# Devon Alpha Fund (Wholesale) **Provider:** Devon Funds Management (https://devonfunds.co.nz) **Source:** https://wholesaleinvestor.co.nz/funds/devon-alpha-fund-wholesale **Facts JSON:** https://wholesaleinvestor.co.nz/api/im/devon-alpha-fund-wholesale/facts.json > This document is a machine-readable concatenation of 2 extracted document(s) for AI/LLM grounding. The original PDFs are linked in each section. > Wholesale-only — for eligible investors per FMCA Schedule 1. WI does not republish manager performance numbers; verify with the manager. --- ## PDS **Source PDF:** https://devonfunds.co.nz/sites/default/files/media-files/Devon_Investment_Funds_Product_Disclosure_Statement_2April_2026.pdf **Published:** 2026-04-02 **Pages:** 34 **Extracted via:** pdftotext on 2026-05-19 Product Disclosure Statement (PDS) 02.04.2026 ISSUER: DEVON FUNDS MANAGEMENT LIMITED DEVON ALPHA FUND DEVON AUSTRALIAN FUND DEVON DIVERSIFIED INCOME FUND DEVON DIVIDEND YIELD FUND DEVON GLOBAL IMPACT BOND FUND DEVON GLOBAL SUSTAINABILITY FUND DEVON SUSTAINABILITY FUND DEVON TRANS-TASMAN FUND This document replaces the Product Disclosure Statement dated 23.12.2025. This document gives you important information about this investment to help you decide whether you want to invest. There is other useful information about this offer on www.business.govt.nz/disclose. Devon Funds Management Limited has prepared this document in accordance with the Financial Markets Conduct Act 2013 (FMC Act). You can also seek advice from a financial advice provider to help you to make an investment decision. Key information summary. What is this? How can you get your money out? This is a managed investment scheme. Your money You may at any time request the redemption of some or will be pooled with other investors' money and invested all of your investment. Minimum redemption amounts in various investments. Devon Funds Management may apply and you will need to complete a redemption Limited (Devon, we, us, our) will invest your money request in the prescribed format which is available and charge you a fee for our services. The returns you from Devon on request. Subject to relevant law, we may receive are dependent on the investment decisions of defer or suspend redemptions in some circumstances. Devon and the performance of the investments. The See “How does this investment work?” on page 4 for value of those investments may go up or down. The types more information on how to get your money out. of investments and the fees you will be charged are Your investment in the Funds can be sold in accordance described in this Product Disclosure Statement (PDS). with relevant law but there is no established market for trading these financial products. This means that you What will your money be invested in? may not be able to find a buyer for your investment. There are 8 separate funds (Funds) offered under this PDS. These investment options are summarised on How will your investment be taxed? the following page. More information about the Each Fund is a Portfolio Investment Entity (PIE). investment target and strategy for each investment The amount of tax you pay in respect of a PIE is based on option is provided in the “Description of your your Prescribed Investor Rate (PIR). To determine your investment option(s)” on page 6. PIR, go to the IRD website www.ird.govt.nz/toii/pir/. For further information, see “What taxes will you pay?” Who manages the Devon in section 6 on page 12. Investment Funds? The manager of the Funds is Devon Funds Management Where can you find more key Limited. See “Who is involved?” on page 13 for more information? information about us. Devon is required to publish quarterly Fund Updates for each Fund. The Fund Updates show the returns, and What are the returns? the total fees actually charged to investors, during the The return on your investment comes from: previous year. The latest Fund Updates are available at • any increase or decrease in the Fund’s unit price; and www.devonfunds.co.nz. We will also provide you with • any distributions made to you from the Fund. copies of those documents on request. The Devon Alpha Fund, Devon Australian Fund, Devon Sustainability Fund and Devon Trans-Tasman Fund intend to pay distributions semi-annually. The Devon Diversified Income Fund, Devon Dividend Yield Fund and the Devon Global Impact Bond Fund intend to pay distributions quarterly. The Devon Global Sustainability Fund does not distribute income, and as such any accrued income for the Fund is reflected in the Fund’s unit price. All distributions are at our discretion. See “How does this investment work?” on page 4 for more information. DEVON FUNDS MANAGEMENT LIMITED 1 Devon investment options. See “What are the risks of investing?” on page 9 for an explanation of the risk indicator and for information about other risks that