44 207 016 6450www.fulcrumasset.com

Responsible EntityEquity Trustees LimitedABN 46 004 031 298 AFSL No 240975GPO Box 2307 Melbourne VIC 3001Phone: +61 3 8623 5000Web: www.eqt.com.au

Fund DistributorAmbassador Funds Management ServicesPty LtdABN 91 133 740 057, AFSL No 331717Phone: +61 2 9081 0230www.ambassadorfms.com

AdministratorJ.P. Morgan Chase Bank, N.A.(Sydney Branch)ABN 43 074 112 011, AFSL 240975C/ - Link Market Services LimitedPO Box 3721Rhodes NSW 2138Fax +61 2 9287 0341www.jpmorgan.com

Fulcrum Diversified Absolute Return Fund PDS 1

This is the Product Disclosure Statement (“PDS”) for the FulcrumDiversified Absolute Return Fund (ARSN 601 830 353) (the‘Fund’) and was issued on 22 October 2018. This PDS has beenprepared and issued by Equity Trustees Limited (ABN 46 004 031298 AFSL 240975) in its capacity as the responsible entity of theFund (referred to throughout this PDS as the “ResponsibleEntity”, “Equity Trustees”, “us” or “we”). The investmentmanager of the Fund is Fulcrum Asset Management LLP and isreferred to throughout this PDS as the ‘Investment Manager’ or‘Fulcrum’. Fulcrum relies on ASIC Class Order 03/1099 whichexempts it from the requirement to hold an Australian financialservices licence under the Corporations Act in respect offinancial services provided by it or its representatives toWholesale Clients on certain conditions. Fulcrum and itsrepresentatives are regulated by the Financial ConductAuthority under UK laws and those laws may differ fromAustralian laws. The Administrator of the Fund is J.P. MorganChase Bank, N.A. (Sydney Branch) (ABN 43 074 112 011 AFSL238367) and is referred to throughout this PDS as ‘JP Morgan’ or’the Administrator’. Ambassador Funds Management ServicesPty Ltd (ABN 91 133 740 057 AFSL No 331717) is the Fund’sdistributor and is referred to throughout this PDS as’Ambassador’.

This PDS is prepared for your general information only. It is notintended to be a recommendation by the Responsible Entity,Investment Manager, Ambassador or any associate, employee,agent or officer of the Responsible Entity, Investment Manager,Ambassador or any other person to invest in the Fund. This PDSdoes not take into account the investment objectives, financialsituation or needs of any particular investor. You should not baseyour decision to invest in the Fund solely on the information inthis PDS. You should consider the suitability of the Fund in viewof your personal financial circumstances, investment objectivesand needs. You may want to seek advice before making aninvestment decision.

Equity Trustees, the Investment Manager, Ambassador and theiremployees, associates, agents or officers do not guarantee thesuccess, repayment of capital or any rate of return on income orcapital or the investment performance of the Fund. Pastperformance is no indication of future performance. Aninvestment in the Fund does not represent a deposit with or aliability of Equity Trustees, the Investment Manager,Ambassador or any of their associates. An investment is subjectto investment risk, including possible delays in repayment andloss of income or capital invested. Units in the Fund are offeredand issued by the Responsible Entity on the terms andconditions described in this PDS. You should read this PDS in itsentirety.

The offer made in this PDS is only available to Wholesale clientsand Wholesale investors receiving this PDS in Australia and NewZealand (electronically or otherwise). New Zealand investorsmust read the Fulcrum Diversified Absolute Return Fund New

Zealand Wholesale Investors Fact Sheet before investing in theFund. This PDS is not to be treated as an offer to sell, or asolicitation of an offer to buy, any units in any jurisdiction inwhich it is unlawful to make such an offer or solicitation or to anyperson to whom it is unlawful to make such an offer orsolicitation. If you received this PDS electronically a paper copywill be provided free upon request during the life of this PDS.Please call Equity Trustees on +61 3 8623 5000 for a copy.

This PDS does not constitute a direct or indirect offer ofsecurities in the US or to any US Person as defined in RegulationS under the Securities Act of 1933 as amended (“US SecuritiesAct”). Equity Trustees may vary its position and offers may beaccepted on merit at Equity Trustees’ discretion. The units in theFund have not been, and will not be, registered under the USSecurities Act unless otherwise determined by Equity Trusteesand may not be offered or sold in the US to, or for, the accountof any US Person (as defined) except in a transaction that isexempt from the registration requirements of the US SecuritiesAct and applicable US state securities laws.

The forward looking statements included in this PDS involvesubjective judgment and analysis and are subject to significantuncertainties, risks and contingencies, many of which areoutside the control of, and are unknown to, Equity Trustees, theInvestment Manager and their officers, employees, agents orassociates. Actual future events may vary materially from theforward looking statements and the assumptions on which thosestatements are based. Given these uncertainties, you arecautioned to not place undue reliance on such forward lookingstatements.

In particular, in considering whether to invest in the Fund, youshould consider the risk factors that could affect the financialperformance of the Fund. The key risk factors affecting the Fundare summarised in section 6.

Unless otherwise stated, all fees quoted in the PDS are inclusiveof Goods and Services Tax (‘GST’) after allowing for an estimatefor Reduced Input Tax Credits (‘RITCs’), and all amounts are inAustralian dollars.

Information in this PDS is subject to change from time to time.We may update information in this PDS that is not materiallyadverse. You can obtain any updated information:

• by calling Equity Trustees on +61 3 8623 5000; or

• by visiting the Equity Trustees website atwww.eqt.com.au/insto;

A paper copy of the updated information will be provided freeof charge on request.

If we make a materially adverse change to the information in thisPDS, we will either issue a new or a Supplementary PDS andensure that unit holders are given notice as required by law. Ifthere is an increase in fees, we will give you at least 30 days priornotice in writing.

2 Fulcrum Diversified Absolute Return Fund PDS

1. Fund at a glance

SummaryFor furtherinformation

Name of the Fund Fulcrum Diversified Absolute Return Fund Section 5

ARSN 601 830 353 Section 5

APIR Code ETL0424AU Section 5

Investment objective The Fund aims to achieve long-term absolute returns in all marketconditions over rolling five year periods, with lower volatility than equitymarkets and in excess of inflation.

Section 5

Investment strategy andinvestments held

In seeking to achieve its aim of long-term absolute returns, the Fund willinvest globally and aim to hold a highly diversified portfolio, typicallyconsisting of exposures to equities, fixed income, commodities,alternatives and cash. Investments may be made through collectiveinvestment schemes (including index funds such as exchange traded funds(ETFs) and actively managed funds managed by the Investment Manager,but not actively managed funds managed by third party investmentmanagers).

The Fund may use derivatives for investment purposes and for efficientportfolio management. The Fund will use hedging strategies to reduce riskover the short term without materially altering its risk profile.

The Fund will be managed without reference to a benchmark.

The Fund will be managed with a forward looking volatility cap of 12%.

Section 5

Benchmark None but target return over inflation.

The type(s) of investors forwhom the Fund would besuitable

The Fund is suitable for Australian Wholesale clients and New ZealandWholesale Investors.

Section 5

Recommended investmenttimeframe

At least 5 to 7 years.

The minimum suggested investment timeframe for the Fund is 5 years. Werecommend that you consider, with your financial adviser, the suggestedinvestment period for the Fund in relation to your own financialcircumstances.

You should review your investment regularly to ensure that the Fundcontinues to meet your investment needs.

Section 5

Minimum initial investment $5,000,000 Section 7

Minimum additionalinvestment

$10,000 Section 7

Minimum withdrawal amount $10,000 Section 7

Minimum balance $2,500,000 Section 7

Cut off time for applications 2:00pm on each Business Day. Section 7

Cut off time for withdrawals 2:00pm on each Business Day.

Valuation of the Fund’s assets The Fund’s assets are normally valued daily. Section 7

Cooling Off No cooling off period applies to the offer made in this PDS as onlyAustralian Wholesale Clients and New Zealand Wholesale Investors maymake an investment in the Fund.

Section 7

Income distribution Determined at least annually at the end of June and normally paid toinvestors within 14 days of the period end.

You may elect to have your distribution reinvested or directly credited to anaccount in your name held at a branch of an Australian domiciled bank.New Zealand investors can only have their distribution reinvested.

Section 7

Management fee 1.0% p.a. of the Net Asset Value (‘NAV’) (including GST less RITCs) Section 9

Entry fee/ exit fee None Section 9

Performance fee None Section 9


2. ASIC BenchmarksThe Fund is a ‘hedge fund’ for the purposes of Australian Securities and Investments Commission (ASIC) Regulatory Guide 240. Thefollowing table sets out a summary of the disclosure ASIC requires for hedge funds, the key features of the Fund and a guide to wheremore detailed information can be found in this PDS. A copy of ASIC Regulatory Guide 240 dated October 2013 (as may be amended,supplemented or replaced from time to time) is available from www.asic.gov.au.

The information summarised in this table and explained in detail in the identified section reference is intended to assist investors withanalysing the risks of investing in the Fund. Investors should consider this information together with the detailed explanation ofvarious benchmarks and principles referenced throughout this PDS and the key risks of investing in the Fund highlighted in section 6of this PDS.

ASIC Benchmark

Is thebenchmarksatisfied? Summary

For furtherinformation

Valuation of assets

This benchmark addresseswhether valuations of theFund’s non-exchange tradedassets are provided by anindependent administrator oran independent valuationservice provider.

Yes Non exchange traded assets comprise of over-the-counter(‘OTC’) derivatives or collective investment schemes. Bothare valued by independent parties.

Section 5

Periodic reporting

This benchmark addresseswhether the responsibleentity of the Fund will provideperiodic disclosure of certainkey information specified byASIC on an annual andmonthly basis.

Yes The Responsible Entity has and implements a policy toprovide the following information to you as soon aspracticable after the relevant period end:

• Annual Report to investors, including financialstatements and auditor’s report;

• Transaction Reports confirming all additionalinvestments, withdrawals, and payments (issuedfollowing transactions and on request);

• Distribution Statements issued annually notifying theinvestor of the value of their investment, income frominvestments and confirming the reinvestment or paymentto the investor’s bank account;

• Reports issued by the Investment Manager annually andmonthly and provide information on the Fund including areview of market conditions and Fund performance (seepage 22 for the list of information disclosed to investors);and

• Tax Statements issued annually, providing investors withtaxation information including a detailed summary of thecomponents of any distributions.

The frequency and content of the current reporting for theFund is considered adequate.

Section 8


3. Disclosure Principles

SummarySection (for furtherinformation)

Investment strategy The investment objective of the Fund is to achieve long-term absolutereturns over rolling five year periods, with lower volatility than equitymarkets and in excess of inflation.

In seeking to achieve its aim of long-term absolute returns, the Fund willhold a diversified portfolio, typically consisting of exposures to equities,fixed income, commodities, alternatives and cash. Investments may bemade through collective investment schemes (including index funds suchas ETFs and actively managed funds managed by the Investment Manager,but not actively managed funds managed by third party investmentmanagers).

The Fund may use derivatives for investment purposes and for efficientportfolio management. The Fund will use hedging strategies to reduce riskover the short term without materially altering its risk profile. The Funddoes not borrow money, but the Fund strategy can contain implicitleverage through the use of futures for investment and hedging purposes.

The Fund will be managed without reference to a benchmark. The goal ofthe Fund is not to replicate standard industry benchmarks but to targetabsolute returns by investing in a diversified pool of global assets acrossasset classes. The fund will invest in assets denominated in variouscurrencies.

The Fund will be managed with a forward looking volatility cap of 12%.

Diversification guidelines for the Fund are set out in section 5. The specificrisks of investing in the Fund are described in section 6.

The Fund does not use the investment technique of short selling ofequities.

Section 5.2, 5.6, 5.7and 5.8

Investment manager Equity Trustees, as Responsible Entity of the Fund, has appointed Fulcrumas investment manager.

Fulcrum is a ‘limited liability partnership’ which was incorporated on22 December 2003. On 14 April 2004, it was approved and regulated by theFinancial Conduct Authority (previously the Financial Services Authority) forthe provision of investment management services.

The firm is headquartered in London with an additional office in New York,managing both absolute and relative return strategies across all of themajor liquid asset classes globally, with a key focus on diversification andrisk management.

Fulcrum has appointed Ambassador Funds Management Services Pty Ltd(‘Ambassador’) as the sole distributor of its products in Australia and NewZealand. Ambassador has offices in Sydney and Melbourne and operatesunder its own AFSL.

See section 4 in relation to the expertise of the Investment Manager andthe investment management agreement.

Under the investment management agreement between the InvestmentManager and Equity Trustees, Equity Trustees can terminate theInvestment Manager’s appointment where the Investment Managerbecomes insolvent, materially breaches the agreement, ceases to carry onits business or in other circumstances. In the event that Equity Trusteesterminates the Investment Manager following one of these events, theInvestment Manager’s appointment would cease upon any terminationdate specified in the notice, and the Investment Manager would beentitled to receive fees in accordance with the agreement until theeffective date of termination.

Section 4


SummarySection (for furtherinformation)

Fund structure The Fund is an Australian unit trust registered under the Corporations Actas a managed investment scheme.

The Responsible Entity of the Fund is Equity Trustees.

Equity Trustees may appoint service providers to assist in the ongoingoperation, management and administration of the Fund.

The key service providers to the Fund are:

• Fulcrum Asset Management LLP, the investment manager of the Fund;

• Ambassador Funds Management Services Pty Ltd, the Fund’sdistributor;

• JP Morgan, the Administrator of the assets of the Fund;

• JP Morgan, the custodian of the assets of the Fund (‘Custodian’).

See section 5.3 for further information on Equity Trustees’ role inmonitoring the performance of service providers and a diagram of flow offunds through the Fund.

Sections 4, 5.3 and6

Valuation, location andcustody of assets

JP Morgan is the Administrator of the Fund and provides administrative,accounting, registry and transfer agency services. The Administrator isresponsible for calculating the Fund’s NAV.

