A. Advisory Firm Macquarie Investment Management Global Limited (“MIMGL”), the Registered Investment Advisor, was established on 5 February 1999 as a company limited by shares. It is incorporated and domiciled in Australia. MIMGL was previously registered in the name of “Macquarie Capital Investment Management (Australia) Limited” and the effective date of the name change to MIMGL, was 1 July 2015.

MIMGL is a full-spectrum investment manager and offers traditional investment management capabilities across a number of asset classes including fixed income, currencies, equities, infrastructure, hedge funds and multi-asset allocation solutions. It delivers a full-service offering to both institutional and retail clients.

MIMGL operates within Macquarie Asset Management (“MAM”). MAM is one of five operating businesses within Macquarie Group Limited (“MGL”). All business activities are encompassed by a strong risk management framework and are facilitated by a number of Macquarie-wide support groups. MIMGL has an Australian Financial Services License (AFS License No: 237843) which authorises the entity to, among other things to, provide financial product advice and deal in financial products.

MIMGL is ultimately owned by MGL, the ultimate parent of Macquarie Group, a multi-national financial services company, via the following holding structure:

Direct 100% owner

Direct 100% owner

B. Advisory Services Provided MIMGL provides portfolio management and investment advisory services for clients located in jurisdictions globally where MIMGL is authorized to provide such services or are exempt from such authorization. It is reasonably likely that MIMGL’s services will be provided across a number of asset classes, including:


• Australian, international and regional equities and equity securities
• Australian and international fixed income
• Cash
• Currencies
• Derivatives

MIMGL’s services may be provided in connection with separately managed accounts or pooled portfolios, including pooled portfolios established or sponsored by related parties of MIMGL. C. Tailored Advisory Services Advisory services are tailored to the specific needs of the client. These arrangements, and any relevant restrictions, are outlined in the agreement entered into between MIMGL and each client. Macquarie Group Limited (Australian Securities Exchange listed entity, stock code ASX: MQG) Privately-held intermediate subsidiaries Form ADV Part 2A Page 5 D. Wrap Fee Programs MIMGL does not participate in wrap fee programs.

E. Regulatory Assets under Management MIMGL provides regular supervisory and investment management services to a portfolio of client assets. The amount of regulatory assets under management (“AUM”) as at 31 March 2019 is:

U.S. Dollar Amount Discretionary: US$ 53,514,544,647 Non-Discretionary: US$ 0.00 Total: US$ 53,514,544,647 please register to get more info

A. Compensation Fee rates are negotiable and may vary depending on a number of factors, including the size and nature of the mandate and the nature of the services provided. Fees may comprise management fees (either a fixed dollar amount or a percentage of gross or net assets under management) and performance fees. The specific fee arrangements, including the amount, timing, and basis of calculation is determined through negotiations with the client and documented in a written agreement.

B. Payment of Fees The time at which fees are payable is negotiated with the client. In general, management fees are payable monthly or quarterly in arrears. Performance fees are payable on outperformance above an agreed benchmark, and may be subject to a high watermark. The written agreement with the client generally provides that the client may terminate the agreement under specific circumstances without the payment of any penalty, upon giving notice to MIMGL.
C. Other fees
No additional fees are paid to MIMGL by clients in connection with advisory services provided. D. Payment of Fees in Advance Clients are not permitted to pay fees in advance of advisory services being provided. E. Compensation for Sale of Securities or Other Investment Products Neither MIMGL nor any of its supervised persons receives any compensation for the sale of securities or other investment products. All forms of compensation are outlined in Item 5.A. Form ADV Part 2A Page 6 please register to get more info

MIMGL does charge performance-based fees on certain accounts. MIMGL access persons may manage accounts that are charged both a performance-based fee and accounts that are charged another type of fee.