are not included in the risk indicator. To help you clarify your own attitude to risk, you can seek independent financial advice or work out your own risk profile at www.sorted.org.nz/tools/investor-kickstarter. Fund Name Description Risk Indicator2 Estimated Annual Fund Charges1 Based on Net Asset Value (NAV) DEVON The Fund aims to generate capital growth over the long LOWER RISK HIGHER RISK 1.85%3 ALPHA term by actively investing in a concentrated portfolio of FUND 10-15 New Zealand and Australian shares and holding 1 2 3 4 5 6 7 cash when appropriate investment opportunities cannot potenially lower returns potenially higher returns be identified. DEVON The Fund aims to generate capital growth over the long LOWER RISK HIGHER RISK 1.60%3 AUSTRALIAN term by actively managing Australian equity investments. FUND The Australian market offers exposure to a number of 1 2 3 4 5 6 7 sectors that are not available in New Zealand. potenially lower returns potenially higher returns DEVON The Fund aims to give investors access to a carefully LOWER RISK HIGHER RISK 0.96% DIVERSIFIED selected portfolio of high yielding investments, including INCOME government and corporate bonds, cash, listed property, 1 2 3 4 5 6 7 FUND infrastructure and utility companies, high yielding equities, potenially lower returns potenially higher returns credit securities and other yielding financial assets. DEVON A select portfolio of New Zealand and Australian listed LOWER RISK HIGHER RISK 1.19%3 DIVIDEND equity securities chosen for their attractive dividend YIELD yields, with some growth prospects to maintain the 1 2 3 4 5 6 7 FUND dividend yield and capital value in real terms. potenially lower returns potenially higher returns DEVON GLOBAL The Fund aims to deliver long-term total returns in excess LOWER RISK HIGHER RISK 0.63% IMPACT BOND of the index by investing in a diverse portfolio of global FUND2 bonds through investment in the Wellington Global Impact 1 2 3 4 5 6 7 Bond Fund managed by Wellington Management Funds (Ireland) plc (Wellington Management). The Wellington potenially lower returns potenially higher returns Global Impact Bond Fund aims is to improve access to, and the quality of, basic life essentials, reduce inequality and mitigate the effects of climate change. DEVON GLOBAL The Fund aims to deliver long-term total returns in excess LOWER RISK HIGHER RISK SUSTAINABILITY of the index by investing in the equities of companies 1.24% FUND2 globally, that generate high return on capital relative to 1 2 3 4 5 6 7 their peers, and whose management teams and boards display exemplary stewardship to sustain those returns potenially lower returns potenially higher returns over time. The Fund obtains this exposure through investment in the Wellington Global Stewards Fund managed by Wellington Management. DEVON This Fund aims to generate capital growth over the long LOWER RISK HIGHER RISK 1.31% SUSTAINABILITY term by investing in those New Zealand and Australian FUND2 listed companies that rate highly on overall environmental, 1 2 3 4 5 6 7 social and corporate governance (ESG) performance. The potenially lower returns potenially higher returns Fund employs an ethical screen to exclude companies where more than 10% of business revenue is derived from the manufacture of alcohol, gambling, pornography and the exploration, extraction, refining or processing of fossil fuels. The Fund will also employ an ethical screen to exclude companies where any business revenue is derived from the manufacturing of tobacco products or armaments.4 DEVON The Fund aims to generate capital growth over the long LOWER RISK HIGHER RISK 1.60%3 TRANS-TASMAN term by actively investing in a portfolio of New Zealand FUND and Australian shares. The Fund tends to be fully invested 1 2 3 4 5 6 7 in shares but can hold cash. potenially lower returns potenially higher returns 1 A buy/sell spread (to fairly allocate the costs of buying and selling underlying assets) may be applicable on investment and redemption, or on switches. See section 5 for more information on buy/sell spreads. 2 As the Devon Global Impact Bond Fund and Devon Global Sustainability Fund have not been in existence for five (5) years, we have used market index returns for the period from 31 December 2020 to 28 February 2022, and actual returns from 1 March 2022 to 31 December 2025, to calculate the risk indicators. Therefore, the risk indicators may provide a less reliable indicator of potential future volatility of the Fund. See Section 3 ‘Description of your investment option’ for more information on risk indicators. 3 The Devon Alpha, Devon Australian, Devon Dividend Yield and Devon Trans-Tasman Funds’ fees include estimated performance-based fees. See page 10 for more information. 4 The Devon Sustainability Fund invests into the Devon Sustainability Wholesale Fund which holds the assets. 