See section 5.4 for further information on custodial arrangement and thegeographical location of assets.

JP Morgan is the Custodian and provides custodial services.

Section 5.4

Liquidity The Fund invests predominantly in liquid assets and is expected to beliquid for the purposes of the Corporations Act.

Section 5.5

Leverage The Fund does not borrow money, but can contain implicit leveragethrough the use of futures for investment purposes. It is not anticipatedthat gross leverage, as defined in Section 5.7, will exceed 500%, while netleverage (total long positions minus total short positions) will normallyrange between 80% to 200%.

Section 5.6 and 5.7

Derivatives The Fund may use derivatives for investment purposes and for efficientportfolio management.

Section 5.6

Short selling The Fund does not use short selling of equities. Short positions may beobtained through derivatives. Refer to section 5.8.

Section 5.8

Withdrawals You can withdraw your investment by faxing a request to withdraw from theFund. The minimum withdrawal amount is $10,000. The Responsible Entitywill generally allow you to access your investment daily.

See section 7 for more information on making a withdrawal

Risks and limitation on withdrawal are set out in section 7.

Section 7


4. Who is Managing the Fund?The Responsible EntityEquity Trustees LimitedEquity Trustees Limited ABN 46 004 031 298 AFSL 240975, asubsidiary of EQT Holdings Limited ABN 22 607 797 615, whichis a public company listed on the Australian Securities Exchange(ASX: EQT), is the Fund’s responsible entity and issuer of thisPDS. Established as a trustee and executorial service provider bya special Act of the Victorian Parliament in 1888, today EquityTrustees is a dynamic financial services institution whichcontinues to grow the breadth and quality of products andservices on offer.

Equity Trustees’ responsibilities and obligations as the Fund’sresponsible entity are governed by the Fund’s constitution(“Constitution”), the Corporations Act and general trust law.Equity Trustees has appointed Fulcrum as the investmentmanager of the Fund. Equity Trustees has appointed a custodianto hold the assets of the Fund. The custodian has no supervisoryrole in relation to the operation of the Fund and is notresponsible for protecting your interests.

The Investment ManagerFulcrum Asset Management LLPFulcrum is an independent asset manager founded in 2004 byGavyn Davies and Andrew Stevens – the firm’s sole focus is fundmanagement. At the date of this PDS the team managesapproximately AUD $5.6billion in absolute and relative returnstrategies for a wide range of institutional clients. The firm isheadquartered in London with an additional office in New York.Top down asset allocation and disciplined risk management arecentral to each of our investment funds.

The Fulcrum Investment Committee has ultimate responsibilityfor the Fund. The Investment Committee has an average of over20 years professional experience and is made up as follows:

Gavyn Davies (Founding Partner, Chairman of Fulcrum,Chairman of the Investment Committee)

• Founded Fulcrum in 2004

• BBC, Chairman, 2001-2004

• Goldman Sachs, Chief Economist, Managing Director thenPartner, 1986-2001

• Simon & Coates then Phillips & Drew, Economist, 1979-1986

• Policy Unit at 10 Downing Street, Economic PolicyEconomist (1974) then adviser to the Prime Minister(1976-1979)

• St John’s College, Cambridge, then Research at BalliolCollege, Oxford, until 1974

Andrew Stevens (Founding Partner, Chief Executive, Chairmanof the Risk Committee)

• Founded Fulcrum in 2004

• Goldman Sachs, Investment Management, ExecutiveDirector, 1992-2004

• Harvard Business School, MBA, 1990-1992

• Burns Fry, New York, Mergers & Acquisitions, Associate,1988-1990

• BA Finance, Georgetown University, 1984-1988

Suhail Shaikh, CFA (Partner, Chief Investment Officer)

• Joined Fulcrum in 2005

• Goldman Sachs, Associate, Investment Strategy Group,2002-2005

• Goldman Sachs, Analyst, Global Equity then Global FixedIncome & Currency Asset Management, 2000-2002

• CFA Charterholder since 2003

• BSc Management, London School of Economics & PoliticalSciences, 1997-2000

Andrew Bevan, PhD (Partner, Fixed Income Strategist)


• Goldman Sachs, Managing Director, Head of GlobalMarkets Research, 1994-2005

• Bear Stearns, Managing Director, Head of FinancialAnalytics and Structured Transactions Group, 1990-1994

• Reading University, First Class BA Economics; City UniversityBusiness School, PhD International Monetary Economics;KCL, PhD Theology 1978; 1986; 2002.

Nabeel Abdoula, CFA (Partner)


• Fulcrum Asset Management, Diversified Growth Strategies(2011-present)

• Goldman Sachs, Investment Strategy Group (2007-2011)

• Warwick University, BSc in Mathematics, OperationalResearch, Statistics and Economics (2003-2007)

• CFA Charterholder since 2011

The individuals noted above are ultimately responsible for theoversight of the investment activities for the Fund and willdevote a majority of their time on investment strategiesapplicable to the Fund. No specific individual of Fulcrum or anyof the specific individuals noted are required to devote anyspecific portion of their time exclusively to the Fund.

There has not been any significant adverse regulatory findingsagainst Fulcrum or the individuals listed.

About the Fund DistributorAmbassadorAmbassador is an independent funds management marketing,sales and client servicing company operating primarily in theAustralian and New Zealand institutional markets. Ambassadorhas offices in Sydney and Melbourne and operates under its ownAFSL.

The Custodian and AdministratorJ.P. Morgan Chase BankJ.P. Morgan Chase Bank, N.A. (Sydney Branch) is theAdministrator and provides certain custodial, administrative,accounting, registry and transfer agency services for the Fund.The Administrator has been appointed to provide these servicesunder an administration agreement between the ResponsibleEntity and the Administrator. The Administrator has no directrelationship with investors.


5. How the Fund Invests5.1 Investment objectiveThe Fund’s objective is to achieve a real return of 3-5% over rolling 5 year periods with substantially lower risk than equity markets andwithout reference to any asset class based benchmarks.

Investors should be aware that the investors’ capital is, in fact, at risk and there is no guarantee that these returns will be achieved,whether over rolling five year periods, or any time period.

5.2 Investment strategyIn seeking to achieve its aim of long-term absolute returns, the Fund will hold a diversified portfolio, typically consisting of exposuresto equities, fixed income, commodities, alternatives and cash. In order to maximise risk-adjusted returns the Fund relies on fourprimary sources of return – asset class timing, relative value opportunities, alternatives and hedging - with the relative weightingsactively managed by the Investment Committee.

A disciplined investment process aims to ensure that, over the long term, the strategy can benefit from positive expected returnsacross a variety of traditional and alternative asset classes. Each asset class is chosen specifically to generate attractive capital growth,regular income or because it improves risk-adjusted returns over the long term. The table below illustrates the typical ranges ofexposure in each asset class:

Asset Class ImplementationMarket Exposure

Ranges (%)

Global Equities • Equity market exposure is obtainedthrough investment in collectiveinvestment schemes (including ETFs)and derivatives based on a numberof broad indices.

10-60

Global Fixed Income • Fixed Income market exposure isobtained through investment in cashsettled bonds, derivatives orcollective investment schemes(including ETFs).

0-80

Alternatives • Alternative market exposure isobtained through investments inabsolute return collective investmentschemes.

0-40

Commodities • Commodity market exposure isobtained through investments incollective investment schemes(including ETFs) and derivatives.

0-20

Investments may be made through collective investmentschemes (including index funds such as exchange traded funds(ETFs) and actively managed funds managed by the InvestmentManager, but not actively managed funds managed by thirdparty investment managers).

The Fund may use derivatives for investment purposes and forefficient portfolio management. The Fund will use hedgingstrategies to reduce risk over the short term without materiallyaltering its risk profile.

The Fund will be managed without reference to a benchmark.

The Fund will be managed with a forward looking volatility capof 12%.

We may change the investment objective, investment strategy,authorised investments and asset allocation and the otherinformation in this section at any time. Any material changes willbe notified to unit holders in accordance with the requirementsof the Corporations Act. This may be after the change hasoccurred.

Risk management:• Hedging is a core part of the strategy and a valuable tool for

managing downside risks. Fulcrum’s team hasdemonstrated skill in being able to cost-effectively hedgeportfolios against severe shocks.

• By protecting portfolios from returns which fall outside aninvestor’s expectations, Fulcrum seeks to ensure aconstructive and very long term relationship with clients.

In order to manage these risks, Fulcrum follows a disciplinedprocess that seeks to maintain high levels of diversificationacross strategies. In addition, Fulcrum continuously monitorsthe following portfolio risks:

Concentration:

• This applies at the strategy level, as well as at the level ofindividual positions.

Volatility:

• Ex-ante volatility is capped at 12%, which helps reduce thelikelihood of sharp losses.

Expected Shortfall (ES) - measures the expected loss for theworst 1% of observations:

• The 99% daily ES is limited to 2.0%.

Key factor exposures:

• Fulcrum assesses the exposure to different risk factors. Forexample, exposure to equities, bonds, commodities and theUS dollar. Where significant factor exposures are identified,these are hedged using liquid options.

Macroeconomic and political:

• Fulcrum assesses the exposure of its portfolios to differentrisk scenarios using the expertise of Fulcrum’s in-house


strategists and economists. Recent examples have includedthe impact of a U.S. recession, Greek sovereign default andpositive European policy shock.

Leverage:

• The strategy does not borrow money, but can containimplicit leverage through the use of derivatives forinvestment purposes. It is not anticipated that grossleverage, as defined in Section 5.7, will exceed 500%, whilenet leverage (total long positions minus total shortpositions) will normally range between 80% to 200%.

Liquidity:

• The strategy invests primarily in highly liquid instruments.However, Fulcrum monitors the strategy’s ability to liquidatepositions over various horizons, including one day, two days,one week and one month.

5.3 Fund StructureInvestment StructureThe following diagram summarises the Fund structure at the date of this PDS:

Fulcrum Asset Management LLP

Investment Manager of the Fund

EQT Responsible Entity

JP Morgan Custodian and

Administrator of the Fund

Fulcrum Diversified Absolute Return Fund

Investor

Service providersAs at the date of this PDS, the service providers to the Fund are:

• Investment Manager: Fulcrum is responsible for managing the investments of the Fund. For further details on Fulcrum‘s roleplease refer to section 4.

• Custodian: JP Morgan holds the assets of the Fund on behalf of the Responsible Entity.

• Administrator: JP Morgan provides fund accounting and unit registry services in connection with the Fund.

The service providers engaged by the Responsible Entity may change without notice to investors. The Responsible Entity has enteredinto service agreements with the service providers and will, with the assistance of Fulcrum, regularly monitor the performance of theservice providers against service standards set out in the relevant agreements.

5.4 Valuation, location and custody of assetsJP Morgan is the Custodian and provides custodial and transfer agency services. The Administrator will value all the Fund’s assetsindependently and follow its own procedures for pricing and utilise its own database of market data, independent market datavendors and industry standard pricing models for verification and comparison which are comprised of direct exchange prices,broker/dealer pricing and counterparty valuation statements. Due to the listed nature of the instruments traded across Fulcrum’s fundrange the vast majority of prices can be taken direct from third party market vendors.

Fulcrum is not involved in the pricing of any instruments within the Fund. As part of an internal control function, the Firm’s operationsteam will analyse the respective prices and valuations provided by the Administrator to calculate the NAV and will independentlyreconcile these versus its own internal books and records using internal tolerance thresholds. Internal prices are sourced primarilyfrom Bloomberg. Any outliers are fully investigated and justified before Fulcrum gives its confirmation of the Administrator’scalculation of the NAV; Fulcrum cannot and does not alter the NAV.

The Fund invests globally in highly liquid instruments, seeking out the most cost-effective of the available implementation options.The investment universe includes global equities, global bonds (government securities and credit), commodities, currencies andliquid hedge fund strategies. Illiquid strategies, such as real estate and private equity, are excluded from the portfolio.

The custodial arrangements in respect of various asset classes are described in the table below.

Asset Class Responsible Custodian Location of Custodian

Assets as a proportionof Net Asset value of

the Fund

International listed equities J.P. Morgan Australia 0-60%

International governmentbonds

J.P. Morgan Australia 0-100%

Exchange-traded derivatives J.P. Morgan UK 0-100%

Over-the-counter(OTC) derivatives

J.P. Morgan / Barclays UK 0-40%


Asset Class Responsible Custodian Location of Custodian

Assets as a proportionof Net Asset value of

the Fund

Cash equivalent investments J.P. Morgan Australia 0-10% (excluding marginrequirements)

Other(Fulcrum Fund Holdings)

J.P. Morgan Luxembourg 0-100%

5.5 LiquidityThe Responsible Entity considers that the Fund meets and will continue to meet the requirements for liquidity under the CorporationsAct and the ASIC disclosure principals in RG 240. It is unlikely that liquidity issues will result from withdrawal requests. Generally, it isthe Investment Manager’s policy to ensure that the Fund remains liquid as the size of the Fund grows.

5.6 DerivativesThe Fund may use futures, options, swaps, forwards and other derivative instruments for investment purposes and for the purposes ofhedging against either price or currency fluctuations. The ability to use such strategies may be limited by market conditions,regulatory limits and tax considerations. Use of derivatives involves certain special risks, including (i) imperfect correlation betweenmovements in the securities or currency on which a futures or options contract is based and movements in the securities or currenciesin the Fund; (ii) the absence of a liquid market for any particular instrument at any particular time; (iii) while the Fund may not begeared in any way through the use of derivatives, the degree of leverage inherent in futures trading, i.e. the low margin depositsnormally required in futures trading, means that futures trading may be highly leveraged; accordingly, a relatively small pricemovement in a futures contract may result in an immediate and substantial loss to the Fund; and (iv) possible impediments to theability to meet redemption requests or other short-term obligations because of the percentage of the Fund’s assets segregated tocover its obligations. Hedging strategies necessarily add costs to the Fund.

