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Vision Super

PRI reporting framework 2020

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

          Collaboration, Engagement, Climate Change & ProxyVoting
        
          Manager Selection & Appointments, Monitoring & Reporting
        

01.3. Indicate if the investment policy covers any of the following

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

The Board of Vision Super is guided by a set of Investment Beliefs when decisions are made about the investment portfolio on behalf of members and sponsors. The Defined Benefit Plan and MySuper Option have tailored beliefs due to their specific circumstances. We also have a number of Investment Beliefs that are common to all investment options.

As outlined with our investment belief number 3, we believe that Environmental, Social and Governance (ESG) issues and sustainability considerations are important within the context of optimising net risk-adjusted returns.

Furthermore, Vision Super recognises that it has a primary responsibilty that is long-term in nature and that the long term prosperity of the economy and the well-being of members depend on a healthy enviornment, special cohesion and good governance within the Fund's operations and the companies in which it invests.

01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

The Board formulates an investment strategy for each investment option. Collectively these strategies, together with the investment strategies for the reserve accounts make up the investment strategy for Vision Super.

The Fund has an overall investment objective to maximize returns in line with the return targets after taking into account the risks associated with various types of investments.

Investment risks captured in the Risk Management Strategy are subject to ongoing monitoring and reporting under the Vision Super risk management framework.

The Investment team monitors the asset allocations of the Investment options (including liquidity and currency exposures) and economic market on a weekly basis (at a minimum).

The Investment team also monitors exposure to liquidity, currency and credit risk in accordance with the relevant policies.

The investment risks of the Fund’s Investment options are formally reviewed each year as part of the annual review of investment strategy.

Climate / ESG:

  • The risk that environmental / climate factors will impair the value of fund investments, or impact negatively on the cost of living in retirement. The risk that social factors (such as human rights, labour standards, health and safety) may result in litigation against companies, and/or reputational loss, which may impair the value of fund investments.
  • The risk that governance factors can result in companies not taking actions in the best interests of investors, which may impair the value of fund investments

Major risk factors are considered and modelled (implicitly or explicitly) when formulating or reviewing investment strategy.  The Investment Liquidity and Cash Flow Management Policy and the Foreign Currency Management Policy provide further detail on consideration of liquidity and currency risk when setting or reviewing investment strategy.

  • The Board currently does not set a target exposure to underlying risk factors, apart from liquidity and foreign currency exposure. Exposure to risk factors is both a consideration and an outcome of setting asset allocation.
  • When formulating and reviewing investment strategy the Board considers benefit structure and membership demographics as follows:
    • Investment strategy is reviewed separately for the accumulation and defined benefit options
    • For the defined benefit options, the Board considers the liability profile for each sub plan, including
      • Funding levels
      • The duration of liabilities
      • The benefit structure (lump sum or pension)
      • Forecast net cash flows.

For all options, liquidity modeling includes modeling forecast cash flows.

Vision Super undertakes Whole of Fund modelling, approximately triennially.  This analysis forecasts membership, assets and cash flows for each division of the Fund (accumulation, account based pension and defined benefit), and informs the review of investment objectives and strategy.

From a whole of fund level we believe that environmental, social and governance issues and sustainability considerations are important within the context of optimizing net risk-adjusted returns.

ESG considerations are included in our fund-wide investment beliefs which guide the decisions we make about our investment portfolios.

Furthermore;

  • We have an obligation to act in the members best interests and that may be in contradiction to the members preferred course of action. However, a toxic and hostile environment is clearly not in the members best interest.
  • We encourage an orderly transition to a low carbon economy
  • We believe a price should be set on all harmful outputs by companies, waste (including nuclear waste)  carbon pollution, other types of pollution
  • We actively engage with our partners, organizations and community groups to further these goals.

In addition, Vision Super has implemented a Sustainable Balanced Investment Option and votes in favor of sensible climate risk ballot resolutions at company Annual General Meetings. 