2 DEVON FUNDS MANAGEMENT LIMITED Contents. 1. Key information summary 1 2. How does this investment work? 4 3. Description of your investment option(s) 6 4. What are the risks of investing? 9 5. What are the fees? 10 6. What taxes will you pay? 12 7. Who is involved? 13 8. How to complain 14 9. Where you can find more information 14 10. How to apply 14 Glossary 15 DEVON FUNDS MANAGEMENT LIMITED 3 How does this investment work? Devon is an investment Devon Funds Management is an investment management company based in Auckland. Founded management business specialising in 2010, we offer a range of funds to New Zealand in building investment solutions investors to meet a variety of investment objectives. We manage money on behalf of a diverse range of leading for our clients. Our highly qualified New Zealand clients, including large superannuation and experienced team is committed schemes, Community Trusts, charities, KiwiSaver schemes, Iwi, corporate pension schemes and individual to helping you achieve your investors. investment objectives. We believe Investing in managed funds can help you achieve your savings goals and create greater wealth for your future. our advantage lies in our people We believe some of the potential benefits of investing – a dedicated team of investment in our Funds are: professionals with many years’ • Professional Management: Employing the expertise and resources of a professional manager experience in managing portfolios, may be beneficial if you do not have the time or skill both within Australasia and further to manage your own investments. • Diversification: By pooling together large amounts afield. We’ve worked hard to of money, we are able to invest in a portfolio of assemble the right talent with the securities which allows for diversification with the aim of reducing the risk of your investment. It also necessary skills and experience to provides access to markets and securities that might manage your Funds.” otherwise be out of reach. • Administrative Simplicity: Our Funds are Portfolio Investment Entities (PIEs). PIEs offer significant advantages from an administrative perspective. We take care of the paperwork involved in buying and selling securities, managing your dividends, interest, corporate actions, reporting and record keeping. • Tax Advantages: Our Funds are all PIEs for tax purposes, meaning that if you are a New Zealand resident unit holder and have supplied us with the correct PIR, tax is usually paid on your behalf at a rate approximating your marginal tax rate and there is no further tax to pay. PIE tax is capped at 28% which can be a benefit for 33% tax rate investors. • Responsible Investing: We believe that by considering Environmental, Social and Governance (ESG) factors across the companies that we own and the sectors that we invest into, we can through time, enhance our ability to meet long-term performance objectives. Incorporating ESG within our process provides us with a greater level of risk analysis and enhances portfolio risk management. We believe that our risk-adjusted returns will be enhanced 4 DEVON FUNDS MANAGEMENT LIMITED through the ownership of companies that execute on Distributions their ESG strategies at a high level and also in those The Devon Alpha Fund, Devon Australian Fund, companies which demonstrate a commitment to Devon Sustainability Fund and Devon Trans-Tasman improving their performance with respect to ESG. Fund intend to pay distributions semi-annually. The We are a signatory to the United Nations supported Devon Diversified Income Fund, Devon Dividend Principles for Responsible Investment (PRI). The Yield Fund and the Devon Global Impact Bond Fund PRI provides global principles and a framework to intend to pay distributions quarterly. The Devon Global help us integrate the consideration of ESG issues Sustainability Fund does not distribute income, and as into our investment decision-making and portfolio such any accrued income for the Fund is reflected in the construction framework. As part of this process we Fund’s unit price. All distributions are at our discretion. report annually to the PRI on our adherence to these You can elect to have distributions re-invested in the policies. We are also a member of the Responsible Fund or direct credited to your bank account. Please Investment Association of Australasia (RIAA). note, we do not pay to third party bank accounts. As a member of RIAA, we commit to promoting, advocating for, and supporting approaches to Making investments responsible investment that align capital with You can make lump sum or regular investments into achieving a healthy and sustainable society, the Funds. Investments can be made by completing the environment and economy. The Devon Sustainability application form for the relevant Fund(s) at the back of Fund