HNRG was formed in 1995 as an independent, wholly-owned subsidiary of John Hancock Life Insurance Company. In 2004, Manulife Financial Corporation acquired John Hancock Financial Services, Inc., making HNRG an indirect, wholly-owned subsidiary of Manulife Financial Corporation. HNRG is organized as a corporation. John Hancock Subsidiaries LLC, an indirect wholly owned subsidiary of Manulife Financial Corporation, is the sole shareholder and a direct owner of 100% of HNRG voting shares. Hancock Timber Resource Group (“HTRG”) and Hancock Agricultural Investment Group (“HAIG”) are operating divisions of HNRG. HTRG was established in 1985. HAIG was established in 1990. HNRG currently provides continuous and regular supervisory or management services with respect to real estate and private equity portfolios. This real estate consists of farmland, timberland, or both. Portfolios are managed by HNRG either on a discretionary or non-discretionary basis. HNRG also provides cash management services to certain of its real estate portfolios, usually through an affiliate. HNRG’s provision of cash management services has not, however, resulted in the creation of any "securities portfolios" as defined in Form ADV Part 1A, Instruction 5.b.(1). HNRG offers additional investment management services, including management of portfolios that include real estate-related securities. Such additional services may include managing client securities portfolios that receive continuous and regular supervisory or management services. HNRG’s investment process utilizes research models to source, analyze, acquire and dispose of assets. Property management firms are used to provide day-to-day property management services. Regional offices are used to oversee field operations to ensure that client objectives are carried out. Approximately 35% of HNRG’s total advisory billings are derived from providing investment advice within the meaning of the Investment Advisers Act of 1940. In several of these situations, HNRG has been authorized to manage short-term cash investments for the entity. While HNRG may manage a client’s real estate investments by acquiring non-security interests in real estate, it is considered to be providing investment advice as to securities when it also invests otherwise idle cash in securities such as commercial paper or money market instruments. Approximately 65% of HNRG’s total advisory billings are derived from furnishing advice to clients on matters not involving securities. Advice for compensation as to investments other than securities includes direct fee or leasehold interests in real estate. Generally, these investments involve the acquisition of fee simple title to timber or agricultural real estate through a limited partnership, limited liability company, corporation or other entity organized for that purpose. HNRG develops client portfolios with the knowledge of the circumstances, preferences and objectives of each specific client. HNRG will manage accounts in accordance with investment guidelines established by the client, or established jointly by HNRG and the client. As of December 31, 2018, HNRG managed approximately $6,657,044,624 of client assets on a discretionary basis and $7,009,132,560 on a non-discretionary basis.
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This brochure is delivered only to qualified purchasers as defined in section 2(a)(51)(A) of the Investment Company Act of 1940. SEC rules allow HNRG to omit disclosure of its fee schedule and certain related information because such information has little utility for institutional and large, sophisticated clients. The specific manner in which fees are charged by HNRG is established in a client’s written investment management agreement with HNRG. Generally, in accordance with the investment management agreement, HNRG may be authorized to deduct fees from cash flow generated by a client’s timberland and agricultural investments. Such fees may include compensation for services, reimbursement of expenses and maintenance of working capital reserves. The timing of fee payments is negotiated with each client, and fees are payable in quarterly installments in arrears. HNRG may engage an affiliate, Hancock Forest Management, Inc. ("HFM") or a third-party property management firm to provide local property management services with respect to timberland investments in the United States. HNRG may engage an affiliate, Farmland Management Services (“FMS”) or a third-party property management firm to provide local property management services with respect to farmland investments in the United States. If HFM or FMS is engaged to provide local timberland or farmland property management services, the fees charged by it will be no less favorable to the client than those charged by unaffiliated property managers. The fees and expenses of the local property manager will be negotiated on an arms' length basis and paid by the client. For commingled funds, HNRG may pay a portion of its fees to one or more placement agents, as well as to the investment advisors to certain investors. HNRG may assess a portfolio development fee in connection with certain agricultural investments. The portfolio development fee is generally paid by the client at the closing and funding of each acquisition of an agricultural investment. All assets of HNRG clients are maintained with third-party custodial institutions that are not affiliated with HNRG. Custodians negotiate certain charges and fees for their services, which are exclusive of and in addition to HNRG fees. please register to get more info