MIMGL is aware that performance-based fees have the potential to cause a conflict of interest by creating an incentive to favour accounts charging such fees over accounts charging asset-based fees. The MIM Best Execution Policy and MIM Deal Allocation Policy address such potential conflicts of interest by prohibiting the Portfolio Manager from unfairly favouring one account over another. These policies, which apply equally to accounts that charge asset-based fees and those that are charged performance-based fees, generally require allocations of investment opportunities to be considered for all eligible funds, taking into account the differing AUM levels, limits and risk profiles. please register to get more info

MIMGL generally provides or will provide investment advisory services to the following types of clients:


• Banks or thrift institutions as sub adviser to other asset managers;
• Pension and profit sharing plans;
• Trust, estate or charitable organizations;
• Corporations/business entities;

MIMGL’s clients may also include governments, government agencies, international organizations, educational institutions and pooled investment vehicles. please register to get more info

A. Methods of Analysis and Investment Strategies MIMGL’s security analysis methods include fundamental and technical analysis.

The main sources of information used by MIMGL are financial newspapers and magazines, interviews of corporate officers and facilities tours, financial research reports and materials prepared by others, publications and ratings issued by corporate rating services, periodic and annual reports, prospectuses and other filings with the Securities and Exchange Commission and similar foreign organizations, company press releases and other publicly available information considered useful by MIMGL. In addition to those sources enumerated, MIMGL also utilizes various additional sources of information to evaluate the investment merits of particular investments, including private placement memoranda prepared by commercial and investment banks, independent credit analysis and market research prepared by banks and brokers, data and statistics published by various bodies and any other due diligence materials appropriate for the nature of the prospective investment.

B. & C. Risk of Loss The following is an outline of the material risks associated with the significant investment strategies and methods of analysis used by MIMGL. MIMGL’s risk management objective is to deliver risk/return outcomes in line with its clients’ expectations. Volatility risk - The price of an investment may go up and down by a material amount, even over a short period of time.
Investment manager risk refers to the risk that MIMGL’s investment style will not achieve its risk and
return objectives, or that it will produce returns that do not compare favourably against its peers or stated performance fee hurdle (if applicable), or that MIMGL will not implement the strategy correctly. Form ADV Part 2A Page 7 Concentration risk is the risk that poor performance in a group of stocks common to a particular region, industry, or other grouping, will significantly affect the performance of the investments or investment strategy recommended by MIMGL. Basis risk arises when the terms and specifications of a derivative contract do not precisely match those of the asset being hedged. Mismatches typically relate to hedging stock-level equity exposures with market-level derivatives. Hedging can also reduce a portfolio’s potential to profit from moves in the underlying asset being hedged.

Turnover risk is the risk that due to the active nature of the strategy of a portfolio, the turnover rate of a portfolio may be substantial, and may involve correspondingly high transactional costs that are borne by the portfolio.

Foreign investment risk - This risk exposes the investments of a portfolio to a range of macroeconomic factors which are unique to the country of investment/operation, and may include factors such as political instability, differing tax or legal rulings and potentially rapid changes in asset prices (particularly for emerging economies).

Emerging market risk refers to the potential for the portfolio to invest in securities which are listed on the exchanges of emerging economies, as well as investing in companies which are located or have operations within such markets. Emerging markets are typically more volatile than developed markets and may expose a portfolio to issues such as heightened political unrest, sovereign intervention, securities whose valuations fluctuate widely and the potential for domestic economic management to impact on the viability of property-based operations within that market.

Currency hedging risk is the risk that currency hedging transactions do not completely remove the currency risk between the investments’ underlying currency exposures and the currency in which the shareholder’s shares are denominated. Currency hedging transactions will affect the returns such that the portfolio does not perform in the same manner as if the investments were left unhedged.

Counterparty risk is the risk of loss due to a counterparty not honouring a financial commitment. Counterparties may include equity brokers, brokers of exchange traded futures, clearing brokers for exchange traded futures, foreign exchange counterparties, and swap counterparties.