For derivative instruments other than purchased options, any loss suffered may exceed the amount of the initial investment made orthe premium received by the Fund. OTC derivative instruments involve an increased risk that the counterparty will fail to perform itscontractual obligations. If a Fund enters into a transaction in OTC markets, a Fund is exposed to the credit of its counterparties, andtheir ability to satisfy the terms of such contracts. For example, a Fund may enter into agreements, or use other derivative techniques,each of which expose a Fund to the risk that the counterparty may default on its obligations to perform under the relevant contract. Inthe event of bankruptcy, or insolvency of a counterparty, a Fund could experience delays in liquidating the position and significantlosses, including declines in the value of its investment during the period in which the Fund seeks to enforce its rights, inability torealise any gains on its investment during such a period and fees and expenses incurred in enforcing its rights. There is also apossibility that the above-mentioned agreements and derivative techniques are terminated due, for instance, to bankruptcy,supervening illegality or change of tax or accounting laws relative to those at the time the agreement was originated. In suchcircumstances investors may be unable to recover any losses incurred.

5.7 LeverageThe strategy does not borrow money, but can be leveraged implicitly through the use of derivatives (including exchange tradedfutures and options as well as non-exchange traded (OTC) options, forwards and swaps). Gross leverage is defined as the sum of theabsolute values of all net portfolio positions (expressed as a percentage of NAV) following the Australian Securities and InvestmentCommission definition RG 240. It is not anticipated that gross leverage will exceed 500%, while net leverage, defined as total longpositions minus total short positions will normally range between 80% to 200%.

Leverage is used to reduce the volatility of the strategy by hedging certain risk exposures. In addition it is used to obtain cost efficientmarket exposure, for example by adding or reducing equity exposures for short periods and to express relative value trades withinequities, fixed income, commodities and currencies.

The use of derivatives may cause the nominal exposure of the Fund to be routinely in excess of 100% of the value of the assets.Leverage can increase the volatility of the Fund and thereby increase gains and losses from the underlying investment. The value andliabilities associated with such strategies can be more variable than regular investments and there may be greater exposure topossible losses.

The impact of maximum levels of leverage, all other factors being equal, are shown below:

Investment returnno leverage % pa

Return on investment of$1,000,000

Investment returnmaximum leverage 500%

Return on investment of$1,000,000

-2% -$20,000 -10% -$100,000

0 $0 0 0

+2% +$20,000 +10% $100,000

Collateral posted with counterparties is managed on a daily basis by assessing the required degree of collateralisation versus whathas been posted. Excess collateral over a tolerance level will be recalled. The remaining collateral will be encumbered. Collateral willbe posted in cash or bills subject to title transfer. If a bank or Institution with which the Fund’s client money is held becomes insolvent,there is a risk of loss of some or all of such money (subject to any deposit protection schemes that may apply) as well as a risk that itmay not be possible to set off amounts held by such approved bank or institution against amounts owed by the Fund to the derivativecounterparty.


Fulcrum favours the largest most creditworthy counterparties. They are selected on the basis of their financial standing, pricing,technical ability and client service. This decision is monitored on an ongoing basis. A number of indicators of credit strength arereviewed as part of the decision making process in transacting with counterparties.

5.8 Short sellingThe Fund does not use the investment technique short selling of equities. Short positions may be obtained through derivatives asdescribed above.

5.9 Labour standards and environmental, social and ethical considerationsThe issue of ethical investment, and particularly those areas of environmental, social and corporate governance, are fundamental tothe aspiration of responsible investing and receive our unqualified support. Furthermore we also believe that ultimately thosecompanies and economies with the highest standards in these areas will be successful with respect to long term relative performance.

Where relevant Fulcrum Asset Management has a policy of not investing in stocks involved in the tobacco or cluster munitions trades.

Given that the equity exposure within the Fulcrum Diversfied Absolute Return Fund is implemented passively (i.e. through investmentin ETFs, futures and swaps based on broad indices) it is not possible to bring labour standards, environmental, social and ethicalconsiderations into the decision making criteria for selecting, retaining or realising an investment within the Fund.

5.10 Fund performanceUp to date information on the performance of the Fund will be available by calling Fulcrum on +44 207 016 6450 or Ambassador on+61 2 9081 0230. Past performance is not indicative of future performance. The Responsible Entity and Investment Manager do notguarantee the success, repayment of capital or any rate of return on income or capital or the investment performance of the Fund.


6. Managing RiskInvestment in any fund carries risks, including volatility ofreturns. Volatility refers to the degree to which returns mayfluctuate around their long-term average. Each asset class,whether it is cash, fixed interest, property or Australian orinternational shares has associated investment risks and thereturn achieved by each will vary accordingly.

You should be aware that an investment in the Fund containsrisks and neither the performance of the Fund nor the security ofyour investment is guaranteed by Equity Trustees or theInvestment Manager. Investments in the Fund are generallysubject to risks, including possible delays in the payment ofwithdrawal proceeds and loss of income and/or capital. Thefollowing discussion of certain risk factors does not purport tobe an exhaustive list or a complete explanation of all the risksinvolved in an investment in the Fund. We recommend you talkto an adviser about the risks involved in investing in the Fundand how it might impact on your individual financialcircumstances.

Market riskInvestors should be aware that there are risks inherent in theholding of securities:

An investment may fall in value due to changes in marketsentiment or economic, technological, political or legalconditions.

Past performance is no guide to the future. The value of units,and any income from them, can go down as well as up,particularly in the short term, meaning that an investment maynot be returned in full.

The tax treatment of the Fund may change and such changescannot be foreseen.

Where regular investments are made with the intention ofachieving a specific capital sum in the future, this will normallybe subject to maintaining a specified level of investment.

International InvestmentsThe Fund invests in international investments which may involvecertain risks, including fluctuations in foreign exchange rates,future political and economic developments and the possibleimposition of exchange controls or other governmental laws orrestrictions. Security prices in different countries are subject todifferent economic, financial, political and social factors. Inaddition, investments may be subject to non-recoverablewithholding taxes.

Liquidity riskInvestments that trade less can be more difficult or more costlyto buy, or to sell, than more liquid or active investments. It maynot be possible to sell or otherwise dispose of illiquid securitiesboth at the price and within a time period deemed desirable bythe Investment Manager.

Portfolio turnover riskThe Fund does not intend to trade, directly or indirectly,portfolio securities for the purpose of realising short-termprofits. However, the Investment Manager will adjust the Fund’sportfolio as considered advisable in view of prevailing oranticipated market conditions and the Fund’s investmentobjective, and there is no limitation on the length of timesecurities must be held, directly or indirectly, by the Fund priorto being sold. Portfolio turnover rate will not be a limiting factorand will vary from year to year. Higher portfolio turnover ratesinvolve correspondingly higher transaction costs, which areborne directly or indirectly by the Fund. In addition, the Fundmay realise significant short term and long-term capital gains.

Derivatives riskThe Fund may use futures, options, swaps, forwards and otherderivative instruments for investment purposes and for thepurposes of hedging against either price or currencyfluctuations. The Investment Manager’s ability to use suchstrategies may be limited by market conditions, regulatory limitsand tax considerations. Use of derivatives involves certainspecial risks, including (i) imperfect correlation betweenmovements in the securities or currency on which a futures oroptions contract is based and movements in the securities orcurrencies in the Fund; (ii) the absence of a liquid market for anyparticular instrument at any particular time; (iii) while the Fundwill not be geared excessively through the use of derivatives, thedegree of leverage inherent in futures trading, i.e., the lowmargin deposits normally required in futures trading, means thatfutures trading may be highly leveraged; accordingly, a relativelysmall price movement in a futures contract may result in animmediate and substantial loss to the Fund; and (iv) possibleimpediments to the ability to meet redemption requests orother short-term obligations because of the percentage of theFund’s assets segregated to cover its obligations. Hedgingstrategies necessarily add costs to the Fund.

For derivative instruments other than purchased options, anyloss suffered may exceed the amount of the initial investmentmade or the premium received by the Fund. OTC derivativeinstruments involve an additional risk that the counterparty willfail to perform its contractual obligations. If a Fund enters into atransaction in OTC markets, a Fund is exposed to the credit ofits counterparties, and their ability to satisfy the terms of suchcontracts. For example, a Fund may enter into agreements, oruse other derivative techniques, each of which exposes a Fundto the risk that the counterparty may default on its obligations toperform under the relevant contract. In the event of bankruptcy,or insolvency of a counterparty, a Fund could experience delaysin liquidating the position and significant losses, includingdeclines in the value of its investment during the period in whichthe Fund seeks to enforce its rights, inability to realise any gainson its investment during such a period and fees and expensesincurred in enforcing its rights. There is also a possibility that theabove-mentioned agreements and derivative techniques areterminated due, for instance, to bankruptcy, superveningillegality or change of tax or accounting laws relative to those atthe time the agreement was originated. In such circumstancesinvestors may be unable to recover any losses incurred.

Some derivative instruments are not readily marketable or maybecome illiquid under adverse market conditions. In addition,during periods of market volatility, a commodity exchange maysuspend or limit trading in an exchange-traded derivativeinstrument which may make the contract temporarily illiquid anddifficult to price. Commodity exchanges may also establish dailylimits on the amount that the price of a futures contract or anoption thereon can vary from the previous day’s settlementprice. Once the daily limit is exceeded, no trades may be madethat day at a price beyond the limit. This may prevent the Fundfrom closing out positions and limiting its losses.

Fixed interest securities riskFixed interest securities are particularly affected by trends ininterest rates and inflation. If interest rates increase, capitalvalues may fall and vice versa. Inflation will erode the real valueof capital. In addition, companies may not be able to honourrepayment on bonds they issue.


Foreign exchange riskThe NAV of the Fund will be computed in the base currencywhereas the investments held for the account of the Fund maybe acquired in other currencies. The Fund’s NAV may changesignificantly when the currencies other than the base currency inwhich some of the Fund’s investments are denominatedstrengthen or weaken against the base currency. Currencyexchange rates generally are determined by supply anddemand in the foreign exchange markets and the perceivedrelative merits of investments in different countries. Currencyexchange rates can also be affected unpredictably byintervention by government or central banks or by currencycontrols or political developments.

In addition currency hedging transactions, while potentiallyreducing the currency risks to which the Fund would otherwisebe exposed, involve certain other risks, including the risk of adefault by a counterparty. In addition, where the Fund entersinto “cross-hedging” transactions (e.g., utilising a currencydifferent from the currency in which the security being hedged isdenominated), the Fund will be exposed to the risk that changesin the value of the currency used to hedge will not correlate withchanges in the value of the currency in which the securities aredenominated, which could result in loss on both the hedgingtransaction and the Fund securities.

Forward currency contracts and currency futures involve thepossibility that the market for them may be limited with respectto certain currencies and, upon a contract’s maturity, thepossible inability to negotiate with the dealer to enter into anoffsetting transaction. There is no assurance that an activeforward currency contract market will always exist. These factorsrestrict the ability to hedge against the risk of devaluation of

currencies in which a substantial quantity of securities are beingheld for the Fund and are unrelated to the qualitative rating thatmay be assigned to any particular security.

Currency riskCurrency fluctuations may adversely affect the value of theFund’s investments and the income thereon depending on aninvestor’s currency of reference.

Emerging markets riskInvestment in emerging markets carries a higher risk thaninvesting in mature markets. This is mainly because of thevolatility of the markets and local regulations, and custody andregistration arrangements, which may be less developed than inmore mature markets.

Legal riskThere is a risk that laws, including tax laws, might change orbecome difficult to enforce.

Net Asset ValueWhilst the Fund may use the latest available published price inrespect of each investment in order to calculate the NAV itreserves the right to use more recent valuations where this isconsidered appropriate. Such valuations may be based on anestimate of a more recent price of any unit or share in anunderlying investment fund or other collective investmentundertaking in which the Fund invests obtained from orcalculated on the basis of more recent information receivedfrom the underlying fund or undertaking or any of its serviceproviders or agents.


7. Investing and WithdrawingInitial applicationsThe offer in this PDS is only available to Australian WholesaleClients and New Zealand Wholesale Investors.

Investors can acquire units by completing an Application Form.The minimum investment amount for the Fund is $5,000,000.

To invest directly please complete the Application Formaccompanying this PDS and send your original ApplicationForm to:

Fulcrum Diversified Absolute Return Fund RegistryC/- Link Market Services LimitedPO Box 3721Rhodes NSW 2138.

Application money should be transferred to the bank accountdetails shown in the Application Form. Please note that neithercash nor cheques will be accepted.

The price at which units are acquired is determined inaccordance with the Constitution (“Application Price”). TheApplication Price, in general terms, is equal to the NAV of theFund, divided by the number of units on issue plus anytransaction costs.

Unit prices are calculated daily.

Applications can be made on any Business Day. However, forunit pricing purposes and income accrual purposes, anyapplication received after 2:00pm on a Business Day willgenerally be treated as having been received the followingBusiness Day.

Transaction costs may reduce the number of units which aninvestor receives when applying for units. See the ‘Buy/SellSpread’ information in the fees section for further information.

The Application Price will vary as the market value of assets inthe Fund rises or falls.

Additional applicationsYou can add to your investment by completing an ApplicationForm accompanying the current PDS. At the date of this PDS,the minimum additional investment in the Fund is $10,000.

Terms and conditions for applicationsFor additional applications the duly completed ApplicationForm may be faxed to +61 2 9287 0341. If payment is beingmade by direct credit, details may be faxed to LINK MarketServices Limited for the attention of the Unit Registry Team viathe following number: +61 2 9287 0341. Please note that we donot pay interest on application monies/any interest is credited tothe Fund.

Equity Trustees reserves the right to refuse any applicationwithout giving a reason. If for any reason Equity Trustees refusesor is unable to process your application to invest in the Fund,Equity Trustees will return your application money to you,subject to regulatory considerations. You will not be entitled toany interest on your application money in this circumstance.

Under the Anti-Money Laundering and Counter-TerrorismFinancing Act 2006, applications made without providing all theinformation and supporting identification documentationrequested on the Application Form cannot be processed untilall the necessary information has been provided. As a resultdelays in processing your application may occur.