01.6. Additional information [Optional].

          In line with the Stronger Super Reforms in Australia and meeting the requirements of industry standards and guidance on proxy voting disclosure, the Trustee approved a proxy voting policy distinct from the ESG policy.
Guidance on our proxy voting disclosure is in line with the regulatory requirements as follows;
  Financial Services Council FSC Standard 1 – Code of Ethics and Code of Conduct (Oct 2016)
• Financial Services Council FSC Standard 13 - Voting Policy, Voting Record and Disclosure (March 2013)
• Financial Services Council FSC Standard 20 - Superannuation Governance Policy (March 2013) &
• The website disclosure requirements set out in SIS Act s.29QB(1)(b) and SIS Regulations 2.38(2) (n) and (o)
        

SG 01 CC. Climate risk

01.6 CC. Indicate whether your organisation has identified transition and physical climate-related risks and opportunities and factored this into the investment strategies and products, within the organisation’s investment time horizon.

Describe the identified transition and physical climate-related risks and opportunities and how they have been factored into the investment strategies/products.

We ask all our fund managers questions on how they are considering climate-risks and are evaluated on the quality of the timeliness around their responses. Some of fund managers are less focussed on risks and opportunities. Unfortunately this is by far the most common position across the fund manager universe.

In these cases we challenge the manager to think about the implications of climate change and explore what it means for their portfolios. Progress has been slow but even within these more typical organisations there is a wide range of perspectives and thinking about the issues.

As example, some of our active global equity portfolios are highly growth focused. These fundamental investment managers focus on growth and innovation, and strive to identify exceptional businesses that are on the right side of changes affecting their industries and the markets they serve (typically operate in less carbon-intensive industries). In the shift to a low-carbon economy, they believe that many of their portfolios businesses are facilitators of that shift while others are poised to be beneficiaries.

These fund managers seek to manage climate risks in two ways. First, their investment criteria tend to lead them to high growth companies that typically operate in less carbon-intensive industries. Second, in the course of conducting their fundamental research, they are attuned to how climate risks may affect a business’s long term value creation.

Some portfolios have an average weighted carbon intensity significantly lower than the benchmark over time and in the advent of the TCFD recommendations, our managers intend to evaluate their strategy pertaining to climate change to ensure they can meet clients’ evolving policy and reporting needs.

Our fund managers also in the course of conducting their fundamental research, are attuned to how climate risks may affect a business’s long term value creation.

Active managers are required to consider the transition to an economy with at most 2 degrees of warming above pre-industrial levels indicate how climate-risks are factored into the assessment of particular portfolio positions. This position changed to 1.5 degree degrees of warming in October 2018 following the IPCC report revising the "safe" level of warming human civilisation can tolerate.

Any material direct investment should include a reasonable estimate of the impact of phasing out fossil fuel usage consistent with limiting global warming to no more than 1.5◦C above the pre-industrial global mean temperature.

Vision Super had also previously submitted a letter to every Federal parliamentarian in Australia asking for certainty and bi-partisanship around energy policy and progress in transitioning to a zero-degree world.

The Fund also offers its members the option of investing in a sustainable super solutions product, which is a passively managed 100% low-carbon benchmark which has gathered a favorable response from our members on account of its low-cost and low-carbon features. The Australian and international passive equity portfolios are managed to a low carbon mandate and we ensure we send a strong message through our voting for specific climate change risk resolutions on a case by case basis.

01.7 CC. Indicate whether the organisation has assessed the likelihood and impact of these climate risks?

Describe the associated timescales linked to these risks and opportunities.

The associated timescales linked climate risks and opportunities will vary depending on the asset class investment. As example, infrastructure and property type investment projects would be considered as being fairly capital intensive with relatively longer time horizons.

Regulatory responses as a result of climate risks should also provide investors an opportunity in new markets and technologies. 

As a support investor of the Climate Action 100+ initiative, we are aligned to the TCFD requirements and expect our fund managers to do the same. If not, we ask them to explain and why that is not the case.

Similar to the TCFD recommendations we think that an appropriate timeframe to assess physical climate risks and opportunties are as follows:

  • Short term: 3-5 years
  • Medium term: 5-20 years
  • Long term: 20+ years

01.8 CC. Indicate whether the organisation publicly supports the TCFD?

01.9 CC. Indicate whether there is an organisation-wide strategy in place to identify and manage material climate-related risks and opportunities.

Describe how and over what time frame the organisation will implement an organisation-wide strategy that manages climate-related risks and opportunities.