Liquidity risk exists when particular investments are difficult to purchase or sell, preventing a portfolio from closing out its position or rebalancing within a timely period and at a fair price. While every effort is made for a portfolio to be able to meet all redemption requests, prevailing market conditions may result in the inability to meet all redemption requests when they are received.
Investment objective risk is the risk that an investor’s objectives will not be met by their choice of
investments. One measure of risk in an investment is the volatility of returns; the greater the volatility, the more likely that returns will differ from those expected. Investments in equity securities and derivatives are traditionally towards the higher end of the risk-return spectrum. This may lead to fluctuations in the unit price and/or amounts distributed to unit holders, including fluctuation over the period between a redemption request being made and the time of redemption. Derivatives risk. Derivatives are leveraged instruments that are used to obtain or reduce market exposures. As the market value of derivatives is variable, gains or losses can be incurred and can be greater than positions in unleveraged instruments. A portfolio may utilize derivatives in order to achieve its investment objective. Form ADV Part 2A Page 8 Equities market risk. A portfolio is exposed to changes in the value of its investments due to equity market risk. This may result in volatility of the share price, and may also result in the loss of principal. Factors that drive changes in share prices include changing profitability of a company or the industry sector in which it participates, general economic cycles, volume of share issuance, investor demand levels, business confidence and government and central bank policies. please register to get more info

A. Criminal or Civil Action There are no such actions with respect to MIMGL or any of its management persons.

B. Administrative Proceedings before a Regulatory Agency There are no such proceedings with respect to MIMGL or any of its management persons.

C. Proceedings before a Self-Regulatory Agency There are no such proceedings with respect to MIMGL or any of its management persons. please register to get more info

A. & B. Other Registrations Neither MIMGL nor any of its management persons are registered, or have an application pending to register, as a broker-dealer, a futures commission merchant, a commodity pool operator, a commodity trading advisor, or a registered representative or associated person of the foregoing entities.

C. Affiliations MIMGL is a direct wholly owned subsidiary of Macquarie Investment Management Holdings Pty Limited (“MIMHPL”). MIMHPL is indirectly wholly owned by Macquarie Group Limited (“MGL”). MIMGL is part of Macquarie Asset Management, a business division of the Macquarie Group.

Macquarie Asset Management’s global investment advisory business comprises investment professionals located in Australia (operating through MIMGL, Macquarie Investment Management Australia Limited (MIMAL), MQ Specialist Investment Management Limited), in EMEA (operating through Macquarie Investment Management Europe Ltd, Macquarie Investment Management Austria Kapitalanlage AG and Macquarie Investment Management Europe S.A.), In Japan (operating through Macquarie Asset Management Japan Co.), in the USA (operating through Macquarie Capital Investment Management LLC, Macquarie Investment Management Business Trust,), and in Hong Kong (operating through Macquarie Funds Management Hong Kong Limited). MIMGL’s related parties include Macquarie Capital (USA) Inc., a U.S registered broker-dealer and member of FINRA that may offer securities in the pooled investment vehicles that MIMGL sponsors and/or advises. Refer to Item 11 B., C. & D: Potential Conflicts of Interest, for a description of material conflicts potentially created by these relationships and how such conflicts are addressed by MIMGL. Form ADV Part 2A Page 9 please register to get more info

A. Code of Ethics All officers and employees of MIMGL are subject to the provisions contained in MIMGL’s Code of Ethics (“Code”), which includes a Personal Investments Policy, Gift and Entertainment Policy, Conflict of Interest Policy and Code of Conduct. These policies are designed to mitigate actual or potential conflicts of interest. The Code outlines MIMGL’s policies and procedures regarding standards of conduct, personal investment transactions, and handling of material, non-public information.

MIMGL imposes restrictions on the ability of its employees and their supervised persons to invest in securities that may be recommended or traded in MIMGL’s client accounts. This policy currently applies to most securities transactions (including transactions in equity or debt securities, municipal bonds, exchange-traded securities, securities indices, derivatives of securities and similar instruments).