In some cases, HNRG may enter into incentive fee arrangements with clients. Such fees are subject to negotiation with each client and established in a client’s written agreement with HNRG. The incentive fee is only received if a portfolio’s return is above a predetermined hurdle rate based on portfolio performance expectations. The incentive fee is designed to align the financial interests of the client and the investment adviser. HNRG and the client determine a portfolio’s hurdle rate based on return expectations. In connection with the acquisition of timberland or farmland, or in the securities of an underlying investment in timberland or farmland, HNRG has an asset allocation policy and procedures designed and implemented to ensure that all clients are treated fairly and equally. Timberland and farmland and are illiquid investments and the existence of an incentive fee among clients does not influence the allocation of investment opportunities among clients. please register to get more info

HNRG currently provides continuous and regular supervisory or management services with respect to real estate portfolios to private equity investors consisting of pension plans, corporations, insurance companies, foundations, endowments and family offices. HNRG generally requires a $100,000,000.00 minimum investment for individually managed timberland portfolios and $100,000,000.00 minimum for farmland portfolios. However, minimum investment requirements may be lower for investments in pooled investment vehicles. The minimum investment for pooled vehicles is specific to each individual deal. HNRG reserves the right to reduce the minimum investment amount. please register to get more info

Investing in real estate and real estate related securities involves the risk of loss that clients should be prepared to bear. HNRG’s analysis is actually asset analysis. However, the same basic techniques would be used to analyze any securities on which HNRG may advise investors in the future. These securities would be issued by vehicles, such as limited partnerships or limited liability companies, used to hold timberland and farmland acquired by HNRG on behalf of investors.