is certified by RIAA. RIAA certification this PDS. A NZ$10,000 minimum applies for the initial signifies that the Devon Sustainability Fund has contribution and NZ$100 minimum per quarter for implemented an investment style and process that subsequent regular payments. For information on how systematically takes into account environmental, to invest in the Fund(s), see “How to apply” on page 14. social, governance or ethical considerations, and this investment process reliability has been verified by an external party. Certification also signifies that Withdrawing your investments the Devon Sustainability Fund adheres to the strict If you wish to make a redemption you must complete a operational and disclosure practices required by redemption request in the prescribed format which is RIAA’s Certification Program. available from Devon on request. Once submitted, your Further information can be found in our Responsible redemption request is not able to be withdrawn. We have Investment Policy at www.devonfunds.co.nz the ability, in certain circumstances to suspend or defer redemptions. In the event that this should ever occur, This PDS is an offer of units in the Devon Investment you can still submit a redemption request and these will Funds. Each Fund is constituted within a Managed be processed, in the order in which they are received, Investment Scheme that is governed by the Devon once the suspension or deferral has been lifted. Trust Deed (dated 30 September 2016). You may withdraw amounts of $2,000 or more. If your The money you invest buys units in the Fund(s) you’ve withdrawal would result in your investment falling chosen. The price of each unit you receive depends on the below $2,000, we may request the Supervisor to value of the Fund at the time you invest. We calculate the withdraw the balance of your holding and repay the unit price by dividing the Net Asset Value of the Fund by proceeds back to you. the number of units the Fund has on issue. We also have Withdrawal requests will be processed each business the discretion to include trading costs in determining day in Auckland. The withdrawal value of the units will the unit price received. The unit price is calculated daily be paid to you, after adjustment for any tax payable (if and published on our website. Daily unit prices for each applicable), within 30 business days from the date your Fund will change as the market value of those Funds’ withdrawal request is received. No person guarantees assets change. The return on your investment is reflected or promises the repayment of, or returns on, your in any increase or decrease in the unit price and any investment in the Funds. distributions from the Fund(s). The number of units you have (your unitholding), when How to switch between Funds multiplied by the unit price, gives you the total value of You can also switch between Funds as often as you like. your investment in the Fund (although the impact of tax Completed switch requests will be made can result in a change in the number of units you hold, up on the next available unit price. A switch will be treated or down, as the unit price is calculated before tax). as a redemption from one Fund and an application into No assets of a Fund will be available to be applied to another Fund. A switching form is available from meet the liabilities of any other Fund managed by us. Devon on request. DEVON FUNDS MANAGEMENT LIMITED 5 Description of your investment option(s). The table below summarises the strategy, objectives and characteristics of each Fund. More information is contained within the Statement of Investment Policies and Objective (SIPO) of the Funds. Summary of investment strategy and objectives Target investment mix Risk category DEVON ALPHA FUND 0-100% 5 Strategy: The Fund invests in a concentrated portfolio of Australasian This Fund has approximately 10-15 select companies listed on the New Zealand equities. a high level of and Australian share markets. The Alpha Fund does not follow an 0-100% cash or volatility. equity index and is actively managed, which means that we make cash equivalent securities. our own investment decisions rather than have the Alpha Fund passively follow an index. Benchmark: Official Cash Rate (OCR) +5%. Objective: The Fund aims to generate capital growth over the long term by actively investing in a concentrated portfolio of New Zealand and Australian equities and holding cash when appropriate investment opportunities cannot be identified. Minimum suggested investment timeframe: 5 years DEVON AUSTRALIAN FUND 80-100% 5 Australasian Strategy: The Fund invests in a select portfolio of companies This Fund has equities. which are primarily Australian listed companies. The Australian a high level of market offers exposure to a number of sectors that are not 0-20% Cash or volatility. available