ESG risks are material risks that have the potential to affect our members’ long term interests. Climate change risk is a primary concern among environmental risks. In addition, ignoring sustainable investment opportunities such as energy efficiency, water and waste management in investment portfolios may lead to a loss of value and materially increase risk.

Climate change is one of the greatest environmental risks that our investment portfolio faces. We are committed to:

  • Considering, identifying and managing climate change as a material financial risk for the purposes of our risk management framework. We will consider, identify and seek to take advantage of any investment opportunities available from the transition to a zero carbon emissions economy
  • Monitoring the carbon performance of the portfolio and striving for improvements
  • Ensuring that climate change risks are considered by our advisers and investment managers, including proper assessment of the data available and full company disclosures
  • Ensuring that climate change risks are analysed as part of the due diligence procedures for new investments
  • Participating in climate change related collaborative initiatives

Vision Super has made a formal statement to become carbon netrual by 2050. The fund is considering a roadmap of how we can best acheive this objective.

Vision Super is integrated into the Australian economy and its investments are integrated into the global economy. We have to act within this context. The transition and the pace it occurs at will depend on what is happening more broadly.  As we note elsewhere in this submission, a focus on the demand side of the equation has barely been mentioned or begin to be dealt with and yet it will be critical.  And this will involve massive cultural change. 

Vision Super also integrates valuation into its consideration of climate risk.  We also integrate community expectations and standards into our approach.  For example, while there might be an appropriate price for carbon intensive assets in considering a transition to a zero carbon world, we will no longer invest in companies generating significant revenues from thermal coal mining nor tar sands.  One difficulty we face is that in our view investment managers are generally well behind the pace in managing carbon risk with some notable exceptions. 

Vision Super also does not consider climate-related risks in isolation.  In our view, inequality (sometimes manifested through excessive executive remuneration) impacts on a society's ability to make effective decisions on climate change for example. Gender and other forms of diversity, particularly wealth diversity, can lead to better governance and decision making at companies and other bodies.

1.10 CC. Indicate the documents and/or communications the organisation uses to publish TCFD disclosures.


SG 02. Publicly available RI policy or guidance documents

 

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

URL/Attachment

URL/Attachment

Other, specify (1) description

          Collaboration, Engagement, Climate Change & ProxyVoting
        

Other, specify (2) description

          Manager Selection & Appointments, Monitoring & Reporting
        

URL/Attachment

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

02.3. Additional information [Optional].

For SG 02.2:

We disclose on all our proxy voting for our equity shareholdings after the completion of a company meeting here:

https://www.visionsuper.com.au/investments/active-ownership

RIAA Responsible Investment Super Study Leaders Board

The Responsible Investment Association Australasia (RIAA) recognised Vision Super in 2019, including us on their Responsible Investment Super Study Leaders Board. We were one of the top 14 out of the 57 funds they researched. They found we consistently articulate and demonstrate a comprehensive responsible investment approach across our investment framework. Importantly for our members, RIAA found that funds like Vision Super who invest responsibly have higher returns than those that don’t. Please refer to the below link

https://responsibleinvestment.org/resources/super-study/

Our participation in RIAA's 2018 Superfund Responsible Investment Benchmark Report, assessed 50 funds and found Vision Super to be one of only 12 funds that meet RIAA’s high reporting standards on responsible investment.

Refer to the following link:

https://responsibleinvestment.org/resources/benchmark-report/

Social & Community Involvement

From a social perspective, we have joined the coalition calling for better workforce reporting and become a signatory to the Workforce Disclosure Initiative (WDI). Its main objective is to bring investors together to secure comparable workforce reporting from listed companies on an annual basis. The data requested covers employees in companies’ global operations and workers in their supply chains is modeled on the Carbon Disclosure Project.

The initiative builds on existing reporting standards, and the data requested form companies covers workforce composition, stability, development, and worker engagement. As at December 2017, the WDI is backed by over 90 institutional investors, responsible for more than $8.6 trillion in assets.

During 2018, we were invited to participate in the Asset Owners Disclosure Project Global Climate Risk Index out-of-scope assessment based of this year’s methodology without inclusion in the main index offering a public rating badge on our assessment and approach to ESG.