Timberland: HNRG uses a proprietary timber investment model to value all of the acquisitions, with the goal of ensuring accurate analysis and consistent, comparable results across acquisitions. HNRG seeks out timberland acquisitions where the competition is apt to be less, so pricing is more likely to be favorable for investors. To implement this strategy, HNRG tries to avoid auctions in favor of negotiated transactions, in order to find complex transactions in which smaller or less sophisticated investment managers are unable to participate, and to purchase large properties that typically attract fewer buyers. To identify investment opportunities, HNRG regularly networks with major landowners. HNRG’s research team generates timber price forecasts and rate of return assessments based on the state of the markets that are used in acquisition decisions and in hold-sell analysis. These “top-down” estimates of rates of return are calibrated against “bottom-up” estimates derived from actual timberland investments (e.g., large-property discounts, relative value of timberland in public and private markets) for incorporation into investment strategies and analysis. HNRG’s timber strategy focuses on acquiring large blocks of high quality timberland at favorable prices for the long-term, adding value through management skills, and selling to take advantage of market opportunities. Geographic diversification of investor portfolios is an instrumental part of the investment strategy. Broad geographic diversification is the best possible protection against the biophysical risks, regional market risk and price fluctuations associated with timberland investments. HNRG also diversifies by age, class, tree species and end product. Farmland: A quantitative approach enables portfolios to be developed with the goal of maximizing total return at each client’s allowable risk level. Research focuses on both macroeconomic and microeconomic issues, considering factors such as long-term farm sector supply and demand projections by crop type and the potential impact of trade agreement implementation on imports and exports. HNRG has developed and implemented a farmland investment strategy based on research and investment fundamentals. A top-down, bottom-up approach comprised of three steps is followed: Step 1: Identify those commodities with favorable long-term demand and supply outlooks and then the countries that can produce those crops competitively. Step 2: Identify the low-cost production regions in each country for those crop types identified in Step 1. Step 3: Identify properties in the low-cost production regions that have the highest expected risk-adjusted returns. This is the bottom-up part of the strategy. This process is completed in conjunction with the relevant local property management group. Individual property analysis includes factors such as soil types, water supply, proximity to markets, agricultural infrastructure, vine and/or tree variety and health. These factors influence the projected internal rate of return prepared for each proposed farmland acquisition. HNRG’s farmland investment strategy focuses on acquiring and managing properties for clients on a long-term basis. Geographic and crop diversification of client portfolios is an instrumental part of the farmland investment strategy. A proper diversification strategy greatly reduces the risk associated with farmland investing. Given the transaction cost associated with farmland assets, short-term strategies are not prudent for farmland investments. The sources of information used in HNRG’s timberland and farmland investment approach primarily emanate from business, financial, academic and government communities. HNRG uses financial newspapers and magazines, research materials prepared by others and Annual reports, prospectuses and filings with the SEC as sources of information. In addition, HNRG utilizes other sources of information such as industry, trade associations, academic publications, and material provided by state and federal government agencies and departments. HNRG integrates these inputs into its analysis of potential investment opportunities, current investment holdings, the strength of its trading partners and the investment environment.
General Timberland Risks:
Forest Product Prices
Prices of traditional forest products can be expected to fluctuate. The demand for one or more commodities is affected by numerous factors, including weather conditions, quality of commodity, and supply and demand for such commodity in domestic and in one or more international markets.
Weather; Natural Disasters
Forests are subject to damage from fire, flood, frost, drought, insects, disease, and storms. Productivity may be lost as a result of adverse weather conditions such as drought. Consistent with industry practice in the jurisdiction of a particular timberland investment, HNRG may or may not maintain insurance against such risks. HNRG will attempt to manage these risks through the geographic dispersion of the properties in which it invests and the diversity of age class and tree species raised.
Environmental Protection
HNRG intends to implement a variety of sustainable management practices designed to conserve resources and avoid environmental damage. HNRG intends to have all timberland meet or exceed all relevant regulations relating to the protection of the environment and to manage the timberland in a manner which will permit independent certification as to conformity with regionally recognized certification standards which may include the Sustainable Forestry Initiative (SFI)®, Forest Stewardship Council (FSC), Australian Forest Certification and Programme for the Endorsement of Forest Certification schemes (PEFC). However, regulations and standards may change, which may require additional capital expenditure or increased operating expenses.
Potential Environmental Liability
In addition to laws which regulate forestry operations and environmental protection, owners and operators of real estate may have liability for the clean-up and remediation of contaminated land and waters (including groundwater) found to pose a threat to human health or the environment. HNRG will seek to understand and quantify the risk of such potential liability through environmental site assessments (Phase I and, if necessary, Phase II), but there is no assurance that it will be successful in assessing and avoiding any such liability.
Competition
The markets for timber are predominantly global in nature and very competitive. The competition is based on both price and quality differentials as compared to other producers.
Foreign Investment Risks
If the client’s investment guidelines allow HNRG to acquire timberland investments where the timberland is located outside of the United States, these investments are subject to the following additional risks, among others:
Political and Economic Factors
The economies of particular foreign countries may differ favorably or unfavorably from the U.S. economy in such respects as growth of gross national product, rate of inflation, capital reinvestment, resource self- sufficiency and balance of payments position. Governments in certain of the foreign countries in which HNRG may invest participate to a significant degree, through ownership interests or regulation, in their respective economies. Action by these governments could have a significant effect on market prices of timberland investments in such countries. With respect to certain foreign countries, there is the possibility of nationalization, expropriation, confiscatory taxation, political changes, government regulation, social instability or diplomatic developments that could affect adversely the economy of such country or the timberland investments in such country.
Investment and Repatriation Restrictions
Investments in real estate located in foreign countries is restricted or controlled in varying degrees. These restrictions may limit, and at times preclude, investment in these foreign countries and may increase costs and expenses. In addition, the repatriation of both investment income and capital from certain foreign countries is restricted and controlled under certain regulations, requiring in some cases the need for governmental consents.
Currency Fluctuations
HNRG will generally value its timberland investments in U.S. dollars. To the extent unhedged, the value of non-U.S. dollar investments will fluctuate with U.S. dollar exchange rates as well as the asset value changes of such non-U.S. timberland investments in local markets. Thus, an increase in the value of the U.S. dollar compared to the currencies of other countries in which HNRG has made timberland investments will reduce the effect of increases, and magnify the U.S. dollar equivalent of the effect of decreases, in the values of the timberland investments in their local markets. Conversely, a decrease in the value of the U.S. dollar will have the opposite effect on non-U.S. dollar timberland investments


General Farmland Risks:
Crop and Commodity Prices
Crop and commodity prices can be expected to fluctuate. The demand for one or more commodities is affected by numerous factors, including weather conditions, quality of commodity, supply and demand for such commodity in the United States and in one or more international markets, relative strength of local currency, government farm programs and policies, demand from the biofuels industry, price volatility as a result of increased participation by non-commercial market participants in commodity markets and changes in global demand resulting from population growth and changes in standards of living. In addition, an increase in raw material prices, such as fertilizer, may have an adverse effect on the operations of the tenants of HNRG subsidiaries and their ability to pay rent.