Pursuant to this policy, employees are required to pre-clear all of their personal securities transactions in securities that are not exempt from the policy. Employees must also receive prior approval before purchasing any securities in a private placement or pursuant to an initial public offering. Further, employees must receive prior approval to serve on a board of a publicly traded company or to engage in certain other outside activities that may conflict with MIMGL's obligations to its clients.

Employees are subject to a 30-day holding period between purchases and sales, or sales and purchases in the same securities.

Any employee who violates this policy may be subject to disciplinary actions, including possible dismissal. In addition, any securities transactions executed in violation of this policy, such as short-term trading or trading during blackout periods, may subject the employee to sanctions, ranging from warnings and trading privilege suspensions to financial penalties, including but not limited to, unwinding the trade and/or disgorging the profits as well as additional disciplinary action. Violations and suspected violations of criminal laws will be reported to the appropriate authorities as required by applicable laws and regulations.

If an employee possesses non-public price-sensitive information about or affecting a financial product, or the issuer of any financial product, that employee is prohibited from buying or selling such financial product, or advising or procuring any other person to buy or sell such financial product.

A copy of the Code will be provided to any client or prospective client upon request.

B., C. & D. Potential Conflicts of Interest MIMGL‘s ultimate parent is MGL, a multi-national financial services company. Therefore, MIMGL is affiliated with a number of entities that may provide, and/or may engage in commercial banking, insurance, brokerage, investment banking, financial advisory, broker-dealer activities (including sales and trading), hedge portfolios, real estate and private equity investing, in addition to the provision of investment management services to institutional and individual investors. Since MGL, its affiliates, directors, officers, and employees (the “Macquarie Group”) are engaged in businesses and have interests other than managing asset management accounts, such other activities may involve real, potential or apparent conflicts of interests. These interests and activities include potential advisory, transactional and financial activities and other interests in securities and companies that may be directly or indirectly purchased or sold by MIMGL for its clients' advisory accounts. These are considerations of which advisory clients should be aware and which may cause conflicts that could be to the disadvantage of MIMGL’s advisory clients. Present and future activities of the Macquarie Group, in addition to those described herein, may also result in conflicts of interest that may be disadvantageous to MIMGL’s clients. Form ADV Part 2A Page 10 MIMGL has established policies, procedures and disclosures designed to address conflicts of interest arising between advisory accounts and the Macquarie Group’s businesses. It is MIMGL’s policy that its personnel involved in decision making for advisory accounts must act in the best interests of their advisory clients and generally without knowledge of the interests of proprietary trading and other operations of the Macquarie Group and/or personnel of the Macquarie Group. Where advisory personnel do know of conflicts or potential conflicts among advisory accounts or between advisory accounts and the Macquarie Group and/or personnel of the Macquarie Group, it is MIMGL’s policy to disclose the existence of such conflicts or potential conflicts in general form through this Form ADV or directly to clients.

MIMGL (i) has related parties that may act as principal, broker or agent in connection with securities transactions with or for clients; (ii) may recommend that clients buy or sell securities in which MIMGL or another affiliate has a financial interest; and (iii) may buy and sell for its own account securities that it recommends to clients.

MIMGL may enter into arrangements with affiliates and third-party service providers to perform various administrative, back-office and other services relating to client accounts. Such service providers may be located in the US or in non-US jurisdictions.

MIMGL acts as a fiduciary with respect to its asset management activities and owes its clients a duty of undivided loyalty. As a fiduciary, MIMGL is required to act solely in the best interests of the clients whose assets it manages. On occasion, other entities within the Macquarie Group may have engagements and responsibilities which could give the appearance of a conflict with MIMGL’s duty of loyalty. To minimize these conflicts, as a general matter, MIMGL’s employees associated with the investment process (including portfolio managers, research analysts and traders) have no contact with employees of the Macquarie Group outside of the Macquarie Asset Management Group (one of five operating groups within Macquarie Group) regarding specific clients, business matters or initiatives, unless permissible by internal procedures, or approved by MIMGL’s Compliance. In Australia, MIMGL and MIMAL are the primary asset management entities within Macquarie Investment Management.