The Fund is also a member of the national City Switch Green Office program which helps organisations to achieve office energy efficiency and reduce carbon emissions and also has a comprehensive recycling system within the office in order to reduce waste.

Furthermore, the Fund is involved in the community outside of super. Each year, we support a number of grassroots events, where we get the opportunity to give back to our members and their local communities.

Over the last few years our Vision Super staff raised over $80,000 for the Snowdome Foundation, Kidney Health Australia, Carers Victoria and the Royal District Nursing Service through staff participation in the Murray to Moyne cycling event. This year, we donated to the bushfire recovery in Victoria, in response to the devastating bushfires that affected areas where our members live and work.

Through social activities, our staff also regularly fundraise for charities including the Prostate Cancer Foundation of Australia, and the Cancer Council Australia. These activities see our diverse range of staff work together to contribute to worthwhile causes. A Vision Super team participated in the Mothers Day Classic, raising money for breast cancer research, and we have a variety of other charity fundraising events planned throughout the year.

We are committed to caring for Victorian communities and organisations that offer positive, sustainable and practical help for all Victorians. Our key community and industry partners include the following:

•ME Bank: ME Bank was created in 1994 to help everyday Australians reach the dream of owning their own home. Now ME is a fully fledged bank, with profits going back to the industry super funds that own them.

•Municipal Association of Victoria (MAV): The MAV are the legislated peak body for local government in Victoria. Formed in 1879, we have a long and proud tradition of supporting councils and councillors.

•Australian Services Union (ASU): Representing the interests of approximately 135,000 members across the country, the Australian Municipal, Administrative, Clerical and Services Union, trading as the Australian Services Union or, just simply, the ASU, is one of the largest trade unions in Australia.

•Victorian Water Industry Association: The Victorian Water Industry Association (VicWater) is the peak industry association for water businesses in Victoria.

•Victorian Chamber of Commerce and Industry: The Victorian Chamber of Commerce and Industry is the peak body for business in Victoria, informing and servicing more than 15,000 members, customers and clients around the State.

The Fund has replaced two of its fleet cars with hybrid Toyota Corollas, and we have a commitment to move our entire fleet to hybrid, electric or other innovative vehicles as options become available that meet our needs. The hybrid Toyotas use significantly less fuel - around 4.5 liters per 100 kilometers, compared with an average of 10.2 liters for the rest of the fleet and use fully recyclable batteries. As the cars come up for renewal we’re looking at investing in a plug-in all electric vehicle for driving around Melbourne, and are monitoring technology and charging stations with a view to going all electric once the infrastructure is there to support our on-road team who travel extensively around Victoria. Our travel policies encourage the use of public transport where ever possible.

To reduce paper consumption Vision Super has pass code printing, which means employees can print only after swiping their security pass at the printer. This has reduced uncollected printing at all our printers throughout the office. We’ve also moved to a ‘digital default’ model where we send communications to members by email as the default and only mail to members who don’t have an email address or have specifically requested paper, or where we’re required to do so by legislation.


SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

We have a Conflict Management Policy (CMP) which applies across the organisation (including the investment process).  The purpose of this Policy is to outline Vision Super’s strategy for managing conflicts (including and the key elements of how we manage conflicts (both actual and perceived) and how it links to Vision Super’s wider risk management framework.  This policy and its underlying framework (the CMF) are reviewed regularly and the underlying framework is reviewed triennially by a person who is operationally independent, appropriately trained and competent.

The CMF is aligned to the Australian Prudential Authority (APRA) Prudential Standard SPS 521 Conflicts of Interest (SPS 521) and is applicable to all directors, senior management and staff.

The Policy operates in conjunction with our Governance and Policy Framework, Risk Appetite Statement (RAS) and Risk Management Strategy (RMS). It also incorporates Vision Super’s Code of Conduct which applies to all directors, responsible persons and staff.

03.3. Additional information. [Optional]

In addition to response to SG 03.2, the CMF is incorporated into Vision Super’s Investment Governance Framework Policy and Vision Super’s due diligence process for potential investments includes assessment of any conflicts of interests.

The Vision Super CMF provides a structure to:

•Identify relevant duties and relevant interests

•Identify conflicts of interest or duty (including potential and perceived conflicts)

•Manage identified conflicts in an appropriate, effective and consistent manner.