in New Zealand. cash equivalent securities. Benchmark: The S&P/ASX200 (Accumulation) Index in NZD. Objective: The Fund aims to generate capital growth over the long term by actively managing your Australian equity investments. Minimum suggested investment timeframe: 5 years DEVON DIVERSIFIED INCOME FUND 0-100% New 3 Strategy: The Fund invests in a carefully selected portfolio Zealand Fixed This Fund of government and corporate bonds, cash, listed property, Interest. has a low to infrastructure and utility companies, high yielding equities, credit 0-40% medium level securities and other yielding financial assets. We employ the Australasian of volatility. specialist services of the JBWere Fixed Interest team to advise on equities. fixed interest security selection and aid in portfolio construction. 0-100% Cash or Devon has oversight and control over this investment process. cash equivalent Benchmark: 75% Bloomberg New Zealand Bond Composite 0-5 securities. Year Index and 25% 50:50 composite of the S&P/NZX50 (Gross) 0-10% Other. Index and the S&P/ASX200 (Accumulation) Index fully hedged to NZD. Objective: The Fund aims to give investors access to a diverse and carefully selected portfolio of high yielding investments and aims to outperform its benchmark on a rolling 12 month basis. Minimum suggested investment timeframe: 3 years 6 DEVON FUNDS MANAGEMENT LIMITED Continued... Summary of investment strategy and objectives Target investment mix Risk category DEVON DIVIDEND YIELD FUND 90-100% 4 Australasian This Fund has Strategy: The Fund invests in a select portfolio of New Zealand equities. a high level of and Australian listed equity securities chosen for their attractive dividend yields, with some growth prospects to maintain the 0-10% Cash or volatility. dividend yield and capital value in real terms. cash equivalent securities. Benchmark: 50:50 composite of the S&P/NZX50 (Gross) Index and the S&P/ASX200 (Accumulation) Index fully hedged to NZD. Objective: The Fund invests in a well-researched portfolio of equities with the objective of generating an above market average dividend yield while providing some growth to maintain capital values in real terms. Minimum suggested investment timeframe: 5 years DEVON GLOBAL IMPACT BOND FUND 0-100% Global fixed 3 interest and cash, This Fund Strategy: The Fund invests into the Wellington Global Impact or cash equivalent has a low to Bond Fund, managed by Wellington Management. Wellington securities. medium level Management seeks to understand the world’s social and environmental problems and to identify and invest primarily in of volatility. debt issued by companies and organisations that they believe are addressing these needs in a differentiated way through their core products, services and projects. The Wellington Global Impact Bond Fund aims to improve access to, and the quality of, basic life essentials, reduce inequality and mitigate the effects of climate change. Benchmark: Bloomberg Global Aggregate Index in NZD, 100% hedged to NZD. Objective: The Fund aims to deliver long-term total returns in excess of the index by investing in a diverse portfolio of global bonds. Minimum suggested investment timeframe: 5 years DEVON GLOBAL SUSTAINABILITY FUND 90-100% 5 Strategy: The Fund invests into the Wellington Global Stewards Global equities. This Fund has Fund, managed by Wellington Management. Wellington 0-10% cash or a high level of Management seeks to invest in companies globally, that generate cash equivalent volatility. high return on capital relative to their peers, and whose management securities. teams and boards display exemplary stewardship to sustain those returns over time. Wellington define stewardship as how companies balance the interests of all stakeholders (customers, employees, communities and the supply chain) in the pursuit of profits and how they incorporate material environmental, social and governance (ESG) risks and opportunities in their corporate strategy. Benchmark: MSCI All Country World Index in NZD, 50% hedged to NZD. Objective: The Fund aims to deliver long-term total returns in excess of the index by investing in a selective portfolio of global equities. Minimum suggested investment timeframe: 5 years DEVON FUNDS MANAGEMENT LIMITED 7 Continued... Summary of investment strategy and objectives Target investment mix Risk category DEVON SUSTAINABILITY FUND 90-100% 4 Australasian This Fund has Strategy: The Fund will look to invest in those companies equities. a high level of that rate highly on overall environmental, social and corporate governance (ESG) performance. The Fund employs an ethical 0-10% cash or volatility. screen1 to exclude companies where more than 10% of business cash equivalent revenue is derived from the manufacture of alcohol, gambling, securities. pornography and the exploration, extraction, refining