The Macquarie Group is a major participant in global financial markets and it acts as an investor, investment banker, investment manager, financer, advisor, market maker, trader, lender, agent and principal in the global fixed income, currency, equity and other markets in which MIMGL’s advisory accounts directly and indirectly invest. As permitted by, and in conformity with applicable laws and regulations, MIMGL’s advisory accounts will invest in, engage in transactions with, make voting decisions with respect to, or obtain services from entities for which the Macquarie Group performs or seeks to perform banking or other services. Additionally, it is likely that MIMGL’s advisory accounts will undertake transactions in securities in which the Macquarie Group makes a market or otherwise has direct or indirect interests. MIMGL makes decisions for its clients in accordance with its fiduciary obligations as manager of its advisory accounts. As noted below, however, certain activities of the Macquarie Group may have a negative or detrimental effect on advisory accounts of MIMGL.

MIMGL may take investment positions in securities in which other clients or related persons within MGL have different investment positions. There may be instances in which MIMGL is purchasing or selling for its client accounts securities in which the Macquarie Group is undertaking the same or differing strategy. Prices, availability, liquidity and terms of the investments may be negatively impacted by the Macquarie Group’s activities and the transactions for MIMGL’s clients may, as a result, be less favorable. The investment results for MIMGL’s clients may differ from the results achieved by the Macquarie Group and other clients of the Macquarie Group. In addition, results among MIMGL clients may differ. For a summary of the restriction of the flow of certain information between MIMGL and other parts of the Firm, please see "Information Barriers and Confidentiality" below. As noted, MIMGL makes decisions for its clients in accordance with its fiduciary obligations as Form ADV Part 2A Page 11 manager of its advisory accounts; independent of what decisions may be made by or in other parts of the Macquarie Group.

The investment activities of the Macquarie Group may limit the investment opportunities for MIMGL’s client accounts. This may occur in certain regulated industries, private equity markets, emerging markets, listed securities market and in certain futures and derivative transactions where restrictions may be imposed upon the aggregate amount of investment by affiliated investors. MIMGL may voluntarily limit transactions for client accounts or limit the amount of voting securities purchased for client accounts, or waive voting rights for certain securities held in client accounts, which may limit positions, in order to avoid circumstances which, in the view of MIMGL, would require aggregation of such client account positions with investments elsewhere in the Macquarie Group that would approach or exceed certain ownership thresholds.

MIMGL may engage in security transactions with brokers who coincidently sell shares of registered investment companies advised by MIMGL, provided that it reasonably believes that the broker will provide best execution. There are no quid pro quo arrangements or agreements in place with these brokers. However, trading with these brokers may raise the appearance of a conflict of interest.

Macquarie Group may also engage MIMGL to manage proprietary money in accounts or portfolios that are separate from Client Accounts (“MIMGL proprietary accounts”). MIMGL may buy, sell, or hold securities or other instruments for MIMGL proprietary accounts while entering into different investment decisions for one or more Client Accounts.

Information Barriers & Confidentiality The Macquarie Group may come into possession of confidential, material non-public information particularly in connection with its commercial and investment banking activities. The Macquarie Group, including MIMGL, has internal procedures in place intended to limit the potential flow of any such non- public information. Should MIMGL come into possession of material, non-public information, MIMGL has procedures that prohibit trading activities based on such information by MIMGL for its clients and by MIMGL employees. MIMGL may not use material, non-public information obtained from any division of the Macquarie Group when making investment decisions for its clients. As a result of these procedures and prohibitions, client accounts may be precluded from purchasing or selling certain securities, which could have a detrimental effect on one or more client accounts. There may be instances where members of MIMGL’s senior management who are not involved in the investment process may be privy to material, non-public information about transactions or securities due to discussions with senior personnel from other departments within the Macquarie Group. However, when in possession of material, non-public information, such members of senior management may not participate or use that information to influence trading decisions or securities; nor may they pass that information along to personnel within MIMGL involved in the investment process (e.g. portfolio managers, research analysts and traders).