Cooling off periodNo cooling off period applies to the offer made in this PDS asonly Australian Wholesale Clients and New Zealand WholesaleInvestors may make an investment in the Fund.

Making a withdrawalInvestors of the Fund can withdraw their investment by faxing arequest to:

LINK Market Services Limited for the attention of the UnitRegistry Team via the following number: +61 2 9287 0341. Theminimum withdrawal amount is $10,000. Refer below for ‘Termsand conditions for withdrawals’. All withdrawal requests must besigned by the investor(s) and withdrawals will only be paiddirectly to the investor(s) bank account held in the name of theinvestor(s) with an Australian domiciled bank. Withdrawalpayments will not be made to third parties.

The price at which units are withdrawn is determined inaccordance with the Constitution (“Withdrawal Price”). TheWithdrawal Price, in general terms, is equal to the NAV dividedby the number of units on issue less any transaction costs.

Unit prices are calculated daily.

Withdrawals requests can be made on any Business Day.However, for unit pricing purposes and income accrualpurposes, any withdrawal request received after 2:00pm on aBusiness Day will generally be treated as having been receivedthe following Business Day.

Transaction costs may reduce the amount which an investorreceives on withdrawal. See the ‘Buy/Sell Spread’ information inthe fees section for further information.

The Withdrawal Price will vary as the market value of assets inthe Fund rises or falls.

Access to fundsEquity Trustees will generally pay withdrawals within 7 days ofreceipt of a withdrawal request for the relevant amount.However, the Constitution of the Fund allows Equity Trustees tomake payment up to 21 days after receipt of a withdrawalrequest (which may be extended by a further 30 days or more incertain circumstances if the Responsible Entity considers it is inthe best interest of members, such as when there is restricted orsuspended trading in assets held by the Fund).

Equity Trustees reserves the right to fully redeem yourinvestment upon 30 days’ notice if your investment balance inthe Fund falls below $2,500,000 as a result of processing yourwithdrawal request.

Terms and conditions for withdrawalsOnce your withdrawal request is received, your instruction maybe acted on without further enquiry if the instruction bears youraccount number or investor details and your (apparent)signature(s), or your authorised signatory’s (apparent)signature(s).

Equity Trustees and/or the Administrator reserve the right to askfor the production of original documents or other information toauthenticate the communication. In the case of non-receipt orcorruption of any message, you will be required to re-send thedocuments.

No withdrawal proceeds will be paid until the Administrator hasreceived the withdrawal request signed by you or yourauthorised signatory. Neither Equity Trustees nor theAdministrator shall be responsible for any mis-delivery ornon-receipt of any facsimile or email. Facsimiles or emails sentto the Administrator shall only be effective when actuallyreceived by the Administrator.


When you are withdrawing, you should take note of thefollowing:

• We are not responsible or liable if you do not receive, or arelate in receiving, any withdrawal money that is paidaccording to your instructions.

• We may contact you to check your details before processingyour withdrawal request. This may cause a delay in finalisingpayment of your withdrawal money. No interest is payablefor any delay in finalising payment of your withdrawalmoney.

• If we cannot satisfactorily identify you as the withdrawinginvestor, we may refuse or reject your withdrawal request orpayment of your withdrawal proceeds will be delayed. Weare not responsible for any loss you consequently suffer.

• As an investor who is withdrawing, you agree that anypayment made according to instructions received by fax,shall be a complete satisfaction of our obligations, despiteany fact or circumstances such as the payment being madewithout your knowledge or authority.

• You agree that if the payment is made according to theseterms, you and any person claiming through or under you,shall have no claim against us about the payment.

• The Constitution allows Equity Trustees to make paymentup to 21 days after we accept a request (which may beextended by a further 30 days in certain circumstances).

• Equity Trustees can deny a withdrawal request whereaccepting the request would cause the Fund to cease to beliquid or where the Fund is not liquid (as defined in theCorporations Act). When the Fund is not liquid, you can onlywithdraw when Equity Trustees makes a withdrawal offer toyou in accordance with the Corporations Act. EquityTrustees is not obliged to make such offers. The Fund will beliquid if at least 80% of its assets are liquid assets (generallycash and marketable securities).

DistributionsThe Fund usually distributes income at least annually at the endof June. Distributions are calculated on the last day of theperiod end (30 June), and are normally paid to investors within14 Business Days of the period end. Equity Trustees may amendthe distribution frequency without notice.

Your share of any distributable income is calculated inaccordance with the Constitution and is generally based on thenumber of units held by you at the end of the distribution periodand the distributable income.

You can have your distribution reinvested or paid to anominated bank account. If you do not indicate a preferenceyou will have your distributions automatically reinvested.

In some circumstances, where you make a large withdrawalrequest (5% or more of the units on issue in the Fund at the startof the relevant distribution period), your withdrawal proceedsmay be taken to include a component of distributable income.

Valuation of the FundThe value of the investments of the Fund is generallydetermined daily.

The value of a unit in the Fund is determined on the basis of thevalue of the investments in the Fund (after taking into accountany liabilities of the Fund), in accordance with the Constitutionof the Fund. For example, the Application Price of a unit in theFund is based on the NAV of the Fund divided by the number ofunits on issue plus an allowance for transaction costs requiredfor buying investments. This allowance is known as the “BuySpread”. At the date of this PDS, there is no Buy Spread. TheBuy/Sell Spread will be reviewed on a regular basis and may

change as a result of the investment strategy of the Fund. TheResponsible Entity has the discretion to change the Buy/SellSpread without providing notice. You can view the currentBuy/Sell Spread on Fulcrum’s website located atwww.eqt.com.au/insto.

Joint account operationFor joint accounts, unless indicated to the contrary on theApplication Form, each signatory must sign withdrawalrequests. Please ensure all signatories sign the declaration in theApplication Form. Joint accounts will be held as joint tenantsunless we are advised to the contrary in writing.

Appointment of authorised nominee to operateaccountYou can appoint a person, partnership or company as yourauthorised signatory. To do so, please nominate them on theinitial Application Form and have them sign the relevantsections. If a company is appointed, the powers extend to anydirector and officer of the company. If a partnership isappointed, the powers extend to all partners. Suchappointments will only be cancelled or changed once wereceive written instructions from you to do so.

Once appointed, your authorised signatory has full access tooperate your investment account for and on your behalf. Thisincludes the following:

• making additional investments;

• requesting income distribution instructions to be changed;

• withdrawing all or part of your investment;

• changing bank account details;

• enquiring and obtaining copies of the status of yourinvestment; and

• having online account access to your investment.

If you do appoint an authorised signatory:

• you are bound by their acts;

• you release, discharge and indemnify us from and againstany losses, liabilities, actions, proceedings, account claimsand demands arising from instructions received from yourauthorised representatives; and

• you agree that any instructions received from yourauthorised representative shall be complete satisfaction ofour obligations, even if the instructions were made withoutyour knowledge or authority.

Electronic instructionsIf you instruct Equity Trustees by electronic means, such asfacsimile or via the internet, you release Equity Trustees fromand indemnify Equity Trustees against, all losses and liabilitiesarising from any payment or action Equity Trustees makes basedon any instruction (even if not genuine):

• that Equity Trustees receives by an electroniccommunication bearing your investor code; and

• which appears to indicate to Equity Trustees that thecommunication has been provided by you (for example, ithas a signature which is apparently your signature or yourauthorised signatory’s or it has an email address which isapparently your email address).

You agree that neither you nor anyone claiming through you hasany claim against Equity Trustees or the Fund in relation to suchpayments or actions.

There is a risk that a fraudulent withdrawal request can be madeby someone who has access to your investor code and a copy ofyour signature or email address. Please take care.


8. Keeping Track of Your InvestmentEnquiriesFor any enquiries regarding your investment or themanagement of the Fund please contact Ambassador on+61 2 9081 0230.

Complaints resolutionEquity Trustees has an established complaints handling processand is committed to properly considering and resolving allcomplaints. If you have a complaint about your investment,please contact us on:

Phone: 1300 133 472Post: Equity Trustees LimitedGPO Box 2307, Melbourne VIC 3001Email: [email protected]

We will acknowledge receipt of the complaint as soon aspossible and in any case within 3 days of receiving thecomplaint. We will seek to resolve your complaint as soon aspracticable but not more than 45 days after receiving thecomplaint.

If you are not satisfied with our response to your complaint, youmay be able to lodge a complaint with the FinancialOmbudsman Service (“FOS”) or from 1 November 2018, directthe complaint to the Australian Financial Complaints Authority(“AFCA”), which will replace FOS.

Contact details are:Online: www.fos.org.au or www.afca.org.auPhone: FOS on 1800 367 287 or AFCA on 1800 931 678Email: [email protected] or [email protected]: GPO Box 3, Melbourne VIC 3001.

The external dispute resolution body is established to assist youin resolving your complaint where you have been unable to doso with us. However, it’s important that you contact us first.

ReportsRegular, simple to read and complete reports are provided toinvestors in the Fund. These reports comprise:

• Annual Report including financial statements and auditor’sreport will be made available on the Equity Trustees websiteat www.eqt.com.au/insto from 30 September each year.

• Transaction Reports confirming all additional investments,withdrawals, and payments (issued following transactionsand on request).

• Distribution Statements issued annually, notifying you of thevalue of your investment, income from investments andconfirming the reinvestment or payment to your nominatedaccount.

• Tax Statements issued annually, providing you with taxationinformation including a detailed summary of thecomponents of any distributions.

The Responsible Entity also has and implements a policy toreport annually on the following information as soon aspracticable after the relevant period end:

• the actual allocation to each asset type;

• the liquidity profile of the portfolio assets as at the end ofthe period;

• the maturity profile of the liabilities as at the end of theperiod;

• the leverage ratio (including leverage embedded in theassets of the Fund, other than listed equities and bonds) asat the end of the period;

• the derivative counterparties engaged (including capitalprotection providers);

• the monthly or annual investment returns of the Fund overat least a five-year period (or, if the Fund has not beenoperating for five years, the returns since its inception); and

• the key service providers if they have changed since thelatest report given to you, including any change in theirrelated party status.

The following information is available on Equity Trustees’website at www.eqt.com.au/insto and is disclosed monthly:

• the current total NAV of the Fund and the redemption valueof a unit in each class of units as at the date the NAV wascalculated;

• the key service providers if they have changed since the lastreport given to investors, including any change in theirrelated party status; and

• for each of the following matters since the last report onthose matters:

• the net return on the Fund’s assets after fees, costs andtaxes;

• any material change in the Fund’s risk profile;

• any material change in the Fund’s strategy; and

• any change in the individuals playing a key role ininvestment decisions for the Fund.

The Fund is not a disclosing entity. If the Fund becomes adisclosing entity, the Fund will be subject to regular reportingand disclosure obligations under the Corporations Act, copiesof documents lodged with the Australian Securities andInvestments Commission (“ASIC”) in relation to the Fund maybe obtained from, or inspected at, an ASIC office and you canobtain the following a copy of the following documents free ofcharge on request:

• the most recent annual financial report lodged with ASIC;

• any half yearly financial report lodged with ASIC after thatfinancial report but before the date of this PDS; and

• any continuous disclosure notices lodged with ASIC afterthat financial report but before the date of this PDS.

You can call Ambassador at +61 2 9081 0230 for updatedinformation on performance, unit prices, Fund size and othergeneral information about the Fund.


9. Fees and Other CostsThe warning statement below is required by law to be displayed at the beginning of the ‘Fees and other costs’ section of productdisclosure statements for managed investment products. The example given in the warning statement does not relate to anyinvestments described within this PDS.

DID YOU KNOW?Small differences in both investment performance and fees and costs can have a substantial impact on your long term returns.

For example, total annual fees and costs of 2% of your account balance rather than 1% could reduce your final return by up to20% over a 30 year period (for example, reduce it from $100,000 to $80,000).

You should consider whether features such as superior investment performance or the provision of better member servicesjustify higher fees and costs.

You may be able to negotiate to pay lower contribution fees and management costs where applicable. Ask the fund or yourfinancial adviser.

TO FIND OUT MOREIf you would like to find out more, or see the impact of the fees based on your own circumstances, the Australian Securities andInvestments Commission (ASIC) website (www.moneysmart.gov.au) has a managed funds fee calculator to help you check outdifferent fee options.

The information in the following template can be used to compare costs between different simple managed investment schemes.Fees and costs can be paid directly from an investor’s account or deducted from investment returns. For information on tax please seeSection 10 of this PDS.

Type of fee or cost Amount How and when paid

Fees when your money moves in or out of the Fund

Establishment feeThe fee to open your investment

Nil There is no establishment fee payablewhen you set up your investment in theFunds.

Contribution feeThe fee on each amount contributed toyour investment

Nil There is no contribution fee payablewhen you invest in the Funds.

Withdrawal feeThe fee on each amount you take out ofyour investment

Nil There is no withdrawal fee payable whenyou redeem investments from the Funds.

Exit feeThe fee to close your investment

Nil There is no termination fee payable whenyou close your investment in the Funds.

Management costs1

The fees and costs for managing yourinvestment

Fees, costs and expenses:

1.00% p.a. of the value of your units in theFund

2

Indirect costs:

0.28% p.a. of the value of your units in theFund

1 All fees quoted above are inclusive of Goods and Services Tax (GST) and net of any Reduced Input Tax Credits (RITC) at theprescribed rate, which is currently either 55% or 75% (depending on the nature of the fee or expense).2 Management fees can be negotiated. See “Differential fees” below. This amount includes Responsible Entity fees, investmentmanagement fees, custodian fees, administration fees and other expenses. However, it does not cover indirect costs, includingperformance related fees which are payable as an expense of the Fund to the Investment Manager. See below for more details as tohow Management Costs (including indirect costs) are calculated.

Additional explanation of fees and costsWhat do the management costs pay for?Management costs comprise the additional fees or costs that an investor incurs by investing in the Fund rather than by investingdirectly in the underlying assets of the Fund. Management costs include management fees and indirect costs.

