Conflicts of Interest Statement

Introduction

First Sentier Investors is a global fund manager, wholly owned by
Mitsubishi UFJ Financial Group (MUFG). It operates in Australia asFirst Sentier Investors and ex-Australia as First State Investments.
It is First Sentier Investors’ policy to conduct all business in an
honest and ethical manner and we are committed to acting
professionally, fairly and with integrity in all our business dealings
and relationships wherever we operate. As part of this, First
Sentier Investors ensures that conflicts of interest are effectively
identified and managed to uphold the Group’s values of integrity,collaboration, excellence, accountability and service.

The Risk and Compliance teams will also assist in theidentification and monitoring of actual and potential conflicts ofinterest whilst also maintaining a record of any conflicts of interest.
Where a conflict of interest or a potential conflict of interest isidentified, the appropriate course of action to ensure fair treatmentof clients may include:–Disclosure of the interest to clients; for instance in investment
management agreements disclosure that we act for morethan one client and we will seek to treat each fairly.

–

Rely on a policy of independence; for instance where First
Sentier Investors is acting for both sides of a transaction i.e.
“agency cross” ensure that terms of the transaction arenormal commercial terms.

–

Establish internal arrangements; for instance preventing
the transfer of information internally by implementing
information barriers.

–

If necessary, decline to act for a client.

What are conflicts of interest?

Conflicts of interest can arise from the interaction between
different business units and affiliates of First Sentier Investors,
their clients, external parties and personal conflicts withemployees. Conflicts can also occur between First Sentier
Investors and our parent MUFG. Where the interests of thesestakeholders are different, this can create a conflict of interest,
which needs to be managed fairly.

A conflict of interest may arise where:–

First Sentier Investors’ interest conflicts with its duty toits clients–First Sentier Investors’ interest to one client conflicts with its
duty to another client–First Sentier Investors owes a duty of confidentiality to one
party but has the obligation to have undivided loyalty to all
its clients.

–Conflicts of interest may be actual, potential or perceived(where no actual conflict of interest exists, the perception of aconflict may be enough to cause potential reputationaldamage). As such, it is important that there are processes andpolicies in place to deal with actual, perceived and potential
conflicts of interest. Where these conflicts arise, considerationmust be afforded to managing the conflict fairly.

Identifying and managing conflictsof interest

All employees are required to understand conflicts of interest, how
they may arise and what should be done when conflicts areidentified. The overarching approach to be followed by all
employees on managing a conflict of interest is as follows:–Identify – understand what a conflict is and how it may arise inrelation to our day to day responsibilities and activities.

–Act – act in a manner aligned with the principles set out in First
Sentier Investors’ policies and procedures to manage
identified conflicts.

–

Report – all actual and potential conflicts must be recorded intheir business unit’s conflicts of interest registers.

Monitoring and reportingFirst Sentier Investors undertakes reviews to check whether
employees are complying with relevant policies and procedures
to identify and manage conflicts of interest. Risk and Complianceregularly monitor’s staff dealing activities, investment
management activity, and the firm’s systems and controls aresubject to periodic review and audit. Information relating toidentifying and managing conflicts of interest is reported, andconsidered by, Committee’s and relevant Boards.

Other policies supporting this statement–

Statement of Professional Practice–Conflicts of Interest Policy–Gifts & Entertainment–Personal Account dealing–

Order Handling (execution and trade allocation)–

Whistle Blowing–

Market Abuse–

Global Stewardship Principles–

Responsible Investment Report–Dealing with Related Entities Policy–Outsourcing Policy1This material has been prepared and issued by First Sentier Investors (Australia) IM Ltd (ABN 89 114 194 311, AFSL 289017) (Author). The Author forms part of First Sentier Investors, a global asset managementbusiness. First Sentier Investors is ultimately owned by Mitsubishi UFJ Financial Group, Inc (MUFG), a global financial group.
This material is directed at persons who are professional, sophisticated or ‘wholesale clients’ (as defined under the Corporations Act 2001 (Cth) (Corporations Act)) and has not been prepared for and is not intended for
persons who are ‘retail clients’ (as defined under the Corporations Act). This material contains general information only. It is not intended to provide you with financial product advice and does not take into account yourobjectives, financial situation or needs. Before making an investment decision you should consider, with a financial advisor, whether this information is appropriate in light of your investment needs, objectives andfinancial situation. Any opinions expressed in this material are the opinions of the Author only and are subject to change without notice. Such opinions are not a recommendation to hold, purchase or sell a particularfinancial product and may not include all of the information needed to make an investment decision in relation to such a financial product.
To the extent permitted by law, no liability is accepted by MUFG, the Author nor their affiliates for any loss or damage as a result of any reliance on this material. This material contains, or is based upon, information thatthe Author believes to be accurate and reliable, however neither the Author, MUFG, nor their respective affiliates offer any warranty that it contains no factual errors. No part of this material may be reproduced ortransmitted in any form or by any means without the prior written consent of the Author.
In Australia, ‘Colonial’, ‘CFS’ and ‘Colonial First State’ are trade marks of Colonial Holding Company Limited and ‘Colonial First State Investments’ is a trade mark of the Bank and all of these trade marks are used by FirstSentier Investors under licence.
Copyright © First Sentier Investors (Australia) Services Pty Limited 2020
All rights reserved.

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