There may also be periods during which MIMGL may not initiate or recommend certain types of transactions, or may otherwise restrict or limit its advice given to clients in certain securities issued by or related to companies that the Macquarie Group is performing banking or other services, or companies in which the Macquarie Group has a proprietary position. As a result, client accounts may be precluded from purchasing or selling certain securities, which could have a detrimental effect on one or more client accounts. Trading with an Affiliate/New Issues Currently, the only compensation received by MIMGL for effecting securities transactions for clients is its advisory fees and commission sharing arrangements. Related persons of MIMGL may receive brokerage commissions, commission equivalents, spread and other fees in connection with brokerage services Form ADV Part 2A Page 12 provided. See Item 12 for more details. MIMGL may purchase, on behalf of its clients, securities in which an affiliate of MIMGL serves as lead underwriter or co-manager of an underwriting syndicate or member of an underwriting syndicate. In these cases, the purchase is generally made from a party unaffiliated with MIMGL, but MIMGL's affiliate may nevertheless benefit from such transactions, including in circumstances where the syndicate of which MIMGL's affiliate is a member is experiencing difficulty in effectuating the distribution of the new issues.

While MIMGL acts solely in the best interests of its clients, these circumstances may give rise to the appearance of a conflict of interest; even though the transactions are effectuated in compliance with applicable regulations (see "Agency Transactions" below). MIMGL may have a potentially conflicting division of responsibilities to both parties to a cross transaction. Additionally, regulatory requirements applicable to MIMGL's related persons may restrict MIMGL from investing in certain securities for its clients. This may affect potential returns on clients' accounts and a client not advised by MIMGL may not be subject to some of these restrictions.

Agency Transactions MIMGL is a related person of various broker-dealers through which it may effect agency transactions. MIMGL has procedures reasonably designed to ensure that agency transactions executed with these related broker-dealers acting as agent comply with applicable law and regulations. If any client portfolio transaction is executed with related broker-dealers, the broker-dealers may charge a commission in connection with these transactions; however, the commissions do not exceed the usual and customary commission that the broker-dealers would charge their own customers. As a general matter, MIMGL can execute agency transactions on behalf of clients with related broker-dealers only if MIMGL has determined in good faith that the client will receive best execution in the transaction, and only in compliance with applicable law and regulations, MIMGL’s policies and procedures, and in accordance with the consent of clients to these kinds of transactions. Executing transactions with affiliates of MIMGL presents conflicts of interest, including that MIMGL affiliates will earn fees with regard to such transactions.

Proprietary Account Trading In accordance with the Macquarie Group’s policy, MIMGL may invest and manage proprietary capital in certain products and strategies also managed by MIMGL for clients; these investments may be hedged against market risk, while client assets may not be so hedged. The portfolio management and trading of the proprietary capital investment as well as any associated hedge activity is undertaken in accordance with MIMGL policies and procedures. Proprietary capital may not perform the same as similarly managed client accounts for a variety of reasons, including regulatory restrictions on the type and amount of securities in which the proprietary capital may be invested, differential credit and financing terms, as well as any hedging transactions. While MIMGL acts solely in the best interests of its clients, these circumstances may give rise to the appearance of a conflict of interest.