A summary of the Policy is located on Vision Super’s website at:

https://www.visionsuper.com.au/images/policies/conflicts-management-summary-2019.pdf

The Vision Super CMF refers to all the structures, systems, people, policies and processes that have been implemented to identify, manage, treat and monitor conflicts of interest.

The CMF is one of Vision Super’s functional governance frameworks as described in Vision Super’s Governance and Policy Framework. Vision Super believes an effective CMF supports the business to make informed decisions, take advantage of opportunities and allows the business to identify the factors that may create an actual or perceived conflict.

The Board is required to operate the fund in the best interests of its members (including all beneficiaries of the Fund).  There are trustee covenants within the Superannuation Industry (Supervision) Act 1993 (SIS Act) that require the Board to act honestly, to exercise a required degree of care, skill and diligence and to perform their duties and powers in the best interests of members. These covenants further specify that the Board must ensure that where a conflict arises and has not been avoided, the duties to and interests of beneficiaries take priority over any duties to and interests of, other persons.

A conflict refers to a situation where the Board, individual directors, responsible persons or staff deliberately or inadvertently prefer their own interests, or that of another person/entity, over the interests of members.  These conflicts (both actual and perceived) may relate to a relevant interest and/or duty.

A relevant interest is:

•Any interest, gift, emolument or benefit

•Financial or non-financial

•Held directly or indirectly held by directors, responsible persons or staff, or an associate of directors, responsible persons or staff, and

•Is reasonably determined to impact the capacity of the director, responsible persons or staff member to act in the best interests of members.

A relevant duty is:

•Any duty owed by directors, responsible persons or staff to an entity or persons other than beneficiaries, and

•Is reasonably determined to impact the capacity of the director, responsible person or staff member to act in the best interests of members.

As the CMF is incorporated into Vision Super’s Investment Governance Framework, conflicts of interests and duties are always monitored and managed appropriately.

A register of interests and duties is maintained.  It is disclosed on our website at: https://www.visionsuper.com.au/images/policies/Registerinterests2020.pdf 

Both directors and staff are required to disclose their interests and duties and to update this with any changes.

At each relevant meeting, the register of interests and duties is reviewed and any conflicts are addressed and the management of that conflict agreed. This includes the internal investment committee meetings, the Investment Committee meetings and the Board meetings.  Due consideration is given to all matters where it has specific governance implications in relation to matters being considered and decided upon.

How Vision Super manages an actual/perceived conflict depends upon the nature of that actual/perceived conflict. 

Examples of how an actual/perceived conflict include:

•Obtaining legal advice on the existence of an actual/perceived conflict

•Declaring conflicts (perceived, potential and actual) at commencement of each board meeting

•Leaving the relevant meetings during the discussions/voting on any matters relating to the issue

•Abstaining from discussions on any matters relating to the issue

•Upon advice, abstaining from voting on any matters in which the director could be interested

•Affirming, at conclusion of each board meeting, that the decisions made have been in the best interests of members for whom the director is a fiduciary, and

•Where the conflicts are personal, requiring a proxy to stand in the director’s place for voting on the resolutions where the conflict arose. The director in question will be prohibited from providing their proxy with a direction on how to vote in this situation.


SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within investee entities.

04.2. Describe your process on managing incidents

The Investment Governance Framework Policy articulates many aspects on how the executive investment team monitors and reports on its fund managers.  The Trustee has a Board approved Incident and Breach Policy. When incidents and breaches occur, there are all recorded in our Incident Breach Register and there is a process for investigation and rectification. This is overseen by our Quality and Risk team.  There is reporting to the relevant Committee/s and Board.

Our custodian National Asset Servicing, as part of our service level agreement with them undertakes mandate compliance monitoring based on the investment guidelines (authorized investments and restrictions) as outlined with our investment management agreements for each listed mandate we have in place with fund managers. We also log incidents internally within the incident and breach register which is then investigated and managed by the internal compliance/risk team.