Weather; Natural Disasters
Farmland is subject to damage from fire, flood, frost, drought, insects, disease, storm damage and poor pollination. Productivity may be lost as a result of adverse weather conditions such as drought or excessive heat or cold. Consistent with industry practice, tenants will not be required to carry crop insurance, and HNRG will determine if insurance on directly operated crops is warranted.
Competition in Agricultural Products Markets
The markets for agricultural products to be grown on the farmland investments of clients are predominantly global in nature and very competitive. The competition is based on both price and quality differentials as compared to other growers, both in the United States and internationally.
Government Regulation
Agricultural production is significantly affected by government policies and regulations. Governmental policies affecting the agricultural industry, such as taxes, tariffs, duties, subsidies and import and export restrictions on agricultural commodities and commodity products, as well as current or potential climate change regulations, can influence industry profitability, the planting of certain crops versus other uses of agricultural resources, the location and size of crop production, whether unprocessed or processed commodity products are traded and the volume and types of imports and exports. In addition, international trade disputes can adversely affect agricultural commodity trade flows by limiting or disrupting trade between countries or regions. Future government policies may adversely affect the supply, demand for and prices of crops and commodities, may restrict the ability of the tenants to do business in their respective target markets and could cause the financial results of the client to suffer.

Timberland and farmland are illiquid investments, and HNRG investors should anticipate a minimum holding period of 7 to 10 years.











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Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of HNRG or the integrity of HNRG management. From time to time, in connection with managing an approximate $14 billion portfolio, HNRG, its subsidiaries and the investment vehicles it manages, are named as a party in various property specific actions related to timberland and agricultural ownership and operations, including slip and fall, personal injury, easement or title claims, eminent domain, trespass or the like.

Farmland Management Services Inc., HNRG’s wholly owned agricultural property manager, and a client investment vehicle, with the approval of the client, reached settlement with the United States in the form of a Consent Decree. The matter is a property related civil enforcement action by the United States Department of Justice alleging a Clean Water Act violation with regard to certain property alleging a wetlands violation.

As part of the process, the Court must review the Consent Decree and may hold a hearing if it requires questions to be answered, and then make a finding that the Consent Decree is consistent with the purposes and parameters of the Clean Water Act. An unopposed motion to approve the Consent Decree was filed by the United States and is pending final approval by the Court.

No other material matters or potential material matters are ongoing.

This response is limited to HNRG, and its subsidiaries and investment vehicles it manages, and it does not include HNRG’s ultimate parent, Manulife Financial Corporation and its subsidiaries. Manulife Financial Corporation is a public company, the shares of which are listed on the Toronto and New York Stock exchanges. please register to get more info

HNRG has arrangements that are material to its advisory business or its clients with various affiliates and “related persons” (which term includes officers, directors, employees, and persons controlling, controlled by or under common control with HNRG), including broker-dealers, investment companies and other pooled investment vehicles, investment advisers and insurance companies. These affiliates are located both within and outside the United States.

Key affiliates are as follows:

John Hancock Life Insurance Company (U.S.A.) US Insurance Company The Manufacturers Life Insurance Company Non-US Insurance Company John Hancock Distributors LLC US Broker-Dealer Manulife Asset Management (US) LLC US Investment Adviser Manulife Asset Management (North America) Limited US Investment Adviser Manulife Asset Management Investments Inc. Non-US Broker-Dealer Manulife Asset Management (Hong Kong) Limited Non-US Investment Adviser Manulife Asset Management (Europe) Limited Non-US Investment Adviser Manulife Asset Management (Japan) Limited Non-US Investment Adviser Manulife Asset Management (Singapore) Pte., Limited Non-US Investment Adviser

HNRG and John Hancock Distributors LLC (“JHD”) have entered into a Placement Agency Agreement. Some employees of HNRG are registered representatives of John Hancock Distributors LLC, and in this capacity may offer and sell to investors interests in funds managed by HNRG. Sales personnel of Manulife Asset Management (US) LLC are also registered representatives of JHD and may offer and sell to investors interests in funds managed by HNRG. Interests are offered to certain qualified institutional investors through JHD by confidential private placement memorandum. HNRG employees are not compensated by John Hancock Distributors LLC.

HNRG may serve as the general partner of a pooled investment vehicle organized as a limited partnership, or as a manager of such a pooled investment vehicle organized as a limited liability company. Such pooled investment vehicles may invest directly or indirectly in commercial timberland and agricultural properties including fee ownership and leasehold interests in timberlands and agriculture. Clients may have invested in certain of these limited partnerships and limited liability companies, but not as a result of solicitation efforts by HNRG.

HNRG provides cash management services to certain of its real estate portfolios through Manulife Asset Management (U.S) LLC.

