Our Firm Pinnacle Investment Management Limited (“Pinnacle”, “we” or the “Firm”) is a company
limited by shares incorporated in Australia on 22 June 2006.
Pinnacle is a multi-affiliate investment management firm – which encompasses an umbrella of
specialist funds management investment manager firms. Pinnacle’s mission is to establish,
grow and maintain a diverse stable of world-class investment managers and Pinnacle currently
maintains relationships with the following 13 autonomous Advisory Affiliates:
Antipodes Partner Limited (Antipodes): 23.57% ownership
Curve Investment Management Pty Limited (Curve): 25% ownership
Firetrail Investments Pty Limited (Firetrail): 23.5% ownership
Hyperion Asset Management Limited (Hyperion): 49.99% ownership
Longwave Capital Partners Pty Limited (Longwave): 40% ownership
Metrics Credit Partners Pty Ltd (Metrics): 35% ownership
Omega Global Investors Pty Ltd (Omega): 40% ownership
Palisade Investment Partners Limited (Palisade): 36% ownership
Plato Investment Management Limited (Plato): 43.1% ownership
Resolution Capital Limited (Resolution Capital): 43.50% ownership
Solaris Investment Management Limited (Solaris): 40% ownership
Spheria Asset Management Limited (Spheria): 40% ownership
Two Trees Investment Management Pty Limited (Two Trees): 43.96% ownership
Riparian Capital Partners Pty Limited (Riparian): 40% ownership
Pinnacle provides its Advisory Affiliates with a variety of services, including the following:
1. equity, seed capital and working capital;
2. superior distribution services, business support and responsible entity services to allow
fund managers to focus on delivering fund outperformance; and
3. independence, including separate management reporting structures and boards of
directors, whilst still offering the economies of scale and financial support inherent in
being part of a larger investment group.
Amongst the above Advisory Affiliates, Antipodes, Omega, Palisade and Two Trees are
Exempt Reporting Advisers with the U.S. Securities and Exchange Commission. Hyperion and
Resolution Capital are Registered Investment Advisers with the SEC. All other Advisory
Affiliates are exempted from registration under the Investment Advisers Act of 1940.
Principal Owners Pinnacle is 100% owned by Pinnacle Investment Management Group Limited, which is a public
reporting company registered on the Australian Securities Exchange (ASX: PNI). Pinnacle is
headquartered in Sydney, Australia and has domestic offices in Brisbane, Melbourne as well as
an international office in London, United Kingdom.
Types of Services Offered Pinnacle provides its Advisory Affiliates Distribution Services (including product distribution,
marketing and business development) to source clients for each Advisory Affiliate as well as
Investment Infrastructure (including business management, licencing and insurance,
compliance and risk, company secretarial and legal counsel, financial reporting and accounting,
human resources, information technology, operations and operational support, middle office
functions, and responsible entity services) in order to support each Advisory Affiliate in
delivering on its respective investment management services to their clients.
As of 30th June 2019, Pinnacle and its Advisory Affiliates managed approximately
US$38,053,519,163 of regulatory assets under management on a discretionary basis and no
regulatory assets under management on a non-discretionary basis.
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Pinnacle provides administrative services to Advisory Affiliates in accordance with service
agreements between subsidiary and/or Advisory Affiliated companies. The services include but
are not limited to business management, licencing and insurance, compliance and risk, company
secretarial and legal counsel, financial reporting and accounting, human resources, information
technology, operations and operational support, middle office functions, and responsible entity
services. These fees are paid by the Advisory Affiliate and not any Fund.
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Pinnacle’s Advisory Affiliates are charged performance fees in compliance with Rule 205-3 of
the Investment Advisers Act of 1940. Any such performance fees will be negotiated on an
individual basis with the affiliate. Pinnacle has policies and procedures designed and
implemented to ensure that all clients are treated fairly and to prevent this conflict from
influencing the allocation of investment opportunities among affiliates.
Pinnacle generally charges fees based on assets under management but may, in consultation
with the applicable affiliate, enter into performance-based fee arrangements that allow for it to
receive fees that are based in whole or in part on agreed upon measures of account performance.