Furthermore, as part of our annual compliance obligations for material outsourcing requirements, we request from our fund managers, master custodian, transition managers and investment advisor the following items/questions as part of our compliance and evaluation sign-off. This is also reviewed by internal compliance and reported to the Governance, Risk and Appointments Committee annually:

Derivative Instruments:                                                                                                   

•You confirm that where derivative instruments have been used, your firm has acted in accordance with your derivative risk statement (DRS) which has previously been provided to Vision Super.

•If, following the repeal of APRA Circular II.D.7- Derivatives, your firm has decided to cease to use a DRS, please provide details of the risk management strategies that your firm has in place to manage the use of derivatives.

Risk Management:

•You confirm that your firm’s risk management strategies address the risk tolerances adopted by your firm, the management of appropriate lines of authority and responsibility for transacting derivatives (including trading limits), and considers worst case scenarios, sensitivity analysis, and the reporting of that analysis.

•You confirm that your firm has ensured that any breaches of the Agreement have been escalated and reported to Vision Super immediately.

•You confirm that your firm has in place, and maintains at all times, an effective business continuity and disaster recovery policy and procedure.

•You confirm that your firm had a Business Continuity and Disaster Recovery Plan for the year ending 30 June 2019 and conducted testing at least once between 1 July 2018 and 30 June 2019.

•Please include a high-level summary of the results of the last business continuity and disaster recovery tests undertaken.

•You confirm that your firm has adequate computer systems in place which provide for back-up of data and software, and that back-up tapes are stored off-site and maintained for the requisite period of time (i.e. in line with the relevant legislation).

•You confirm that your firm has, at all times, documented policies and procedures in place for the detection and prevention of fraud (including any instances of suspicious transactions or activities), which includes a process whereby Vision Super is notified of any instances of fraud/suspicious activity which may affect Vision Super’s portfolio.

•You confirm that your firm promptly reports all instances of fraud, as well as any suspicious transactions, to Vision Super.

•Since the last review, have any changes or events occurred which have had (or will have) an impact on the Risk Management Framework at your firm? If so, please provide details and any associated documents to that effect.

Portfolio Management:

•You confirm that your firm has kept Vision Super’s portfolio under view, and that you could freely communicate with no obstacles, at regular intervals, with Vision Super regarding the investment and management of the portfolio.

•You confirm that your firm has kept proper books of account in relation to Vision Super’s portfolio which records transactions, and provides information in relation to Vision Super’s portfolio, which assists Vision Super, its custodian and its auditors in the preparation of reports required under the relevant legislation.

•You confirm that your firm has not taken any charge, lien or other encumbrance over, or in relation to, the assets of Vision Super’s portfolio other than expenses and outlays of expenses made within the terms of the Agreement.

•You confirm that your firm has provided proper instructions to its custodian in relation to transactions concerning Vision Super’s portfolio.

•You confirm that your firm has used all reasonable endeavors to ensure that the assets within Vision Super’s portfolio are invested in accordance with Vision Super’s authorized instructions.

Disclosure and Reporting:

•You confirm that your firm has prepared, and delivered to Vision Super and its custodian, all reports in accordance with the Agreement in a proper and timely manner, which are free of material defects, errors or omissions.

•You confirm that your firm has exercised all due diligence and vigilance in carrying out its functions, powers, and duties under the Agreement.

•You confirm that your firm has provided a summary of any investment instructions agreed between Vision Super and your firm for the management of Vision Super’s portfolio, as well as any changes which may have occurred during the reporting period.

•You confirm that your firm has accounted to Vision Super for any monetary benefits, fees or commissions received, or any related body corporate of your firm, in relation to the investment of Vision Super’s portfolio (other than benefits permitted in your firms policy on soft dollar arrangements and fees and commissions permitted) in accordance with the Agreement.

Other questioning relates to the following areas:

•Internal Controls

•Auditing &

•Governance Issues

•i.e. ◦You confirm that your firm is not the subject of any investigation by any governmental or regulatory authority or self-regulating organization. In the case where it is alleged that your firm has breached any of its regulatory obligations or engaged in misconduct, please provide appropriate notices and relevant details.

◦You confirm that there are no current or anticipated criminal or material civil proceedings in any Australian court or tribunal which directly involves your firm.

◦You confirm that that your firm is a body corporate and not a disqualified person under the Superannuation Industry (Supervision) Act 1993.

 


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