In addition, management costs do not include transactional and operational costs (i.e. costs associated with investing the underlyingassets, some of which may be recovered through Buy/Sell Spreads).

Management feesThe management fees of 1.00% p.a. of the NAV of the Fund are payable to the Responsible Entity of the Fund for managing the assetsand overseeing the operations of the Fund. The management fees are accrued daily and paid from the Fund monthly in arrears and


reflected in the unit price. As at the date of this PDS, ordinary expenses such as investment management fees, custodian fees,administration and audit fees, and other ordinary expenses of operating the Fund are covered by the management fees at noadditional charge to you.

The management fees shown above do not include extraordinary expenses (if they are incurred in future), such as litigation costs andthe costs of convening investor meetings.

Indirect CostsIndirect costs include fees and other management costs (if any) arising from underlying funds and, if applicable, a reasonable estimateof the cost of investing in over-the-counter derivatives to gain investment exposure to assets or implement the Fund’s investmentstrategy. Indirect costs are reflected in the unit price of the Fund and borne by investors, but they are not paid to the ResponsibleEntity or Investment Manager.

The estimated components of the Fund’s indirect costs are based on the financial year ended 30 June 2018.

Actual indirect costs for future years may differ. If in future there is an increase to indirect costs disclosed in this PDS, updates will beprovided on Equity Trustees’ website at www.eqt.com.au/insto where they are not otherwise required to be disclosed to investorsunder law.

Transactional and operational costsIn managing the assets of the Fund, the Fund may incur transactional and operational costs such as brokerage, settlement costs,clearing costs and applicable stamp duty when assets are bought and sold, and the costs of derivatives used for hedging purposes (ifapplicable). This generally happens when the assets of a fund are changed in connection with day-to-day trading or when there areapplications or withdrawals which cause net cash flows into or out of a fund.

The Buy/Sell Spread reflects the estimated transaction costs incurred in buying or selling assets of the Fund when investors invest in orwithdraw from the Fund. The Buy/Sell Spread is an additional cost to the investor but is incorporated into the unit price and incurredwhen an investor invests in or withdraws from the Fund and is not separately charged to the investor. The Buy Spread is paid into theFund as part of an application and the Sell Spread is left in the Fund as part of a redemption and not paid to Equity Trustees or theInvestment Manager. The estimated Buy/Sell Spread is nil upon entry and nil upon exit. The dollar value of these costs based on anapplication or a withdrawal of $5,000,000 is $0 for each individual transaction. The Buy/Sell Spread can be altered by the ResponsibleEntity at any time. The Responsible Entity may also waive the Buy/Sell Spread in part or in full at its discretion.

Transactional costs which are incurred other than in connection with applications and withdrawals arise through the day-to-day tradingof the Fund’s assets and are reflected in the Fund’s unit price. As these costs are factored into the NAV of the Fund and reflected in theunit price, they are an additional implicit cost to the investor and are not a fee paid to the Responsible Entity. These costs can arise as aresult of bid-offer spreads (the difference between an asset’s bid/buy price and offer/ask price) being applied to securities traded bythe Fund. Liquid securities generally have a lower bid-offer spread while less liquid assets have a higher bid-offer spread reflecting thecompensation taken by market makers in providing liquidity for that asset.

During the financial year ended 30 June 2018, the total transaction costs for the Fund were estimated to be 0.19% of the NAV of theFund, of which none of these transaction costs were recouped via the Buy/Sell Spread, resulting in a net transactional cost to the Fundof 0.19% p.a.

Can the fees change?Yes, all fees can change without investor consent, subject to the maximum fee amounts specified in the Constitution. Equity Trusteeshas the right to recover all reasonable expenses incurred in relation to the proper performance of its duties in managing the Fund andas such these expenses may increase or decrease accordingly. We will generally provide investors with at least 30 days’ notice of anyproposed change to the management costs. In most circumstances, the Constitution defines the maximum level that can be chargedfor fees described in this PDS. Expense recoveries may change without notice, for example, when it is necessary to protect theinterests of existing members and if permitted by law.

GSTAll fees and other costs quotes include GST less any RITC.

Example of annual fees and costsThis table gives an example of how the fees and costs for this managed investment product can affect your investment over a one yearperiod. You should use this table to compare this product against other managed investment products.

Example – Fulcrum Diversified Absolute Return Fund

BALANCE OF $2,500,000 WITH A CONTRIBUTION OF $5,000 DURING THE YEAR

Contribution Fees Nil For every $5,000 you put in, you will be charged $0.

Plus

ManagementCosts comprising:

1.28% And, for every $2,500,000 you have in the Fund you will be charged $32,000 each year,comprising:

Fees and costs ofmanaging yourinvestment:

1.00% p.a. $25,000

Indirect costs: 0.28% p.a. $7,000


Example – Fulcrum Diversified Absolute Return Fund

EqualsCost of Fund

If you had an investment of $2,500,000 at the beginning of the year and you put in anadditional $5,000* during that year, then you would be charged fees of:$32,000**What it costs you will depend on any differential fees you may negotiate.

* This example assumes the $5,000 contribution occurs at the end of the first year, therefore management costs are calculated usingthe $2,500,000 balance only.

**Additional fees may apply. Please note that this example does not capture all the fees and costs that may apply to you such as theBuy/Sell Spread.

Warning: If you have consulted a financial adviser, you may pay additional fees. You should refer to the Statement of Advice orFinancial Services Guide provided by your financial adviser in which details of the fees are set out.

ASIC provides a fee calculator on www.moneysmart.gov.au, which you may use to calculate the effects of fees and costs on accountbalances.


10. TaxationThe following information summarises some of the Australiantaxation issues you may wish to consider before making aninvestment in the Fund and assumes that you hold yourinvestment in the Fund on capital account and are notconsidered to be trading in investments for tax purposes. Theinformation should be used as a guide only and does notconstitute professional tax advice as individual circumstancesmay differ.

A number of tax reform measures are currently under review bythe Australian Government, including the previously proposednew regime for the taxation of Managed Investment Trusts(“MITs”), the taxation of trusts more broadly and rules relating tothe treatment of foreign sourced income. These reforms mayimpact on the tax position of the Fund and its investors.Accordingly, it is recommended that investors seek their ownprofessional tax advice, specific to their own circumstances, ofthe taxation implications of investing in the Fund.

Taxation of the FundGeneralThe Fund is a resident trust estate for Australian tax purposes.On the basis that the Fund has distributable income andinvestors are presently entitled to all of the Fund’s distributableincome, (which is the Responsible Entity’s intention) and theFund is not a public trading trust; the Fund should be taxed as aflow-through trust. This means that investors should be taxed ontheir share of the Fund’s net taxable income, and the Fundshould not be subject to Australian income tax.

In the case where the Fund makes a loss for Australian taxpurposes, the Fund cannot distribute the tax loss to investors.However, the tax loss may be carried forward by the Fund foroffset against taxable income of the Fund in subsequent years,subject to meeting certain trust loss recoupment tests.

Deemed Capital Gains Tax (“CGT”) ElectionEligible MITs may make an irrevocable election to apply adeemed capital account treatment for gains and losses ondisposal of certain eligible investments (including equities andunits in other trusts and some rights and options over equitiesand units in other trusts but excluding derivatives and foreignexchange contracts). It is intended that the Fund should qualifyas a MIT as defined under the Australian tax law and make theMIT election for deemed capital account treatment (“MITcapital election”).

As a result, an investor’s share of the net income of the Fund mayinclude an amount that consists of net capital gains, whichincludes discount capital gains and capital gains tax (“CGT”)concession amounts, derived by the Fund.

To the extent the Fund’s investment strategy includesinvestments to which the MIT capital election may not apply(e.g. exchange traded options and certain futures), dependingon the circumstances, these investments may be on revenueaccount.

Taxation of Financial Arrangements (“TOFA”)Broadly, under TOFA, the gains or losses (including incomeand/or deductions) on financial arrangements are brought toaccount under a compounding accruals and realisation basis.Any gain or losses in relation to a financial arrangement, such asdebt securities, where TOFA applies would generally be treatedon revenue account (and would not be covered by the MITcapital election). This could also include options over shares incertain circumstances.

The TOFA provisions may apply to the Fund in future. TheInvestment Manager and Tax Adviser of the Fund will assist theResponsible Entity with ongoing monitoring and compliancewith the TOFA rules.

Tax File Numbers (“TFN”) and Australian BusinessNumbers (“ABN”)It is not compulsory for an investor to quote their TFN or ABN. Ifan investor is making this investment in the course of a businessor enterprise, the investor may quote an ABN instead of a TFN.Failure by an investor to quote an ABN or TFN or claim anexemption may cause the Responsible Entity to withhold tax atthe top marginal rate, plus the Medicare Levy, on grosspayments including distributions of income to the investor. Theinvestor may be able to claim a credit in their tax return for anyTFN or ABN tax withheld.

Foreign Account Tax Compliance ActThe United States of America enacted the Foreign Account TaxCompliance Act (“FATCA”) in 2010 to identify U.S. residents thatinvest in assets through non-U.S. entities. In April 2014, theAustralian Government signed an intergovernmental agreement(IGA) with the U.S., which requires all Australian financialinstitutions to comply with FATCA, as modified by the IGA.

Broadly, the Fund is required to collect and review informationto determine whether it has an obligation to report informationabout certain investors in the Fund to the ATO (which will passthat information onto the IRS). Accordingly, the Fund mayrequest certain information from you to enable the Fund tocomply with its FATCA obligations.

Failure to comply with FATCA obligations may result in theFund, to the extent relevant, being subject to a 30% withholdingtax on payment of U.S. income or gross proceeds from the saleof certain U.S. investments. The Fund will provide informationabout its FATCA status where required so that FATCAwithholding is not applied to the relevant U.S. income or grossproceeds.

Taxation of Australian Resident InvestorsDistributionsEach Australian resident investor will be subject to taxation ontheir proportionate share of the net taxable income derived bythe Fund.

Investors who become entitled to a distribution from the Fund inrespect of a financial year will receive an annual tax statementdetailing all relevant taxation information concerningdistributions.

The tax consequences for investors of receiving distributionsfrom the Fund depend on the components of the distributableincome to which investors have become entitled.

Foreign Source Income and Foreign Income Tax Offset(“FITO”)The Fund is expected to derive income that consists of foreignsource income that may be subject to tax overseas, for examplewithholding tax, which under some circumstances may bedistributed to investors. Where a distribution to the investorconsists of a FITO, the investor may be entitled to a FITO for thetax paid. The FITO may be used to offset the Australian taxpayable on the foreign source income. Investors should includetheir share of both the foreign income and the amount of theFITO (if any) in their assessable income. To the extent to whichthe investor does not have sufficient foreign source income toutilise all of the FITOs relevant to a particular year of income, theexcess FITOs cannot be carried forward to a future income yearand as such will be lost.


Non Assessable DistributionsUnder current practice, distributions of non-assessable amountsare generally not subject to tax in the hands of passive investors.Broadly, the receipt of certain non-assessable amounts willgenerally reduce the cost base of the Australian residentinvestor’s units in the Fund for CGT purposes. This results ineither an increased capital gain, or a reduced capital loss, uponthe subsequent disposal of the investor’s units in the Fund.However, in certain circumstances, such amounts may beassessable to an investor rather than giving rise to a CGT costbase adjustment.

Capital GainsAn investor’s share of the net taxable income of the Fund mayinclude an amount that consists of net capital gains, derived bythe Fund. Where the Fund’s net taxable income includes capitalgains (including any discount capital gains), the investor needsto ‘gross up’ any discount capital gain (by the amount of anyreduction in the discount capital gain that the Fund obtained).Regardless of whether the ‘discount concession’ amount isdistributed by the Fund, individual, trust, and complyingsuperannuation fund investors may be entitled to the discountcapital gain concessions in determining their net capital gain.Investors may also be able to offset certain other capital lossesthey may have against their share of the capital gains included inthe net taxable income distributed by the Fund (after grossingup any discount capital gains).

Disposal of Units by Australian Resident InvestorsIf an Australian resident investor transfers or redeems their unitsin the Fund, this will generally constitute a disposal for taxpurposes. Where an investor holds their units in the Fund oncapital account, a capital gain or loss on the disposal may ariseand each investor should calculate their capital gain or lossaccording to their own particular facts and circumstances. Incalculating the taxable amount of a capital gain, a discount of50% for individuals and trusts or 33 1/3% for complyingAustralian superannuation funds may be allowed where theunits in the Fund have been held for more than 12 months. NoCGT discount is available to companies.

If an Australian resident investor realises a capital loss on theirinvestment, the loss may be applied against other capital gainsthe investor may have. Unused capital losses can be carriedforward and may be utilised in a future income year.

Australian Taxation of Non-Resident InvestorsNon-resident investorsThe following comments are general in nature and non-residentinvestors should seek independent tax advice before investing,taking into account their particular circumstances and theprovisions of any relevant Double TaxationAgreement/Exchange of Information Agreement (“EOI”)between Australia and their country of residence.

Tax on incomeThe Fund expects to derive predominantly foreign sourceincome which would generally not be subject to Australianwithholding tax when distributed by the Fund to non-residentinvestors.

The Fund is required to withhold Australian tax fromdistributions to non-resident investors for certain types ofAustralian sourced net taxable income, including Australiansourced interest income or other Australian sourced income.The rate of tax deducted will depend on the type of incomedistributed and the country of residence of the investor.

Capital gainsBased on the Fund’s investment profile, generally non-residentinvestors should not be subject to Australian capital gains tax onthe disposal of units in the Fund unless the units were capitalassets held by the investor in carrying on a business through apermanent establishment in Australia. Australian tax may applyin certain circumstances if the non-resident holds their units onrevenue account.

The CGT discount is not available for non-resident investors. It isstrongly recommended that non-resident investors seek theirown tax advice.


11. Other Important InformationConsentsFulcrum Asset Management LLP has given and, at the date ofthis PDS, has not withdrawn, its written consent:

• to be named in this PDS as the investment manager of theFund; and

• to the inclusion of the statements made about it, the Fundand the tables and statistical information, which areattributed to it, in the form and context in which theyappear.

