4.1 General Description of Advisory Firm This brochure relates to the investment advisory services offered by Tactical Global Management Limited (“TGML” or the
“Advisor”). TGML is a specialist manager in the areas of currency, rebalancing overlay management and global macro.
TGM is regulated in Australia by the Australian Securities and Investments Commission.
TGML’s principal owners are as follows:
Dr Peter Higgs; and
Mr Stephen Goode.
4.2 Description of Advisory Services TGM offers a range of beta management services including rebalancing and currency overlays and balance sheet management
services. The objective of these is to assist clients in the management of their underlying assets and associated cashflows
relative to their strategic benchmark.
TGM is also a leader in the application of global economic and financial market modelling to generate risk adjusted (“alpha”)
returns for clients.
4.3 Availability of Customised Services for Individual Clients Services for clients are in accordance with mutually agreed upon written investment guidelines and provides continuous
supervision of client portfolios. Investment services may be tailored for each client’s specific needs and objectives, and clients
may impose reasonable restrictions on investing in certain types of securities or types of securities. TGML has established
procedures and controls to help ensure compliance with each client’s specific investment guidelines.
4.4 Assets under Management As of February 28, 2019, TGML manages, on a discretionary basis, US$27bn.
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5.1 Advisory Fees and Compensation The Advisor’s fee schedule will vary depending on the type of account and investment strategy and is subject to negotiation with
each client. Typically, the Advisor’s annual investment advisory service fee is calculated as a percentage of the market value of
the assets it manages.
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6.1 Performance-Based Fees Certain types of clients are charged an incentive or performance based fee. Generally, these performance based fees are
calculated on the appreciation of a client’s assets. As part of the initial acceptance process, clients will work with TGML to
determine the fee structure that best suits their needs.
6.2 Side-by-Side Management and Conflicts of Interest This item is not applicable to the Advisor.
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The Advisor primarily provides investment advisor services to institutional and wholesale clients including:
Corporations
Charitable organisations
Insurance companies
Pension funds
Banking institutions
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8.1 Methods of Analysis and Investment Strategies The Advisor utilises different methods of analysis that are tailored for each of the investment strategies it offers its clients.
8.2 Material Risks relating to Investment Strategies The investment strategies utilised by the Advisor depend on the requirements of the client and the investment guidelines
associated with the client’s account. Each strategy is subject to material risks. An account may not achieve its objective of the
Advisor’s expectations regarding particular securities or markets are not met.
The Advisor will disclose the risk factors for a particular strategy to a client.
Set forth below are some of the material risk factors that are often associated with the investment strategies and types of
investments relevant to many of the Advisor’s clients:
8.2.1 General Market Risk Market risk represents the risk of adverse movements in an asset market (including asset prices, volatility, changes in yield curve,
implied option volatility or other market variables) for the derivatives or the underlying asset, reference rate or index to which the
derivative relates.
8.2.2 Derivatives Risk Derivatives, including forward foreign exchange contracts, futures, options and commodity-linked derivatives and swaps, may be
riskier than other types of investmnets because they may be more sensitive to changes in economic and market conditions, and
could result in losses that significantly exceed the Fund’s original investment. Derivatives also expose the Fund to counterparty
risk (the risk that the derivative counterparty will not fulfil its contractual obligations), including the credit risk of the derivative
counterparty. Derivatives may not perform as expected, so the Fund may not realise the intended benefits. When used for
hedging, the change in value of a derivative may not correlate as expected with the security being hedged. In addition, given
their complexity, derivatives expose the Fund to risks of mispricing or improper valuation.
8.2.3 Liquidity Risk Liquidity risk exists when a particular position cannot be unwound or the risk that the fund or portfolio will not be able to meet its
obligations resulting from its derivatives activities.
8.2.4 Currency Risk Currency risk is the risk that foreign currency denominated assets will lose value due to the effect of an adverse exchange rate
movement.
8.2.5 Operational Risk Operations risk is the risk that deficiencies in the effectiveness and accuracy of the information systems or internal controls will
result in a material loss. This risk is associated with human error system failures, and inadequate procedures and internal
management controls.
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9.1 Criminal or Civil Proceedings The Advisor has no material civil or criminal actions to report.
9.2 Administrative Proceedings Before Regulatory Authorities The Advisor has no material administrative proceedings before regulatory authorities to report.