MIMGL maintains or is subject to various policies regarding Code of Conduct, Personal Dealing, Gifts and Entertainment, Personal Conflicts of Interest and Conflicts of Interest generally that are designed to mitigate actual or potential conflicts of interest. Copies of these policies are available to view upon request. MIMGL imposes restrictions on the ability of its employees and their supervised persons to invest in securities that may be recommended or traded in MIMGL’s client accounts. This policy currently applies to most securities transactions (including transactions in equity or debt securities, municipal bonds, exchange-traded securities, securities indices, derivatives of securities and similar instruments) and mutual portfolio transactions (including transactions in closed end mutual portfolios, excluding money market portfolios and other mutual portfolios specifically designed for short-term investment). Form ADV Part 2A Page 13 Pursuant to this policy, employees are required to pre-clear all of their personal securities transactions in securities that are not exempt from the policy. Employees must also receive prior approval before purchasing any securities in a private placement or pursuant to an initial public offering. Further, employees must receive prior approval to serve on a board of a publicly traded company or to engage in certain other outside activities that may conflict with MIMGL's obligations to its clients. please register to get more info

Selection of Broker-dealers MIMGL’s ability to determine the securities bought and sold as well as the amount bought and sold is limited by the investment objectives of the client and the diversification and other requirements of the mandate agreed with the client and documented in the client agreement.

When selecting brokers and dealers to execute transactions, MIMGL will consider several different factors, including, among others, a broker’s and dealer’s quality of execution (for example, accurate and timely execution, clearance and error/dispute resolution); reputation, financial strength and stability of the party; ability to execute block trading and block positioning capabilities; willingness to execute difficult transactions; willingness and ability to commit capital; access to underwritten offerings and secondary markets; ongoing reliability; overall costs of a trade (net price paid or received); nature of the security and the available market makers; desired timing of the transaction and size of trade; confidentiality of trading activity; market intelligence regarding trading activity and the value of research and brokerage services provided. Consistent with MIMGL’s policy to seek best execution, there may be occasions where MIMGL uses a broker or dealer that charges a higher transaction price if MIMGL determines in good faith that the amount of such cost is reasonable in relation to the value of the product and/or service provided by the executing broker. As a result of considering these multiple factors, MIMGL may pay a broker or dealer a higher transaction price than the amount that would be charged by another broker and dealer to execute the same transaction.

The services furnished by a broker may benefit MIMGL in rendering investment advisory services to all of its clients. MIMGL may pay a broker a commission in excess of that which another broker might have charged for effecting the same transaction, in recognition of the value of the brokerage or research services provided by the broker. Soft dollars means research or other benefits (products or services) provided to MIMGL by a broker (dealer) as a result of commissions generated from financial transactions executed by the broker for client accounts or portfolios managed by MIMGL. As MIMGL operates in a number of jurisdictions globally, MIMGL’s soft dollar principles is based on the CFA Institute Soft Dollar Standards – Guidance for Ethical Practices Involving Client Brokerage, the FSC Guidance Note No. 10.00 – Brokerage Arrangements, U.S Safe Harbor requirements under Section 28(e) of the Securities and Exchange Commission Act, the Hong Kong Securities and Futures Commission Code of Conduct (Section 13.1 – 13.4).

Client Referrals MIMGL does not engage in broker referral activities, but has related persons that do engage in these activities. Directed Brokerage Clients may direct MIMGL to use specific broker-dealers. If a client directs MIMGL to use a specific broker- dealer, it may lose any discounts that MIMGL may negotiate on aggregated transactions, it may pay higher transaction costs or brokerage commissions and MIMGL may be unable to achieve the most favorable execution. Directing MIMGL to use a particular broker-dealer might also affect the timing of a client’s transaction. There may be times when MIMGL may not trade with a client’s directed broker-dealer until all Form ADV Part 2A Page 14 non-directed brokerage orders are completed. please register to get more info

Equity Portfolios In some instances the clients in equity portfolios receive daily performance, NAV's and portfolio listings but typically this information is provided monthly. Portfolio reports detailing performance, attribution, market review etc. are distributed at least quarterly but more often monthly.