Fulcrum Asset Management LLP has not otherwise beeninvolved in the preparation of this PDS and has not caused orotherwise authorised the issue of this PDS. Fulcrum AssetManagement LLP and its employees and officers do not acceptany responsibility arising in any way for errors or omissions fromthis PDS, other than in relation to the statements for which it hasprovided its consent.

Ambassador Funds Management Services Pty Ltd has givenand, at the date of this PDS, has not withdrawn, its writtenconsent to be named in this PDS as the Distributor of the Fund.

JPMorgan has not been involved in the preparation of this PDSor caused or otherwise authorised the issue of this PDS.JPMorgan has not independently verified the informationcontained in this PDS and, accordingly, accepts no responsibilityfor the accuracy or completeness of the information. JPMorgandoes not guarantee the success or the performance of the Fundnor the repayment of capital or any particular rate of capital orincome return.

Constitution of the FundYou will be issued units in the Fund when you invest. Subject tothe rights, obligations and restrictions of a class, each unitrepresents an equal undivided fractional beneficial interest inthe assets of the Fund as a whole subject to liabilities, but doesnot give you an interest in any particular property of the Fund.

Equity Trustees’ responsibilities and obligations, as theResponsible Entity of the Fund, are governed by theConstitution as well as the Corporations Act and general trustlaw. The Constitution contains a number of provisions relating tothe rights, terms, conditions and obligations imposed on bothEquity Trustees, as the responsible entity of the Fund, andinvestors. Some of the provisions of the Constitution arediscussed elsewhere in this PDS.

Other provisions relate to your rights under the Constitution,and include:

• your right to share in any Fund income, and how wecalculate it;

• what you are entitled to receive when you withdraw or if theFund is wound up;

• your right to withdraw from the Fund - subject to the timeswhen we can cease processing withdrawals, such as if aFund becomes ‘illiquid’;

• the nature of the units - identical rights attach to all unitswithin a class; and

• your rights to attend and vote at meetings – however theserights are mainly contained in the Corporations Act.

There are also provisions governing our powers and duties,including:

• how we calculate unit prices, the maximum amount of feeswe can charge and expenses we can recover;

• when we can amend the Constitution - generally we canonly amend the Constitution where we reasonably believe

that the changes will not adversely affect investors’ rights.Otherwise the Constitution can only be amended ifapproved at a meeting of investors;

• when we can retire as the Responsible Entity of the Fund -which is as permitted by law;

• when we can be removed as the Responsible Entity of theFund - which is when required by law; and

• our broad powers to invest, borrow and generally managethe Fund.

The Constitution also deals with our liabilities in relation to theFund and when we can be reimbursed out of the Fund’s assets.For example:

• subject to the Corporations Act we are not liable for actingin reliance and good faith on professional advice;

• subject to the Corporations Act we are not liable for any lossunless we fail to act in good faith or we act negligently; and

• we can be reimbursed for any liabilities we incur inconnection with the proper performance of our powers andduties in respect of the Fund.

As mentioned above, Equity Trustees’ responsibilities andobligations as the Responsible Entity of the Fund are governedby the Constitution of the Fund, the Corporations Act andgeneral trust law, which require that we:

• act in the best interests of investors and, if there is a conflictbetween investors’ interests and our own, give priority toinvestors;

• ensure the property of the Fund is clearly identified, heldseparately from other funds and our assets, and is valuedregularly;

• ensure payments from the Fund’s property are made inaccordance with the Constitution and the Corporations Act;and

• report to ASIC any breach of the Corporations Act inrelation to the Fund which has had, or is likely to have, amaterially adverse effect on investors’ interests.

Attribution Managed Investment Trust (“AMIT”) –core rulesThe Fund may qualify as an eligible Attribution ManagedInvestment Trust (AMIT), and if so, intends to elect into the AMITregime. The AMIT legislation applies an attribution modelwhereby Equity Trustees as the Responsible Entity of the Fundattributes amounts of trust components of a particular characterto investors (or “members”) on a fair and reasonable basisconsistent with the operation of the Fund’s Constitution, whichincludes provisions in relation to AMIT. Under the AMIT rules,the following will apply:

Fair and reasonable attribution: Each year, the Fund’sdetermined trust components of assessable income, exemptincome, non-assessable non-exempt income and tax offsets (i.e.credits) will be allocated to investors on a “fair and reasonable”attribution basis, rather than being allocated proportionallybased on each investor’s present entitlement to the income ofthe Fund.

Unders or overs adjustments: Where the Fund’s determinedtrust components for a year are revised in a subsequent year(e.g. due to actual amounts differing to the estimates of income,gains / losses or expenses), then unders and overs may arise.Unders and overs will generally be carried forward and adjustedin the year of discovery.

Cost base adjustments: Where the distribution made is lessthan (or more than) certain components attributed to investors,


then the cost base of an investor’s units may be increased (ordecreased). Details of cost base adjustments will be included onan investor’s annual tax statement, referred to as an AMITMember Annual Statement (“AMMA”).

Large redemptions: In certain circumstances, gains may beattributed to a specific investor, for example, gains on disposalof assets to fund a large redemption being attributed to theredeeming investor.

Penalties: In certain circumstances (e.g. failure to comply withcertain AMIT rules), specific penalties may be imposed.

The new rules are intended to reduce complexity, increasecertainty and reduce compliance costs for managed investmenttrusts and their investors. Where the Fund does not elect intothe AMIT regime, or has made the election but the election isnot effective for the income year (e.g. the Fund does not satisfythe requirements to be a managed investment trust for theincome year), the Tax Law applicable to non-AMITs should berelevant. In particular, the Fund should not generally pay tax onbehalf of its investors and instead, investors should be assessedfor tax on any income and capital gains generated by the Fundto which they become presently entitled.

Non-listing of unitsUnits in the Fund are not listed on any stock exchange and noapplication will be made to list the units of the Fund on any stockexchange.

Termination of the FundThe Responsible Entity may resolve at any time to terminate andliquidate the Fund (if it provides investors with notice) inaccordance with the Constitution and the Corporations Act.Upon termination and after conversion of the assets of the Fundinto cash and payment of, or provision for, all costs, expensesand liabilities (actual and anticipated), the net proceeds will bedistributed pro-rata among all investors according to theaggregate of the withdrawal price for each of the units they holdin the Fund.

Our legal relationship with youEquity Trustees’ responsibilities and obligations, as theResponsible Entity of the Fund, are governed by theConstitution of the Fund, as well as the Corporations Act andgeneral trust law. The Constitution of the Fund contains anumber of provisions relating to the rights, terms, conditionsand obligations imposed on both Equity Trustees, as theresponsible entity of the Fund, and investors.

Equity Trustees may amend the Constitution if it considers thatthe amendment will not adversely affect an investor’s rights.Otherwise the Constitution may be amended by way of a specialresolution of investors.

A copy of the Constitution of the Fund is available, free ofcharge, on request from Equity Trustees.

Compliance PlanEquity Trustees has prepared and lodged a compliance plan forthe Fund with ASIC. The compliance plan describes theprocedures used by Equity Trustees to comply with theCorporations Act and the Constitution of the Fund. Each yearthe compliance plan for the Fund is audited and the audit reportis lodged with ASIC.

Unit pricing discretions policyEquity Trustees has developed a formal written policy in relationto the guidelines and relevant factors taken into account whenexercising any discretion in calculating unit prices (includingdetermining the value of assets and liabilities). A copy of thepolicy and, where applicable and to the extent required, any

other relevant documents in relation to the policy (such asrecords of any discretions which are outside the scope of, orinconsistent with, the unit pricing policy) will be made availableto you free of charge on request.

IndemnityEquity Trustees, as the Responsible Entity of the Fund, isindemnified out of the Fund against all liabilities incurred by it inproperly performing or exercising any of its powers or duties inrelation to the Fund. To the extent permitted by theCorporations Act, this indemnity includes any liability incurredas a result of any act or omission of a delegate or agentappointed by the Responsible Entity. Equity Trustees may retainand pay out any monies in its hands all sums necessary to affectsuch an indemnity.

Your PrivacyThe Australian Privacy Principles contained in the Privacy Act1988 (Cth) (“Privacy Act”) regulate the way in which we collect,use, disclose, and otherwise handle your personal information.Equity Trustees is committed to respecting and protecting theprivacy of your personal information, and our Privacy Policydetails how we do this.

It is important to be aware that, in order to provide our productsand services to you, Equity Trustees may need to collectpersonal information about you and any other individualsassociated with the product or service offering. In addition topractical reasons, this is necessary to ensure compliance withour legal and regulatory obligations (including under theCorporations Act, the AML/CTF Act and taxation legislation). Ifyou do not provide the information requested, we may not beable to process your application, administer, manage, invest,pay or transfer your investment(s).

You must therefore ensure that any personal information youprovide to Equity Trustees is true and correct in every detail. Ifany of this personal information (including your contact details)changes, you must promptly advise us of the changes in writing.While we will generally collect your personal information fromyou, your broker or adviser or the Investment Manager andAdministrator directly, we may also obtain or confirminformation about you from publicly available sources in order tomeet regulatory obligations.

In terms of how we deal with your personal information, EquityTrustees will use it for the purpose of providing you with ourproducts and services and complying with our regulatoryobligations. Equity Trustees may also disclose it to othermembers of our corporate group, or to third parties who wework with or engage for these same purposes. Such third partiesmay be situated in Australia or offshore, however we takereasonable steps to ensure that they will comply with the PrivacyAct when collecting, using or handling your personalinformation.

The types of third parties that we may disclose your informationto include, but are not limited to:

• stockbrokers, financial advisers or adviser dealer groups,their service providers and/or any joint holder of aninvestment;

• those providing services for administering or managing theFund, including the Investment Manager, Custodian andAdministrator, auditors, or those that provide mailing orprinting services;

• our other service providers;

• regulatory bodies such as ASIC, ATO, APRA and AUSTRAC;and


• other third parties who you have consented to us disclosingyour information to, or to whom we are required orpermitted by law to disclose information to.

Equity Trustees or the Investment Manager may from time totime provide you with direct marketing and/or educationalmaterial about products and services they believe may be ofinterest to you. You have the right to “opt out” of suchcommunications by contacting us using the contact detailsbelow.

In addition to the above information, Equity Trustees’ PrivacyPolicy contains further information about how we handle yourpersonal information, and how you can access information heldabout you, seek a correction to that information, or make aprivacy-related complaint.

Full details of Equity Trustees’ Privacy Policy is available atwww.eqt.com.au. You can also request a copy by contactingEquity Trustees’ Privacy Officer on +61 3 8623 5000 or by emailto [email protected].

Anti-Money Laundering and Counter TerrorismFinancing (AML/CTF)Australia’s AML/CTF laws require Equity Trustees to adopt andmaintain a written AML/CTF Program. A fundamental part of theAML/CTF Program is that Equity Trustees must hold up-to-dateinformation about investors (including beneficial ownerinformation) in the Fund.

To meet this legal requirement, we need to collect certainidentification information (including beneficial ownerinformation) and documentation (“KYC Documents”) from newinvestors. Existing investors may also be asked to provide KYCDocuments as part of an ongoing customer duediligence/verification process to comply with AML/CTF laws. Ifapplicants or investors do not provide the applicable KYCDocuments when requested, Equity Trustees may be unable toprocess an application, or may be unable to provide products orservices to existing investors until such time as the information isprovided.

In order to comply with AML/CTF Laws, Equity Trustees may alsodisclose information including your personal information that itholds about the applicant, an investor, or any beneficial owner,to its related bodies corporate or service providers, or relevantregulators of AML/CTF Laws (whether inside or outsideAustralia). Equity Trustees may be prohibited by law frominforming applicants or investors that such reporting hasoccurred.

Equity Trustees shall not be liable to applicants or investors forany loss you may suffer because of compliance with theAML/CTF laws.

Information on underlying investmentsInformation regarding the underlying investments of the Fundwill be provided to an investor of the Fund on request, to the

extent Equity Trustees is satisfied that such information isrequired to enable the investor to comply with its statutoryreporting obligations. This information will be supplied within areasonable timeframe having regard to these obligations.

Foreign Account Tax Compliance Act (“FATCA”)In April 2014, the Australian Government signed anintergovernmental agreement (“IGA”) with the United States ofAmerica (“U.S.”), which requires all Australian financialinstitutions to comply with the FATCA Act enacted by the U.S. in2010.

Under FATCA, Australian financial institutions are required tocollect and review their information to identify U.S. residentsand U.S controlling persons that invest in assets throughnon-U.S. entities. This information is reported to the AustralianTaxation Office (“ATO”). The ATO may then pass thatinformation onto the U.S. Internal Revenue Service.

In order to comply with the FATCA obligations, we may requestcertain information from you. Failure to comply with FATCAobligations may result in the Fund, to the extent relevant, beingsubject to a 30% withholding tax on payment of U.S. income orgross proceeds from the sale of certain U.S. investments. If theFund suffers any amount of FATCA withholding and is unable toobtain a refund for the amounts withheld, we will not berequired to compensate investors for any such withholding andthe effect of the amounts withheld will be reflected in the returnsof the Fund.

Common Reporting Standard (“CRS”)The CRS is developed by the Organisation of EconomicCo-operation and Development and requires certain financialinstitutions resident in a participating jurisdiction to documentand identify reportable accounts and implement due diligenceprocedures. These financial institutions will also be required toreport certain information on reportable accounts to theirrelevant local tax authorities.

Australia signed the CRS Multilateral Competent AuthorityAgreement and has enacted provisions within the domestic taxlegislation to implement CRS in Australia. Australian financialinstitutions need to document and identify reportable accounts,implement due diligence procedures and report certaininformation with respect to reportable accounts to the ATO. TheATO may then exchange this information with foreign taxauthorities in the relevant signatory countries.

In order to comply with the CRS obligations, we may requestcertain information from you. Unlike FATCA, there is nowithholding tax that is applicable under CRS.