HNRG manages fixed income assets owned by various other direct or indirect wholly-owned subsidiaries of Manulife Financial Corporation, including John Hancock Life Insurance Company (U.S.A.) (General Account and insurance separate accounts) and Manufacturers Life Insurance Company. Manufacturers Life Insurance Company and John Hancock Life Insurance Company (U.S.A.) may be significant investors in funds managed by HNRG. All investment management arrangements with related persons are conducted on an arms length basis so as to neither advantage nor disadvantage HNRG’s other clients or the above-mentioned related persons. For contractual, regulatory and other business reasons, the Investment Division of Manulife Financial Corporation maintains an information barrier between Manulife Asset Management Public Markets and Manulife Asset Management Private Markets (including HNRG) and the General Account. The establishment and enforcement of these information barriers ensures that investment proxy voting and investment powers entrusted to one business unit are exercised without inappropriate influence, that sensitive information is not improperly transferred from one business unit to another in violation of a contractual or fiduciary duty, and that certain sensitive information in the possession of one business unit is not unnecessarily imputed to another business unit. The HNRG Information Barrier Protocol (“Protocol”) was established to grant a limited communication exception between certain HNRG persons and certain MAM Public Markets persons, including compliance controls to ensure the overall integrity of the established information barrier. HNRG and its affiliates may have common directors and common officers and may share certain administrative and/or back office functions.

Neither HNRG nor a related person has any arrangements where it is paid cash by or receives some economic benefit from a non-client in connection with giving advice to clients.






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HNRG has adopted a Code of Ethics (“HNRG Code”) in accordance with rule 204A-1 under the Investment Advisers Act of 1940 that regulates the personal securities trading activities of investment personnel and other supervised persons. HNRG has also adopted the Manulife Code of Business Conduct and Ethics (“MFC Code”), which includes general standards of ethical conduct for all directors, officers and employees of HNRG. The HNRG Code and MFC Code are available to any client or prospective client upon request. The HNRG Code applies to all directors, officers and employees or HNRG and governs the conduct of any personal investment transaction. HNRG seeks to prevent the misuse of, or avoid any appearance of impropriety regarding material, non-public information by restricting the ability of its directors, officers and employees from trading securities of entities with which HNRG is engaged in a purchase or sale transaction or reasonably expects to engage in such a transaction. The HNRG Code provides that Access Persons and members of their households must report their personal holdings of, and transactions in, covered securities, including mutual funds managed by an investment adviser affiliate of HNRG. HNRG requires all Access Persons to file Individual Securities Transactions Reports within 10 days of being designated an Access Person and on a quarterly and annual basis thereafter. The HNRG Code is designed to ensure that the personal securities transactions, activities and interests of the employees of HNRG will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. HNRG or a related person may buy or sell, for client accounts, securities or investments in which HNRG or a related person has a financial interest. In addition, in satisfaction of client coinvestment requirements or its own corporate investment objectives, HNRG or a related person may buy or sell for itself or for an affiliated account, investments that it also recommends to its clients or purchases for client accounts. HNRG or a related person may also serve as a general partner in certain pooled investment vehicles and may hold directly or indirectly ownership interests in such funds as a general partner or otherwise. Accordingly, HNRG or a related person may receive a portion of the income and gains realized on such investment. Under the HNRG Code, there is a ban on transactions in securities of companies with whom it is actively dealing in a transaction or is reasonably expected to engage in a transaction or about whom HNRG may have material nonpublic information. Conversely, certain securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of HNRG clients. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the HNRG Code to reasonably prevent conflicts of interest between HNRG and its clients. please register to get more info

Registered investment advisers are required to describe the factors that it considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation. HNRG has no information applicable to this item.

Affiliated broker-dealers (see Item 10) act only as placement agents for the sale of securities of which HNRG is the sponsor and do not hold accounts of clients of HNRG.

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HNRG typically reviews each account at annual meetings with the client, its consultant, or both. Additional reviews may be conducted when requested by a client or when there is a change in economic outlook which warrants an interim review. Internal reviews of particular accounts are performed by the division of HNRG responsible for managing particular client accounts. For each internal review, appropriate personnel of HNRG monitor or assess an account’s various attributes, including its portfolio guidelines, asset values, performance, portfolio structure and holdings. Approximately 2 to 4 individuals participate in an account’s review. Portfolio managers are generally responsible for accounts and are supported by analysts as appropriate. Client meetings generally cover the same material as internal reviews. In addition, HNRG may provide supplementary information during a client meeting. This supplementary information may include such topics as relevant organizational or personnel changes concerning HNRG, information concerning aggregate assets under management of HNRG or HNRG investment strategies. HNRG provides financial reports to clients generally on a quarterly and annual basis. In addition to traditional financial statements, the reports include financial highlights for the given period. Additional reports and materials may be provided depending on arrangements with each client. please register to get more info