Equity portfolios are reviewed by the portfolio managers on at least a weekly basis and monitored daily. The portfolios are monitored on a daily basis by an independent risk management team. The independent team ensures the portfolios are managed within their stated guidelines. In the event a portfolio underperforms over a period of time, then additional internal reporting may be required to explain the underperformance in detail and any changes required to the process.

Fixed Income and Currency Portfolios The following outlines the processes where MIMGL has Fixed Income and Currency Portfolios. Fixed Income and Currency portfolios are monitored daily by the portfolio managers. The team has a weekly portfolio managers meeting to share market information and discuss current positions taken. Each sub-team also has weekly team meetings to discuss in detail the specific positions held. Each morning, the team has an informal portfolio update with performance and attribution figures circulated to senior management. If any unusual performance is detected, it will be investigated. The independent risk management team monitors all portfolios on a daily basis to ensure the portfolios are managed within their stated guidelines. MIMGL provides regular reports to clients in MFIC portfolios, at least each quarter but usually each month. The reports include a review of the market and the performance of the account compared to the stated benchmark. Additional reports are provided as requested. please register to get more info

A. Other Compensation MIMGL does not receive any economic benefit from anyone who is not a client in relation to the provision of investment advisory services to its clients.

B. Compensation for Client Referrals From time to time, MIMGL may pay fees for client referrals as permitted by Section 206(4)-3 of the Advisers Act. These fees typically involve the payment of a portion of the asset-based investment management fee and/or performance fee paid to MIMGL by the client. Other related party investment advisers may similarly compensate persons for clients referred to them. MIMGL does not receive such compensation. An affiliate of MIMGL, Macquarie Group Services Limited (‘MGSL’), leverages the purchasing demand of the Macquarie Group and its portfolio businesses to negotiate agreements with unaffiliated vendors such as insurance companies, employee benefit companies and office supply companies. The terms of these agreements aim to provide better pricing and service levels than each portfolio business could typically obtain on its own. Management, of each of the portfolio businesses, evaluate each vendor offer based on its own merits relative to other options in the marketplace and makes its own decision as to whether to participate. When a company participates, MGSL may, subject to certain conditions, be able to receive a Form ADV Part 2A Page 15 commission or rebate from the vendor. Such rebates are typically calculated as a percentage of company spendings (typically 2% to 5%, depending on vendor, product and whether the company entering into the contract is a new or existing customer). please register to get more info

MIMGL does not currently maintain custody of any client assets. please register to get more info

Generally, MIMGL is retained on a discretionary basis and authorized to make the determinations in accordance with clients’ specified investment objectives without client consultation or consent before a transaction is effected.

Before assuming discretionary authority, MIMGL requires a client to enter into a written investment management agreement with MIMGL. Any limitations on MIMGL’s discretion in the case of a particular client will be agreed in advance and set forth in the investment management agreement between MIMGL and such client. For registered investment companies, MIMGL’s authority to trade may also be limited by certain federal securities and tax laws.

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MIMGL has adopted proxy voting policies and procedures contained in its Proxy Voting Policy (the "Policy") to address how MIMGL will vote proxies, if applicable, for its clients. The Policy seeks to ensure that, if applicable, MIMGL votes proxies (or similar instruments) in the best interest of its clients, including when there may be material conflicts of interest in voting proxies. For this purpose, “best interest” means in the best economic interest of each client or account and its shareholders, as investors, without regard to any self-interest which MIMGL, its management or affiliates might have in a particular voting matter or any interest which its clients’ shareholders may have other than their economic interest, in common, as investors.

Clients may obtain a copy of MIMGL’s Proxy Voting Policy, or, if applicable, information regarding how MIMGL voted proxies, upon request.

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A. Financial Conditions MIMGL does not have custody of client portfolios or securities, nor does it permit prepayment of fees. MIMGL is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitment to its clients. B. Bankruptcy MIMGL has never been the subject of a bankruptcy petition. please register to get more info