12. Glossary of Important TermsApplication FormThe Application Form used by investors who wish to subscribefor units directly in the Fund and accompanying this PDS.

Asset allocationThe weighting of assets in an investment portfolio amongdifferent asset classes (such as shares, bonds, property andcash).

Business DayA day other than a Saturday or a Sunday on which banks areopen for general banking business in Melbourne or if theadministrator of the Fund primarily performs its administrativefunctions in respect of the Fund in a city other than Melbourne,the city in which the administrator performs such functions.

Buy/Sell SpreadThe difference between the Application Price and WithdrawalPrice of units in the Fund, which reflects the estimatedtransactions costs associated with buying and selling the assetsof the Fund, when investors invest in or withdraw from the Fund.

ConstitutionThe Constitution of the Fund which describes the rights,responsibilities and beneficial interest of both investors and theResponsible Entity in relation to the Fund.

Corporations ActThe Corporations Act 2001 (Cth) and Corporations Regulations2001 (Cth), as amended from time to time.

DerivativesGenerally, a derivative is a financial contract whose valuedepends upon, or is derived from, the value of an underlyingasset, reference rate or index. Derivatives may relate to stocks,bonds, interest rates, currencies or currency exchange rates,commodities, and related indexes. Examples include optionscontracts, futures contracts, options on futures contracts, swapagreements (including, but not limited to, long and short creditdefault swaps and forward swap spread locks) and options onswap agreements.

DistributionThe amount that is paid to investors after the end of adistribution period. This generally includes any income andrealised capital gains.

HedgeThe practice of undertaking one investment activity in order toprotect against loss in another. While hedges can reducepotential losses, they can also reduce potential profits.

LiquidityThe ability of an investment to be easily and quickly convertedinto cash with little loss of capital.

Long positionsA long position is one in which the investor owns the investmentwhere the investor seeks to profit if the price of the investmentgoes up.

Net Asset Value (“NAV”)The value of assets of the Fund less the value of the liabilities ofthe Fund (excluding net assets attributable to investors).

Wholesale InvestorIn the case of a New Zealand investor, has the meaning given inclause 3(2) of Schedule 1 of the Financial Markets Conduct Act2013 (New Zealand).

Retail ClientPersons or entity which is a retail client as defined undersection 761G of the Corporations Act.

RITCReduced Input Tax Credit. Equity Trustees will apply for reducedinput tax credits on behalf of the Fund, where applicable, toreduce the GST cost to the Fund.

Short positionsA short position is one in which the investor has sold aninvestment that the investor doesn’t own where the investorseeks to profit if the value of an investment falls. Short sales aregenerally covered, that is, the seller will “borrow” theinvestment to settle the sale and then will buy the sameinvestment in the open market to return the borrowedinvestment. The difference between the sale price and thepurchase price of the investment in the open market is the profitor loss earned by the investor.

UCIAn undertaking for collective investment.

UCITSAn undertaking for collective investment in transferablesecurities.

US PersonA person so classified under securities or tax law in theUnited States of America (“US”) including, in broad terms, thefollowing persons:

(a) any citizen of, or natural person resident in, the US, itsterritories or possessions; or

(b) any corporation or partnership organised or incorporatedunder any laws of or in the US or of any other jurisdiction ifformed by a US Person (other than by accredited investors whoare not natural persons, estates or trusts) principally for thepurpose of investing in securities not registered under the USSecurities Act of 1933; or

(c) any agency or branch of a foreign entity located in the US; or

(d) a pension plan primarily for US employees of a US Person; or

(e) a US collective investment vehicle unless not offered to USPersons; or

(f) any estate of which an executor or administrator is a USPerson (unless an executor or administrator of the estate who isnot a US Person has sole or substantial investment discretionover the assets of the estate and such estate is governed bynon-US law) and all the estate income is non-US income notliable to US income tax; or

(g) any trust of which any trustee is a US Person (unless a trusteewho is a professional fiduciary is a US Person and a trustee whois not a US Person has sole or substantial investment discretionover the assets of the trust and no beneficiary (or settlor, if thetrust is revocable) of the trust is a US Person); or

(h) any discretionary account or similar account (other than anestate or trust) held by a dealer or other fiduciary for the benefitor account of a US Person; or

(i) any non-discretionary account or similar account (other thanan estate or trust) held by a dealer or other fiduciary organised,incorporated or (if an individual) resident in the US for thebenefit or account of a US Person.

Wholesale ClientPerson or entity which is wholesale client as defined under theCorporations Act.


Equity Trustees Application Form – 2018

Section 3 – Investor details – Individuals/Joint Please complete if you are investing individually, jointly or you are an individual or joint trustee.

See Group A AML/CTF Identity Verification Requirements in Section 9

Investor 1 Title First name(s) Surname

Residential address (not a PO Box/RMB/Locked Bag)

Suburb State Postcode Country

Email address Contact no.

Date of birth (DD/MM/YYYY) Tax File Number* – or exemption code

/ /

Country of birth Occupation

Investor 2 Title First name(s) Surname




Date of birth (DD/MM/YYYY) Tax File Number* – or exemption code

/ /

Country of birth Occupation

If there are more than 2 beneficial owners, please provide details as an attachment.

Do any of the investors named hold a prominent public position or function in a government body (local, state, territory, national or foreign) or in an international organisation or are you an immediate family member or a business associate of such a person?

No Yes, please give details:


Section 4 – Investor details – Companies/Corporate Trustee Please complete if you are investing for a company or where the company is acting as trustee.

See Group B AML/CTF Identity Verification Requirements in Section 9 Full company name (as registered with ASIC or relevant foreign registered body)

Registered office address (not a PO Box/RMB/Locked Bag)


Australian Company Number Tax File Number* – or exemption code

Australian Business Number* (if registered in Australia) or equivalent foreign company identifier

Contact Person Title First name(s) Surname


Principal place of business: For non-Australian companies please provide a local agent name and address if you do not have a principal place of business in Australia. Registered Office Address (not a PO Box/RMB/Locked Bag)


Registration details Name of regulatory body Identification number (e.g. ARBN)

Beneficial owners

All beneficial owners will need to provide Group A AML/CTF Identity Verification Requirements in Section 9

Shareholders and other beneficial owners (shareholders and those who own directly, indirectly, jointly or beneficially 25% or more of the company’s issued capital).

Beneficial owner 1 Title First name(s) Surname



Date of birth (DD/MM/YYYY)

/ /






/ /


Do any of the beneficial owners named hold a prominent public position or function in a government body (local, state, territory, national or foreign) or in an international organisation or are you an immediate family member or a business associate of such a person?


Senior Managing Official and controlling person (e.g. managing directors, senior executive etc. who are authorised to sign on the company’s behalf, make policy, operational and financial decisions)

1 2

3 4


Section 5 – Investor Details – Trusts/superannuation funds Please complete if you are investing for a trust or superannuation fund.

See Group C AML/CTF Identity Verification Requirements in section 9 Full name of trust or superannuation fund

Full name of business (if any) Country where established

Australian Business Number* (if obtained)

Tax File Number* – or exemption code

Trustee details - How many trustees are there?

Individual trustee(s) – complete section 3 – Investor details – Individuals/Joint

Company trustee(s) – complete section 4 – Investor details – Companies/Corporate Trustee

Combination – trustee(s) to complete each relevant section

Type of Trust

Registered Managed Investment Scheme

Australian Registered Scheme Number (ARSN)

Regulated Trust (including self-managed superannuation funds and registered charities that are trusts)

Name of Regulator (e.g. ASIC, APRA, ATO, ACNC)

Registration/Licence details

Other Trust (unregulated) Please describe

Beneficiaries of an unregulated trust Please provide details below of any beneficiaries who directly or indirectly are entitled to an interest of 25% or more of the trust.

1 2

3 4

If there are no beneficiaries of the trust, describe the class of beneficiary (e.g. the name of the family group, class of unit holders, the charitable purpose or charity name):

Please provide the full name of the settlor of the trust where the initial asset contribution to the trust was greater than $10,000 and the settlor is not deceased:

Beneficial owners of an unregulated trust Please provide details below of any beneficial owner of the trust. A beneficial owner is any individual who directly or indirectly has a 25% or greater interest in the trust or a person who exerts control over the trust. This includes the appointer of the trust who holds the power to appoint or remove the trustees of the trust.


All beneficial owners will need to provide Group A AML/CTF Identity Verification Requirements in Section 9





/ /





/ /


Do any of the beneficial owners named hold a prominent public position or function in a government body (local, state, territory, national or foreign) or in an international organisation or are you an immediate family member or a business associate of such a person?



Section 6 – Authorised representative, agent and/or financial adviser Please complete if you are appointing an authorised representative, agent and/or financial adviser.

I am an authorised representative or agent as nominated by the investor(s)

See Group D AML/CTF Identity Verification Requirements in Section 9 You must attach a valid authority such as Power of Attorney, guardianship order, grant of probate, appointment of bankruptcy etc. that is a certified copy. The document must be current and complete, signed by the investor or a court official and permits the authorised representative or agent to transact on behalf of the investor.

Full name of authorised representative or agent

Role held with investor(s)

Signature Date

I am a financial adviser as nominated by the investor

Name of adviser AFSL number

Dealer group Name of advisory firm

Postal address

Suburb State Postcode


Financial Adviser Declaration I/We hereby declare that I/we are not a US Person as defined in the PDS/IM. I/We hereby declare that the investor is not a US Person as defined in the PDS/IM. I/We have completed an appropriate Customer Identification Procedure (CIP) on this investor

which meets the requirements (per type of investor) set out above, AND EITHER

I/We have attached the relevant CIP documents; OR I/We have not attached the CIP documents however I/We confirm that I have completed the

AML/KYC checks on the investor(s) in accordance to the AUSTRAC’s requirements. I/We also agree to provide Equity Trustees the relevant CIP documents on request.

Signature Date

Access to information Unless you elect otherwise, your authorised representative, agent and/or financial adviser will be provided access to your investment information and/or receive copies of statements and transaction confirmations. By appointing an authorised representative, agent and/or financial adviser you acknowledge that you have read and agreed to the terms and conditions in the PDS/IM relating to such appointment.

Please tick this box if you DO NOT want your authorised representative, agent and/or financial adviser to have access to information about your investment.

Please tick this box if you DO NOT want copies of statements and transaction confirmations sent to your authorised representative, agent and/or financial adviser.

Please tick this box if you want statements and transaction confirmations sent ONLY to your authorised representative, agent and/or financial adviser.


Section 7 – Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard (CRS) Self-Certification Form – ALL investors MUST complete

Sub-Section I - Individuals Please fill this Sub-Section I only if you are an individual. If you are an entity, please fill Sub-Section II.

1. Are you a US citizen or resident of the US for tax purposes?

Yes: provide your Taxpayer Identification Number (TIN) or equivalent (or Reason Code if no TIN is provided) below and continue to question 2

Investor 1 Investor 2

No: continue to question 2

2. Are you a tax resident of any other country outside of Australia?

Yes: state each country and provide your TIN or equivalent (or Reason Code if no TIN is provided) for each jurisdiction below and skip to question 12

Investor 1 Investor 2 If more space is needed please provide details as an attachment.

No: skip to question 12

Reason Code: If TIN or equivalent is not provided, please provide reason from the following options:

• Reason A: The country/jurisdiction where the entity is resident does not issue TINs to its residents. • Reason B: The entity is otherwise unable to obtain a TIN or equivalent number (Please explain why the

entity is unable to obtain a TIN in the below table if you have selected this reason). • Reason C: No TIN is required. (Note. Only select this reason if the domestic law of the relevant

jurisdiction does not require the collection of the TIN issued by such jurisdiction).

If Reason B has been selected above, explain why you are not required to obtain a TIN:


Sub-Section II - Entities Please fill this Sub-Section II only if you are an entity. If you are an individual, please fill Sub-Section I.

3. Are you an Australian complying superannuation fund?

Yes: skip to question 12


FATCA 4. Are you a US Person?

Yes: continue to question 5


5. Are you a Specified US Person?

Yes: provide your TIN below and skip to question 7

No: indicate exemption type and skip to question 7

6. Are you a Financial Institution for the purposes of FATCA?

Yes: provide your Global Intermediary Identification Number (GIIN)

If you do not have a GIIN, please provide your FATCA status below and continue to question 7

Exempt Beneficial Owner, provide type below:


Deemed-Compliant FFI (other than a Sponsored FI or a Trustee Documented Trust),

provide type below:

Non-Participating FFI, provide type below:

Sponsored Financial Institution. Please provide the Sponsoring Entity’s name and GIIN:

Trustee Documented Trust. Please provide your Trustee’s name and GIIN:

Other, provide details:


CRS 7. Are you a tax resident of any country outside of Australia and the US?

Yes: state each country and provide your TIN or equivalent (or Reason Code if no TIN is provided) for each jurisdiction below and continue to question 8

Investor 1 Investor 2 If more space is needed please provide details as an attachment.







8. Are you a Financial Institution for the purpose of CRS?

Yes: specify the type of Financial Institution below and continue to question 9

Reporting Financial Institution Non-Reporting Financial Institution:

Trustee Documented Trust Other: please specify:

9. Are you an investment entity resident in a non-participating jurisdiction for CRS purposes and managed by another financial Institution?

Yes: skip to question 11


Non-Financial Entities 10. Are you an Active Non-Financial Entity (Active NFE)?

Yes: specify the type of Active NFE below and skip to question 12: Less than 50% of the Active NFE’s gross income from the preceding calendar year is

passive income (e.g. dividends, distribution, interests, royalties and rental income) and less than 50% of its assets during the preceding calendar year are assets held for the production of passive income

Corporation that is regularly traded or a related entity of a regularly traded corporation




Governmental Entity, International Organisation or Central Bank Other: please specify:

No: you are a Passive Non-Financial Entity (Passive NFE). Continue to question 11

Controlling Persons 11. Does one or more of the following apply to you: • Is any natural person that exercises control over you (for corporations, this would include directors or

beneficial owners who ultimately own 25% or more of the share capital) a tax resident of any country outside of Australia?