or processing of fossil fuels. The Fund will also employ an ethical screen to exclude companies where any business revenue is derived from the manufacture or sale of armaments, production and manufacture of tobacco and tobacco-based products or nicotine alternatives , and any company involved in whaling activities or on human rights watchlists as stated by MSCI2. The Fund invests in a select portfolio of well researched New Zealand and Australian listed companies. Benchmark: 50:50 composite of the S&P/NZX50 Portfolio Index and the S&P/ASX200G index hedged to NZD. Objective: This Fund aims to generate capital growth over the long term by actively managing your New Zealand and Australian equity investments. The Fund also aims to deliver an MSCI ESG rating greater than the MSCI ESG rating of the brenchmark. Minimum suggested investment timeframe: 5 years DEVON TRANS-TASMAN FUND 50-100% 5 Australasian This Fund has Strategy: The Fund invests in a select portfolio of well researched equities. a high level of companies which are primarily New Zealand and Australian listed companies. 0-50% Cash or volatility. cash equivalent Benchmark: 50:50 composite of the S&P/NZX50 (Gross) Index securities. and the S&P/ASX200 (Accumulation) Index unhedged to NZD. Objective: This Fund aims to generate capital growth over the long term by actively managing your New Zealand and Australian equity investments. Minimum suggested investment timeframe: 5 years We can make changes to the SIPO of any Fund in accordance with the Trust Deed and the Financial Markets Conduct Act 2013. Before making changes to the SIPO, we will consider if the changes are in your best interests and consult with the Supervisor. We will give notice of changes to unit holders of the relevant Fund prior to effecting any material changes. The most current SIPO for the Funds can be found on the scheme register at www.business.govt.nz/disclose. Our use of the various market indices referred to in the above table is subject to certain terms, conditions and disclaimers as described in the offer register at www.business.govt.nz/disclose in the document titled ‘Other Material Information.’ This is located under the ‘Documents’ tab on the managed fund offer register under Devon Investment Funds. Further information about the assets in the Funds can be found in the Fund Updates on our website www.devonfunds.co.nz. 1 Once Devon has made the decision to invest in a particular company, that company is subject to ongoing monitoring on a periodic basis in respect of the screening applied before that investment was made. If this monitoring programme was to identify a possible exception (for example, a company with more than 10% of business revenue derived from the manufacture of alcohol), the holding will be disposed of within 30 days in normal market conditions. In the event of a breach being identified, Devon will communicate with clients on both the nature of the breach and the steps taken to address the breach. 2 More information on the types of fossil fuels, tobacco-based products, nicotine alternatives, and armaments excluded is contained within the SIPO. 8 DEVON FUNDS MANAGEMENT LIMITED What are the risks of investing? Understanding the risk indicator subject to custodial and political risks, and volatility. Managed funds in New Zealand must have a standard Investment in foreign currency entails exchange risks. risk indicator. The risk indicator is designed to help Below investment grade: Lower rated or unrated investors understand the uncertainties both for loss securities may have a significantly greater risk of default and growth that may affect their investment. You can than investment grade securities, can be more volatile, compare Funds using the risk indicator. less liquid, and involve higher transaction costs. An example of our risk indicator is below. If any of these risks occur, you may receive less on the LOWER RISK HIGHER RISK The risk indicator for sale of your units than you expect. each of the Funds can No person guarantees or promises the repayment of, 1 2 3 4 5 6 7 be found on page 2 of or returns on, your investment in the Funds. potenially lower returns potenially higher returns this PDS. Other specific risks The risk indicator is rated from 1 (low) to 7 (high). The ESG: The Devon Global Impact Bond Fund, Devon Global rating reflects how much the value of the Fund’s assets Sustainability Fund and Devon Sustainability Fund use goes up and down (volatility). A higher risk generally ESG exclusions (negative screens) to assist in making means higher potential returns over time, but more ups investment decisions. The Devon Alpha Fund, Devon and downs along the way. Australian Fund, Devon Diversified Income Fund, Devon To help you clarify your own attitude to risk, we suggest Dividend Yield Fund and Devon Trans-Tasman Fund’s