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IOOF Advice Research Statement of Conflicts Management

IOOF has a group level conflicts management policy which sets out our framework for controlling, disclosing and avoiding conflicts of interest. This IOOF Advice Research Statement of Conflicts Management (Statement) informs you of how the IOOF Research team complies with the conflicts management obligation in the course of their role as research report providers. You may read more about IOOF Research, including our research scope, expertise, coverage, filters, spread of ratings, and find a full list of the products and classes of products that we provide research on, via our website.

Information barriers and segregation of duties

IOOF quarantines price-sensitive information that is not generally available in the market.

Electronic and physical storage systems holding such information and any other sensitive information are restricted to staff and teams who have a need to know about it, and access rights are determined and monitored by IT and management.

IOOF Research and staff working on the other side of information barriers do not generally work in close physical proximity of each other and in most cases they are in different office locations. Frequent staff transfers between research, financial planning and advisory, product or investment management, and like departments is discouraged, and these respective business units have well-defined and independent reporting lines.

Benefits and remuneration

No commissions or fees are paid to Research Analysts in relation to providing research reports. Research reports are provided for general advice and information purposes only, and not as an offer for the acquisition or sale of a product.

Like all IOOF employees, the Research team is remunerated based on each individual staff member's skills, qualifications and experience, and by reference to employment market salary trends. An annual, discretionary bonus may be awarded to IOOF employees, including IOOF Research staff, based on management assessment of their performance against position objectives.

From time to time Research staff may receive nominal gifts or hospitality from product providers. Acceptance of these benefits is subject to the guidelines and limits set out in the IOOF Group gifts policy. The IOOF Group Compliance team keeps a register of gifts and oversees the adherence of employees with the gift policy.

IOOF Research may attend industry forums, conferences and other like events for information or education purposes. Although their reasonable costs of accommodation or transport may be covered by the fund manager, dealer groups or product issuers, research staff do not directly benefit from this. Accommodation and transport will be provided purely to enable Research staff to attend and to keep informed about markets, the economy, product issuers, advisers, fund managers and other key industry professionals.

Interests and associations

IOOF Research holds no material interests in the products that are subject to the research reports they provide. Research staff strictly adhere to restrictions placed by IOOF on trading in securities.

As part of their day to day operations, IOOF Research staff may be provided with factual information about a product by the product issuer. Staff may also visit the product issuer's premises for the purposes of obtaining or verifying factual information about a product and the issuer.

IOOF Research may provide in-house general advice about products issued by licensees that are a part of IOOF, and from time to time it may broadly distribute general advice about products of IOOF licensees for promotional purposes. Such advice is not a research report to which this Statement applies.

Provision of non-research services

IOOF Research does not provide non-research services to any product issuer in the ordinary course of its operations. Where non-research-services are provided, IOOF Research will self-report to our Legal, Risk and Compliance teams, and disclose their activities in any research report relating to the product issuer that it has provided non-research services to.

The Head of Research and management staff will assess whether it is appropriate to undertake any other measures, including the implementation of a 'quiet period' whereby Research Analysts stop providing research reports while they provide non-research services.

Controls

IOOF Research operates within the Group wide investment governance framework that ensures that opinions and recommendations in research reports are well-founded on reasonable grounds, and have been crafted with due care, skill and diligence. Governance arrangements inject rigour and prudence into the research process and may enhance the quality of research reports.

The Legal, Risk and Compliance teams, audit, committees and the Board each have a role in monitoring and reviewing the effectiveness of controls surrounding the research process, and to continually improve the risk management and controls around this process.

Staff of IOOF Research are also bound by and are subject to a suite of Group level policies aimed at managing conflicts effectively, and adherence to these policies are a condition of their employment. The policies cover subject matter such as conflicts management, the receipt of gifts, managing outsourced and vendor relationships, code of conduct, the IOOF values, trading restrictions and fraud.

Disclosure of conflicts of interest

The author of each research report will disclose in that report, whether they or their associates have, or are likely to have in future, a material interest in the product that is subject to the report. Research analysts will also disclose benefits from providing the report, any associations or relationships with the product issuer subject to the report (including the provision of non-research services), and any assistance that they have received from the product issuer.