• If you are a trust, is any natural person including trustee, protector, beneficiary, settlor or any other natural person exercising ultimate effective control over the trust a tax resident of any country outside of Australia?

Controlling person 1 Title First name(s) Surname




/ /

Country of tax residence

TIN or equivalent Reason Code if no TIN provided

Controlling person 2 Title First name(s) Surname




/ /

Country of tax residence

TIN or equivalent Reason Code if no TIN provided

If there are more than 2 controlling persons, please provide details as an attachment.









12. Signature and Declaration – ALL investors must sign I undertake to provide a suitably updated self-certification within 30 days of any change in

circumstances which causes the information contained herein to become incorrect. I declare the information above to be true and correct.

Investor 1 Investor 2 Name of individual/entity Name of individual/entity

Name of authorised representative Name of authorised representative Signature Signature

Date Date


Section 8 – Declarations – ALL investors MUST complete In most cases the information that you provide in this form will satisfy the AML/CTF Act, the US Foreign Account Tax Compliance Act (‘FATCA’) and the Common Reporting Standards (‘CRS’). However, in some instances the Responsible Entity may contact you to request further information. It may also be necessary for the Responsible Entity to collect information (including sensitive information) about you from third parties in order to meet its obligations under the AML/CTF Act, FATCA and CRS.

When you complete this Application Form you make the following declarations:

• I/We have received the PDS/IM and made this application in Australia (and/or New Zealand for those offers made in New Zealand).

• I/We have read the PDS/IM to which this Application Form applies and agree to be bound by the terms and conditions of the PDS/IM and the Constitution of the relevant Fund/Trust in which I/we have chosen to invest.

• I/We have considered our personal circumstances and, where appropriate, obtained investment and/or taxation advice.

• I/We hereby declare that I/we are not a US Person as defined in the PDS/IM.

• I/We acknowledge that (if a natural person) I am/we are 18 years of age or over and I am/we are eligible to hold units in the Fund/Trust in which I/We have chosen to invest.

• I/We acknowledge and agree that Equity Trustees has outlined in the PDS/IM provided to me/us how and where I/we can obtain a copy of the Equity Trustees Group Privacy Statement.

• I/We consent to the transfer of any of my/our personal information to external third parties including but not limited to fund administrators, fund investment manager(s) and related bodies corporate who are located outside Australia for the purpose of administering the products and services for which I/we have engaged the services of Equity Trustees or its related bodies corporate and to foreign government agencies for reporting purposes (if necessary).

• I/we hereby confirm that the personal information that I/we have provided to Equity Trustees is correct and current in every detail, and should these details change, I/we shall promptly advise Equity Trustees in writing of the change(s).

• I/We agree to provide further information or personal details to the Responsible Entity if required to meet its obligations under anti-money laundering and counter-terrorism legislation, US tax legislation or reporting legislation and acknowledge that processing of my/our application may be delayed and will be processed at the unit price applicable for the Business Day as at which all required information has been received and verified.

• If I/we have provided an email address, I/we consent to receive ongoing investor information including PDS/IM information, confirmations of transactions and additional information as applicable via email.

• I/We acknowledge that Equity Trustees does not guarantee the repayment of capital or the performance of the Fund/Trust or any particular rate of return from the Fund/Trust.

• I/We acknowledge that an investment in the Fund/Trust is not a deposit with or liability of Equity Trustees and is subject to investment risk

including possible delays in repayment and loss of income or capital invested.

• I/We acknowledge that Equity Trustees is not responsible for the delays in receipt of monies caused by the postal service or the investor’s bank.

• If I/we lodge a fax application request, I/we acknowledge and agree to release, discharge and agree to indemnify Equity Trustees from and against any and all losses, liabilities, actions, proceedings, account claims and demands arising from any fax application.

• If I/we have completed and lodged the relevant sections on authorised representatives, agents and/or financial advisers on the Application Form then I/we agree to release, discharge and indemnify Equity Trustees from and against any and all losses, liabilities, actions, proceedings, account claims and demands arising from Equity Trustees acting on the instructions of my/our authorised representatives, agents and/or financial advisers.

• If this is a joint application each of us agrees that our investment is held as joint tenants.

• I/We acknowledge and agree that where the Responsible Entity, in its sole discretion, determines that: o I/we are ineligible to hold units in a

Fund/Trust or have provided misleading information in my/our Application Form; or

o I/we owe any amounts to Equity Trustees, then I/we appoint the Responsible Entity as my/our agent to submit a withdrawal request on my/our behalf in respect of all or part of my/our units, as the case requires, in the Fund/Trust.

• For Wholesale Clients - I/We acknowledge that I am/we are a Wholesale Client (as defined in Section 761G of the Corporations Act 2001 (Cth)) and are therefore eligible to hold units in the Fund/Trust.

• For New Zealand applicants - I/we have read the terms of the offer relating to New Zealand investors, including the New Zealand warning statement.

• For New Zealand Wholesale Investors - I/We acknowledge and agree that:

• I/We have read the “New Zealand Wholesale Investor Fact Sheet” and PDS/IM or “New Zealand Investors: Selling Restriction” for the Fund/Trust;

• I am/We are a Wholesale Investor and am/are therefore eligible to hold units in the Fund/Trust; and

• I/We have not: o Offered, sold, or transferred, and will not

offer, sell, or transfer, directly or indirectly, any units in the Fund/Trust;


o Granted, issued, or transferred, and will not grant, issue, or transfer, any interests in or options over, directly or indirectly, any units in the Fund/Trust; and

o Distributed and will not distribute, directly or indirectly, the PDS/IM or any other offering materials or advertisement in relation to any offer of units in the Fund/Trust,

in each case in New Zealand, other than to a person who is a Wholesale Investor; and

• I/We will notify Equity Trustees if I/we cease to be a Wholesale Investor; and

• I/We have separately provided a signed Wholesale Investor Certification located at the end of this Application Form.

• All references to Wholesale Investor in this Declaration are a reference to Wholesale Investor in terms of clause 3(2) of Schedule 1 of the Financial Markets Conduct Act 2013 (New Zealand).

*Terms and conditions for collection of Tax File Numbers (TFN) and Australian Business Numbers (ABN) Collection of TFN and ABN information is authorised and its use and disclosure strictly regulated by tax laws and the Privacy Act. Investors must only provide an ABN instead of a TFN when the investment is made in the course of their enterprise. You are not obliged to provide either your TFN or ABN, but if you do not provide either or claim an exemption, we are required to deduct tax from your distribution at the highest marginal tax rate plus Medicare levy to meet Australian taxation law requirements.

For more information about the use of TFNs for investments, contact the enquiries section of your local branch of the ATO. Once provided, your TFN will be applied automatically to any future investments in the Fund/Trust where formal application procedures are not required (e.g. distribution reinvestments), unless you indicate, at any time, that you do not wish to quote a TFN for a particular investment. Exempt investors should attach a copy of the certificate of exemption. For super funds or trusts list only the applicable ABN or TFN for the super fund or trust.

When you sign this Application Form you declare that you have read, agree to and make the declarations above

Investor 1 Investor 2 Name of individual /entity Name of individual/entity

Capacity (e.g. Director, Secretary, Authorised signatory)

Capacity (e.g. Director, Secretary, Authorised signatory)

Signature Signature

Date Date

Company Seal (if applicable)


Section 9 – AML/CTF Identity Verification Requirements

The AML/CTF Act requires the Responsible Entity to adopt and maintain an anti-money laundering and counter-terrorism financing ('AML/CTF') program. The AML/CTF program includes ongoing customer due diligence, which may require the Responsible Entity to collect further information.

• Identification documentation provided must be in the name of the investor. • Non-English language documents must be translated by an accredited translator. • Applications made without providing this information cannot be processed until all the necessary

information has been provided. • If you are unable to provide the identification documents described please contact Equity Trustees.

These documents should be provided as an original or a CERTIFIED COPY of the original.

Who can certify? Below is an example of who can certify proof of ID documents under the AML/CTF requirements:

• Bailiff • Bank officer with 5 or more years of

continuous service • Building society officer with 5 or more years

of continuous service • Chiropractor (licensed or registered) • Clerk of court • Commissioner for Affidavits • Commissioner for Declarations • Credit union officer with 5 or more years of

continuous service • Dentist (licensed or registered) • Fellow of the National Tax Accountant's

Association • Finance company officer with 5 or more years

of continuous service • Judge of a court • Justice of the peace • Legal practitioner (licensed or registered) • Magistrate • Marriage celebrant licensed or registered

under Subdivision C of Division 1 of Part IV of the Marriage Act 1961

• Master of a court • Medical practitioner (licensed or registered) • Member of Chartered Secretaries Australia • Member of Engineers Australia, other than at

the grade of student • Member of the Association of Taxation and

Management Accountants

• Member of the Australian Defence Force with 5 or more years of continuous service

• Member of the Institute of Chartered Accountants in Australia, the Australian Society of Certified Practicing Accountants or the Institute of Public Accountants

• Member of the Parliament of the Commonwealth, a State, a Territory Legislature, or a local government authority of a State or Territory

• Minister of religion licensed or registered under Subdivision A of Division 1 of Part IV of the Marriage Act 1961

• Nurse (licensed or registered) • Optometrist (licensed or registered) • Permanent employee of Commonwealth,

State or local government authority with at least 5 or more years of continuous service.

• Permanent employee of the Australian Postal Corporation with 5 or more years of continuous service

• Pharmacist (licensed or registered) • Physiotherapist (licensed or registered) • Police officer • Psychologist (licensed or registered) • Registrar, or Deputy Registrar, of a court • Sheriff • Teacher employed on a full-time basis at a

school or tertiary education institution • Veterinary surgeon (licensed or registered)

When certifying documents, the following process must be followed: • All copied pages of original proof of ID documents must be certified. • The authorised individual must ensure that the original and the copy are identical; then write or stamp

on the copied document “certified true copy”. This must be followed by the date and signature, printed name and qualification of the authorised individual.

• In cases where an extract of a document is photocopied to verify customer ID, the authorised individual should write or stamp “certified true extract”


GROUP A – Individuals/Joint

Each individual investor, individual trustee, beneficial owner, or individual agent or authorised representative must provide one of the following primary photographic ID:

A current Australian driver’s licence (or foreign equivalent) that includes a photo and signature. An Australian passport (or foreign equivalent) (not expired more than 2 years previously). An identity card issued by a State or Territory Government that includes a photo.

If you do NOT own one of the above ID documents, please provide one valid option from Column A and one valid option from Column B.

Column A Column B

Australian birth certificate.

Australian citizenship certificate.

Pension card issued by Department of Human Services.

A document issued by the Commonwealth or a State or Territory within the preceding 12 months that records the provision of financial benefits to the individual and which contains the individual’s name and residential address.

A document issued by the Australian Taxation Office within the preceding 12 months that records a debt payable by the individual to the Commonwealth (or by the Commonwealth to the individual), which contains the individual’s name and residential address. Block out the TFN before scanning, copying or storing this document.

A document issued by a local government body or utilities provider within the preceding 3 months which records the provision of services to that address or to that person (the document must contain the individual’s name and residential address).

If under the age of 18, a notice that: was issued to the individual by a school principal within the preceding 3 months; and contains the name and residential address; and records the period of time that the individual attended that school.

GROUP B – Companies

For Australian Registered Companies, provide one of the following (must clearly show the Company’s full name, type (private or public) and ACN):

A certified copy of the company’s Certificate of Registration or incorporation issued by ASIC A copy of information regarding the company’s licence or other information held by the relevant

Commonwealth, State or Territory regulatory body e.g. AFSL, RSE, ACL etc. A full company search issued in the previous 3 months. If the company is listed on an Australian securities exchange, provide details of the exchange and the

ticker (issuer) code. If the company is a majority owned subsidiary of a company listed on an Australian securities exchange,

provide details of the exchange and the ticker (issuer) code for the holding company.

For Foreign Companies, provide one of the following:

A certified copy of the company’s Certificate of Registration or incorporation issued by the foreign jurisdictions in which the company was incorporated, established or formed.

A certified copy of the company’s articles of association or constitution. A copy of a company search on the ASIC database or relevant foreign registration body.

All of the above must clearly show the company’s full name, its type (i.e. public or private) and the ARBN issued by ASIC, or the identification number issued to the company by the foreign regulator.

In addition, please provide verification documents for each beneficial owner (senior managing official and shareholder) as listed under Group A.

A beneficial owner of a company is any customer entitled (either directly or indirectly) to exercise 25% or more of the voting rights, including a power of veto, or who holds the position of senior managing official (or equivalent).


GROUP C – Trusts

For a Registered Managed Investment Scheme, Government Superannuation Fund or a trust registered with the Australian Charities, Regulated Superannuation Fund (including a self-managed super fund) and Not-for-profit Commission (ACNC), provide one of the following:

A copy of the company search of the relevant regulator’s website e.g. APRA, ASIC, or ATO. A copy or relevant extract of the legislation establishing the government superannuation fund sourced

from a government website. A copy from the ACNC of information registered about the trust as a charity Annual report or audited financial statements. A certified copy of a notice issued by the ATO within the previous 12 months. A certified copy of the Trust Deed

For all other Unregulated trust (including Foreign trust), provide the following:

A certified copy of the Trust Deed. If the trustee is an individual, please also provide verification documents for one trustee as listed under Group A.

If the trustee is a company, please also provide verification documents for a company as listed under Group B.

GROUP D – Authorised Representatives and Agents

In addition to the above entity groups:

If you are an Individual Authorised Representative or Agent – please also provide the identification documents listed under Group A.

If you are a Corporate Authorised Representative or Agent – please also provide the identification documents listed under Group B.

All Authorised Representatives and Agents must also provide a certified copy of their authority to act for the investor e.g. the POA, guardianship order, Executor or Administrator of a deceased estate, authority granted to a bankruptcy trustee, authority granted to the State or Public Trustee etc.

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