A Pinnacle Advisory Affiliate client is charged an investment advisory fee directly by the
Pinnacle Advisory Affiliate with which it contracts.
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Pinnacle Advisory Affiliates and Non-US Investment Pool Clients
Pinnacle provides distribution and administrative services to the Pinnacle Advisory Affiliates,
which are U.S. exempt reporting advisers. Pinnacle’s subsidiaries (Pinnacle Fund Services
Limited and Pinnacle RE Services Limited) are the issuers of non-U.S. investment pools, in the
form of managed investment schemes issued under the relevant provisions of the Australian
Corporations Act 2001, to which the Pinnacle Advisory Affiliates are appointed as investment
manager.
Account Minimums
The minimum account size for each investment strategy that is available through Pinnacle
Advisory Affiliates is established by the applicable Pinnacle Advisory Affiliate. Account
minimums may be waived to reflect existing relationships, anticipated client additions to assets
under management, changing market conditions, client servicing requirements, or for other
reasons. Any waivers of account minimums are done in consultation with the applicable
Pinnacle Advisory Affiliate.
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Investment ObjectivePinnacle’s Advisory Affiliates have autonomy over their investment strategies and portfolio
decisions. Each Advisory Affiliate has common infrastructure support comprising operations,
compliance, sales, marketing, client service, and overall business management. Overall, these
investment franchises manage domestic and international equities, derivatives, infrastructure
and fixed income strategies.
Below is a summary of the investment strategies and methodologies used by each Advisory
Affiliate of Pinnacle.
AntipodesAntipodes is a global asset manager offering a pragmatic value approach across long only and
long-short strategies. It aspires to grow client wealth over the long-term by generating absolute
returns in excess of the benchmark at below market levels of risk. Antipodes seeks to take
advantage of the market’s tendency for irrational extrapolation, identify investments that offer
a high margin of safety and build high conviction portfolios with a capital preservation focus.
Antipodes is majority owned by its seasoned investment team and its performance culture is
underpinned by sensible incentives, a focused offering and the outsourcing of non-investment
functions to maximise focus on investing.
Curve Curve provides investors with a nimble discretionary macro exposure, allowing investors to
gain exposure to interest rates, foreign exchange and major equity index markets, along with
an Asian macro geographic focus.
FiretrailFiretrail is an active investment manager, specialising in high conviction equities investing.
Firetrail employs a fundamental investment approach to the fund’s portfolio to identify
companies that it believes are undervalued over the medium term. The investment style is
unconstrained, which means Firetrail will invest in both ‘growth’ and ‘value’ companies, as
well as across diverse industries and sectors. Firetrail employs a bottom-up approach to
portfolio construction. Risk management is integrated throughout the process to understand and
control stock specific, macroeconomic and market risk in the fund.
HyperionHyperion is a high conviction growth style manager that specialises in identifying and investing
in quality Australian equities. Hyperion’s proprietary investment process produces a relatively
concentrated portfolio of high-quality companies with predictable earnings and superior growth
potential. Hyperion’s strategy uses rigorous and in-depth quantitative and qualitative analysis
to establish a unique portfolio.
Longwave Longwave believes in the value of deep fundamental understanding of the securities in which
they invest. They also believe that the discipline of a quantitative approach allows the testing
and evolution of their investment process and guards against behavioural biases which may
otherwise negatively impact investment performance.
MetricsMetrics is an active participant in the market, involved in a broad range of inter-bank lending
transactions, including through our various managed funds. Because lending is their lifeblood,
they’re passionate about working with borrowers and investors to help them achieve their goals.
Metrics believes that the corporate loan market represents a large and active segment of
Australia’s corporate fixed income market and provides superior risk-adjusted returns
compared with other fixed income investments.
OmegaOmega is a specialist investment manager, offering outcome-oriented investment solutions to
investors. Established in 2008, Omega is a majority employee owned specialist investment
manager with a management team who have over 100 combined years of experience delivering
outcomes for investors globally. Omega’s motto is to begin with the end in mind and Omega
believes investors’ aims are best fulfilled by having portfolios that are intelligently designed
with a specific outcome or performance objective in mind. Omega believes that market
capitalisation benchmarks are in the main inefficient, and are not a true reflection of investor
needs, particularly in terms of risk control and diversification.