It is HNRG’s policy not to enter into third party solicitation agreements except in accordance with Section 206(4)-3 of the Advisers Act. The HNRG Compliance Department must pre-approve any solicitation arrangements or agreements. Solicitation agreements may only be signed by the Chief Executive Officer, Director of Business Development and Chief Compliance Officer or in their absence, their designee. The HNRG Compliance Department is responsible for maintaining copies of all third-party solicitation agreements and for periodically monitoring the compliance of third party solicitation agreements. please register to get more info

Neither HNRG, nor any related person acts as the qualified custodian of client assets. However, HNRG is deemed to have custody when HNRG is the general partner of a pooled investment vehicle organized as a limited partnership, or when HNRG is the managing member of a pooled investment vehicle organized as a limited liability company. HNRG may also have the authorization to direct the payment of fees from client assets maintained with a custodian (see Item 5).

With respect to an account of a limited partnership, limited liability company, or another type of pooled investment vehicle, HNRG may comply with custody requirements by delivering audited financial statements of the pooled investment vehicle to investors. For each of these clients, an annual audit of the pooled investment vehicle is conducted by an accountant registered with and subject to inspection by the Public Company Accounting Oversight Board. The annual audited financial statements are prepared in accordance with the U.S generally accepted accounting principles and delivered to investors within 120 days of the fiscal year end. Such clients are exempt from the requirement to have a qualified custodian distribute periodic account statements because the investment vehicle is audited annually as described above. HNRG will deliver unaudited financial statements to clients on a quarterly basis.

In the case of non-pooled investment vehicles, clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets.

HNRG urges its clients to carefully review such statements and compare such official custodial records to the account statements that HNRG may provide to you. HNRG’s statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. please register to get more info

HNRG typically receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of real estate securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account and the parameters for investment and authority for HNRG is set forth in the particular agreement. When selecting securities and determining amounts, HNRG observes the investment policies, limitations and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to HNRG in writing. HNRG is committed to putting the interests of its advisory clients first and seeks to act in a manner consistent with applicable laws and its fiduciary and contractual obligations to its clients. At times, HNRG may determine in an exercise of its discretion, to limit or refrain from entering into certain transactions for some or all clients in order to seek to avoid a potential conflict of interest with an affiliate and or advisory clients, or where the legal, regulatory, administrative or other costs associated with entering into the transaction are deemed by HNRG to outweigh the expected benefits. Further, certain regulatory and legal restrictions or limitations and internal HNRG and Manulife policies may restrict certain investment activities of HNRG on behalf of its clients. For example, HNRG’s investment activities with respect to certain securities, issuers, regulated industries and non-U.S. markets may be restricted where applicable laws or regulations impose limits or burdens with respect to exceeding certain investment thresholds when aggregated with its affiliates or other advisory accounts. HNRG may also be precluded from pursuing transactions involving a public company if certain Manulife affiliated entities have restricted trading in that company. Additionally, HNRG adheres to Manulife’s policies that would generally prohibit certain investments made in issuers which might be deemed to present undue environmental, social or governance risks that may otherwise meet a client’s account investment criteria. Where not prohibited under applicable law or not possible because of a portfolio co-investment requirement, the client can seek to direct HNRG to include in its account such securities that would otherwise be restricted under these policies. please register to get more info

As a natural resource asset manager with relatively small amounts of equity securities in its managed accounts, HNRG rarely if ever will be called upon to vote equity securities on behalf of any of its managed accounts. If and when HNRG does vote equity securities, it will likely be in connection with a related timberland or farmland investment. HNRG would follow its proxy voting policy in carrying out its responsibilities to that client. Since, in general, the proxy voting required of HNRG will arise in connection with a related timberland or farmland investment and the individual circumstances of subject companies, HNRG typically will not know in advance how it will vote. For routine matters HNRG would expect to vote in accordance with the position of the subject company’s management. For all other matters, HNRG would decide how to vote on a case-by-case basis considering the relevant circumstances of the subject company.

Clients may obtain a copy of HNRG’s complete proxy voting policies and procedures upon request. Clients may also obtain information from HNRG about how HNRG voted any proxies on behalf of their account(s).
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Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about HNRG’s financial condition. HNRG 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. please register to get more info