you seek financial advice or work out your risk profile at primary objective is not related to ESG factors. However, www.sorted.org.nz/calculators/investment-planner. the consideration of ESG factors is an essential part of Please note that even the lowest category does not Devon’s investment process. ESG screens are included mean a risk-free investment, and there are other risks in the pre-investment phase of an investment to ensure (described under the heading “Other Specific Risks”) investment companies align with our stated objectives. that are not captured by this rating. This risk indicator We constantly monitor any changes with regard to ESG is not a guarantee of a Fund’s future performance. The factors as part of our ongoing decisions to retain or divest risk indicator is based on the returns data for the five investments. The outcome of these screens may reduce years to 31 December 2025 where available. While the returns you receive. risk indicators are usually relatively stable, they do In the case of the Devon Global Impact Bond Fund shift from time to time. You can see the most recent and Devon Global Sustainability Fund, there is also risk indicator in the latest quarterly Fund Update for a risk that the outcome of the screening performed, these Funds. and investment decisions made by the underlying A combination of actual Fund returns and market fund manager (Wellington Management), may not index returns, as outlined on page 2, has been used align with your preferences. For more information on to determine the risk indicator for the Devon Global the screens applied by Wellington Management, see Impact Bond Fund, Devon Global Sustainability Fund Wellingtons ESG Policies here: www.wellington.com/ and Devon Sustainability Fund as these Funds have not en/sustainability/reports-and-policies been operational for the required 5 years. Credit: Specific to the Devon Diversified Income Fund General investment risks and Devon Global Impact Bond Fund. The value of a bond may decline, or the issuer /guarantor may fail to Some of the things that may cause a Fund’s value to meet obligations. Typically lower-rated bonds carry a move up and down, which affect the risk indicator, are: greater degree of credit risk than higher-rated bonds. Market risk: Risk of losses based on the overall Default risk: Specific to the Devon Diversified Income performance of financial markets. Fund and Devon Global Impact Bond Fund is the risk that Security specific risk: Risks that are specific an issuer of a security in which the Fund has invested to a particular security. will not pay the interest and/or repay the principal of Currency & hedging risk: Risk of losses from a security in which the Fund has invested. This risk is fluctuating foreign exchange rates. generally greater for issuers with lower credit ratings but Interest rate risk: Risk that a security’s value will may reduce your return on units in the Fund. change due to a change in interest rates. Investment objective risk: Risk that the investment There may be other circumstances that can increase objectives of a Fund will not be met. the risk to your returns that are not reflected in the risk Concentration risk: Risk arising from a Fund’s assets indicator. We recommend you view our Other Material being concentrated in a particular security, group of Information document which contains information securities, geographical area, industry or other grouping. about other risks not mentioned in this PDS. Operational risks: Risk of an error in procedures or Our Other Material Information document can be found systems which impacts the pricing of units in a Fund. on the offer register at www.business.govt.nz/disclose Emerging markets: Emerging markets may be DEVON FUNDS MANAGEMENT LIMITED 9 What are the fees? You will be charged fees for investing in the Funds. Fees are deducted from your investment and will reduce your returns. If we invest in other funds, those funds may also charge fees. The fees you pay will be charged in two ways: • regular charges – for example annual fund charges and performance fees. Small differences in these fees can have a big impact on your investment over the long term; and • one-off fees – for example abnormal legal or regulatory fees. Estimated Annual Fund Charges (as a percentage of net asset value) Fund Estimated Estimated Total Management fee Administration performance-based annual fund charges Devon Alpha Fund 0.87% 0.54% 1.85% Devon Australian Fund 0.87% 0.29% 1.60% Devon Diversified Income Fund 0.52% N/A 0.96% Devon Dividend Yield Fund 0.62% 0.13% 1.19% Devon Global Impact Bond Fund 0.34% N/A 0.63% Devon Global Sustainability Fund 0.95% N/A 1.24% Devon Sustainability Fund 0.87% N/A 1.31% Devon Trans-Tasman Fund 0.87% 0.29% 1.60% Some of the fees charged to the Funds in the table above are performance fees are