PalisadePalisade is a specialist independent infrastructure manager providing dedicated and
professional investment management services to the wholesale superannuation market and
other specialist investors. Palisade offers a depth of resources and a strong investment culture
focused on delivering solid performance and high standards of client service. Palisade’s
philosophy is to deliver secure long-term returns, aligned with the investors and objectives of
its investors and the community.
PlatoPlato’s investment philosophy is that markets are less than perfectly efficient, and a disciplined
systematic process can take advantage of these inefficiencies to deliver better risk adjusted
returns than the market. Plato’s investment process provides very attractive opportunities to
generate out-performance, versus an appropriate benchmark, over the longer term.
Resolution CapitalResolution Capital is a specialist investment manager that focuses on managing portfolios of
global listed Real Estate Investment Trusts (‘REITs’) and other real estate securities. Resolution
Capital is independent and majority employee owned. Resolution Capital is an active manager
and believes that the ultimate driver of returns from REITs and real estate securities is the
quality and level of sustainable cash earnings generated by the underlying real estate. As a result
Resolution Capital’s investment process is focused on evaluating these cash-flows consistently
across real estate sectors and regions. Resolution Capital believes that listed real estate provides
an excellent means of gaining exposure to the returns of some of the world’s highest quality
real estate assets.
SolarisSolaris’ investment team believes there are opportunities in both value and growth stocks.
Solaris has no consistent bias towards either value or growth stocks. Therefore, their style can
be described as ‘style neutral’ or ‘style agnostic’. Stock selection is Solaris’ main area of
expertise. Using fundamental analysis, Solaris selects stocks to exploit market inefficiencies in
forecasts and valuations. Investment decisions are supported by detailed analysis of the
securities and key financial markets with an eye on global perspectives. Solaris applies strict
risk controls to minimise the downside risk.
SpheriaSpheria is a fundamental based investment manager with a bottom-up focus, specialising in
smaller companies. Its investment philosophy is to purchase securities where the present value
of future free cash flows can be reasonably ascertained, and the security is trading at a discount
to the calculated intrinsic value, subject to certain risk criteria.
Two TreesTwo Trees is a specialist systematic global macro investment manager. Two Trees combines a
deep understanding of financial economics, quantitative techniques and risk management to
construct diversified multi-asset class portfolios seeking to deliver superior performance
relative to the benchmark.
Riparian Riparian is a specialist Water, Agriculture and Food investment firm, that was established with
the specific purpose of identifying, acquiring and managing investments across the agricultural
sector. The investment strategies that are executed on span the agricultural value chain. Water,
the critical and capped input into Australian agriculture, forms a core investment focus of
Riparian. The founding partners all have a strong affinity with agriculture, having grown up on
farms and in regional communities, studying agriculture at secondary and tertiary levels and
having worked in the industry throughout their careers. Riparian’s mission is to provide long
term, sustainable returns for all stakeholders.
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The Firm has not been subject to any disciplinary action, whether criminal, civil or
administrative (including regulatory) in any jurisdiction. Likewise, no persons involved in the
management of the Firm have been subject to such action.
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Pinnacle is licensed by the Australian Securities & Investments Commission, holding an
Australian Financial Services Licence Number (322140), authorising it to carrying on a
financial services business.
Pinnacle RE Services Limited holds Australian Securities & Investment Commission License
Number (340235), authorising it to carry on a financial services business, including issuing
interests in managed investment schemes as a Trustee.
Pinnacle Fund Services Limited holds Australian Securities & Investment Commission License
Number (238371), authorising it to carry on a financial services business, including issuing
interests in registered managed investment schemes as a Responsible Entity.
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Trading Participation or Interest in Client Transactions As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of
all material facts and to act solely in the best interest of each of our clients at all times.