9.3 Self-Regulatory Organisation (“SRO”) Proceedings The Advisor has no SRO disciplinary proceedings to report.
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11.1 Code of Ethics TGML has in place a Code of Ethical Conduct pursuant to Rule 204A-1 under the Advisors Act. The Code of Ethical Conduct is
designed to ensure that TGML employees comply with applicable laws and place the interests of clients first.
Additionally, all TGML employees are subject to the Personal Dealing Policy which imposes certain restrictions on securities
transactions in the personal accounts of employees to help avoid conflicts of interest.
11.2 Securities in which the Adviser or a Related Person has a Material Financial Interest The Advisor does not take principal positions nor does it allow any related person to take a position in securities that would
present a material financial interest.
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12.1 Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions The Advisor selects brokers for the execution of transactions for client accounts in accordance with its best execution policies and
procedures. The list of brokers available for execution of transactions are pre-agreed with the client. In making a decision about
best execution, the Advisor considers a number of factors including, but not limited to, the:
The price at which the Order could be executed;
The costs that will be payable by the Client as a result of the execution of the Order;
The size and nature of the Order;
The speed of execution and settlement of the Order;
The likelihood that the Order will be executed and settled;
Financial status, responsibility and solvency of the counterparty;
Responsiveness of the counterparty;
The quality and efficiency of the settlement process post execution; and
Any other consideration that is relevant to the execution of the Order.
12.1.1 Research and Other Soft Dollar Benefits The Advisor’s primary objective in broker-dealer selection is to comply with its duty to obtain best execution of orders for clients.
Best execution does not necessarily mean the lowest commission, but instead involves consideration of a number of factors as
noted in point 12.1 above.
Under the Advisor’s soft dollar policy, if any services are obtained from brokers they must fall within the safe harbor requirements
of Section 28(e) of the Securities Exchange Act 1934.
12.1.2 Brokerage for Client Referrals The Advisor does not select broker-dealers in order to receive client referrals. The factors used by the Advisor in selecting
broker-dealers in order to execute trades are described in point 11.1 above.
12.1.3 Directed Brokerage The Advisor does not recommend, request or require that clients direct transactions through a specified broker-dealer. The
factors used by the Advisor in selecting broker-dealers in order to execute trades are described in point 11.1 above.
12.2 Order Aggregation The Advisor aggregates purchase or sale orders of the same security for multiple client accounts where the same order for these
clients is to be placed at the same time. Once executed the trades are allocated to each client, via an algorithm, to ensure that
each client as closely as possible received the same average execution price.
13 Review of Client Accounts The Advisor periodically reviews client accounts utilising product-specific review processes and supervisory personnel.
Accordingly, account review may differ across various product groups in order to more effectively serve clients.
Each client account is incorporated into the daily operations processes to ensure compliance with the clients’ investment
objectives and guidelines.
13.1 Factors Prompting Review of Client Accounts other than a Periodic Review Additional reviews of client accounts may be triggered by client request, compliance monitoring, industry factors, market
developments, statutory and regulatory changes and any issues that may have been identified with respect to a client account.
13.2 Content and Frequency of Account Reports to Clients The Advisor regularly provides written reports to clients that are tailored to the type of mandate for each client. At a minimum
each client receives a Monthly Performance Report. In addition, the Advisor typically meets with each client at least annually to
review investment strategy, performance and administrative matters.
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As described in Item 4 the Advisor does provide discretionary investment management services. Prior to any services being
provided an Investment Management Agreement must first be signed. Execution of such agreement authorises the Advisor to
supervise and direct the investment and reinvestment of assets in the client’s account on the client’s behalf and at the client’s
risk.
The Advisers discretionary authority may be limited by the terms of its written agreement with each client. These limitations
might include objective and investment guidelines that the client establishes for the account.
17 Voting Client Services This item is not applicable due to the nature of the securities traded by the Advisor.
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18.1 Balance Sheet Pursuant to SEC instructions, the Advisor is not required to include its balance sheet as part of this Brochure.
18.2 Financial Conditions Likely to Impair Ability to Meet Contractual Commitments to Clients The Advisor is not subject to any financial condition that is reasonably likely to impair its ability to meet contractual commitments
to clients.
18.3 Bankruptcy Filings The Advisor has not been the subject of a bankruptcy petition at any time during the past ten years.
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