Pinnacle’s fiduciary duty is the fundamental principle for the firm’s Code of Ethics, which
includes procedures for personal securities transaction and insider trading. The Firm requires
all employees to conduct business with the highest level of ethical standards and to comply with
all federal and state securities laws at all times. The Firm and its employees must conduct
business in an honest, ethical, and fair manner and avoid all circumstances that might negatively
affect or appear to affect the duty of complete loyalty to all clients
Related persons of Pinnacle may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, the Firm’s related persons
will place client interests ahead of their own interests and adhere to the Code of Ethics.
Likewise, related persons of the Firm may buy or sell securities for themselves at or around the
same time they buy or sell the same securities in client accounts. In order to minimize this
conflict of interest, the Firm’s related persons will place client interests ahead of their own
interests and strictly adhere to the established Code of Ethics. Further, related persons will
refrain from buying or selling the same securities prior to buying or selling for clients in the
same day unless included in a block trade.
Code of Ethics and Personal Account Dealing All employees, directors, contractors and consultants of Pinnacle are expected to act lawfully,
honestly, ethically and in the best interests of the Firm in the course of their daily work.
Employees are encouraged to use best judgement to ensure fair dealing and the ethical conduct.
Pinnacle seeks to establish a collaborative relationship with external stakeholders. It requires
Pinnacle Personnel to:
carry out enquiries before selecting and engaging with a third party to ensure they are
reputable and competent and do not present unacceptable reputational risks;
engage in fair dealings with third parties, act with integrity and not seek to obtain a
competitive advance through unethical practices or behave in a manner which may
damage the Firm’s reputation; and
ensure that there is no conflict of interest that would make the engagement of a
particular third party inappropriate
Pinnacle along with its Advisory Affiliates does not permit, or condone, any form of bribery or
corruption, or the payment of any form of inducement to a third party.
It does not encourage staff to give or receive gifts or hospitality that may impact their business
judgment. Pinnacle Personnel are required to record the relevant details of any gift on the
Gift Registry which is maintained by the Firm and to decline any gift where the value is greater
than the limits specified in the Firm’s Gift and Entertainment Policy. Any gift or gesture of
hospitality should be declined if it appears excessive, is inappropriate in nature or at an
inappropriate venue, or if it will result in any sense of obligation or if it will adversely affect
the reputation of the Group.
Pinnacle has established a whistleblowing and no retaliation policy.
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Pinnacle does not enter into transactions on behalf of clients. Pinnacle’s Advisory Affiliates
when entering into brokerage transactions for their clients maintain a panel of reputable brokers,
which are selected based on a variety of factors. Pinnacle’s Advisory Affiliates may receive
research and related products or services from the brokers they engage with, and each has in
place policies on conflicts of interest as well as brokerage allocation.
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Review of Accounts The Funds of each Advisory Affiliate are reviewed and reconciled on a monthly basis with
quarterly valuation and cash reports prepared by the Fund’s independent Fund Administrator.
In addition, each Advisory Affiliate also monitors the Funds performances to help ensure
conformity with investment objectives and guidelines.
The Funds’ administrator will prepare quarterly unaudited Funds valuation pack stating the
Funds’ share price for each share class or other Fund interest.
Reporting The Funds of each Advisory Affiliate are audited on an annual basis. Pinnacle’s accounts are
audited annually.
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The Firm or any related person of the Firm generally does not compensate any person in the
U.S. who is not a Pinnacle supervised person for client referrals in the U.S.
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Subject to the investment objectives, policies and restrictions of each Advisory Affiliate as set
forth in the Investment Management Agreement / Investment Advisory Agreement and
Offering Materials of such Advisory Affiliate, Pinnacle will exercise no authority to
determine the acquisition, supervision or exit of investments, to place any cash or equivalents
on deposit in or to the respective portfolios.
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Pinnacle does not vote on securities.
Pinnacle’s Advisory Affiliates may be in some instances authorized by their clients to vote on
certain securities.
Where Pinnacle is the issuer of a pooled investment vehicle managed by an Advisory Affiliate,
Pinnacle empowers the Advisory Affiliate to make all voting decisions and has no involvement
in those decisions.
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Pinnacle has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to clients and has not been the subject of a bankruptcy proceeding.
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