calculated below. Actual performance- subject to goods and services tax (GST), while others are based fees for the most recent scheme year will be available GST‑exempt. To clarify, investment management services in the latest quarterly Fund Update. provided to the Funds are exempt from GST, so GST is not If Devon invests in other Funds, those Funds may also charge charged on the management fee, or any performance‑based fees. At the date of this PDS, the Devon Diversified Income fee paid to us. All other services provided to the Funds are Fund invests into the Devon Dividend Yield Fund, the Devon subject to GST at the standard rate of 15%.The total annual Global Impact Bond Fund invests into the Wellington Global fund charges are an estimate of each Funds Net Asset Value Impact Bond Fund, and the Devon Global Sustainability (NAV) and shall not exceed the amount shown above for each Fund invests into the Wellington Global Stewards Fund. All Fund. All fees are accrued daily, paid monthly in arrears to us fees from these investments are fully refunded. and are reflected in the unit price. There are currently no individual action fees, no The charges outlined above cover: establishment, termination, withdrawal or switching fees Management fee: all investment management services, charged to the Fund. We can introduce these fees in the including amounts due to external fund managers. future in accordance with the Trust Deed and applicable law. Administration charges: all other expenses including Brokerage and other transaction costs are paid directly by supervisor, custodian, administration, registry. unit pricing, the fund. Under the terms of Funds governing document, fund accounting, legal, audit and regulatory compliance. other expenses such as one-off costs and taxes may also be Additionally, the Manager and the Supervisor are entitled charged to the Fund. to be reimbursed out of each Fund for all other expenses properly and reasonably incurred by the Supervisor or the Performance-based fees Manager in connection with carrying out their respective Some of our Funds have performance-based fees if they duties under the Trust Deed. earn above the Fund’s hurdle rate of return, subject to Performance-based fees: These are estimates calculated a high water mark, as detailed below. The use of a high on the basis of combined Fund returns since inception and water mark ensures that you do not pay for the same market performance from 30 June 1992 to 31 December performance twice. The term high water mark means the 2025 (33.5 years) as described in Devon’s Other Material highest value that a Fund has achieved on previous per- Information document located at www.business.govt.nz/ formance fee calculation dates. Performance-based fees disclose. We have not made any estimate for outperformance are only payable if a Fund’s performance exceeds the high of the market by the Funds. water mark. A high water mark ensures that if a manager Given this, and the use of long term averages, it is to be loses money over a period, they must achieve investment expected that actual performance fees may be more (or less) returns above the high water mark before receiving a than shown in the table in any given year. In particular, performance-based fee. The high water mark can be reset investors should be aware that the Devon Alpha Fund does every three years at our discretion in conjunction with the not track a market index. Please see the details of how the Supervisor. 10 DEVON FUNDS MANAGEMENT LIMITED Continued... Devon Alpha Fund Devon Australian Fund Hurdle rate of return 12%p.a. Hurdle rate of return S&P/ASX200 in NZD. Amount of fee The first 1% of gross return Amount of fee 10% of the net return of the above the hurdle rate of Fund (reflected in the unit return up to 13% per annum, price) over the hurdle rate of then 15% of the gross return return for the relevant period. thereafter. There is a cap on Maximum limit No the performance fee of 3%. High water mark Yes Maximum limit No Frequency of payment Calculated and accrued, if High water mark Yes and calculation applicable, in the daily unit Frequency of payment Calculated and accrued, if price and paid monthly based and calculation applicable, in the daily unit on the rolling annual returns. price and paid annually, on 31 March each year. Devon Dividend Yield Fund Devon Trans-Tasman Fund Hurdle rate of return 50:50 composite of the S&P/ 50:50 composite of the S&P/ NZX50 (Gross) Index and the NZX50 (Gross) Index and the S&P/ASX200 (Accumulation) Hurdle rate of return Index fully hedged. S&P/ASX200 (Accumulation) Index unhedged to NZD. Amount of fee 10% of the net return of Amount of fee 10% of the net return of the the Fund (reflected in the Fund (reflected in the unit unit price) over the Fund’s price) over the hurdle rate of hurdle rate of return for the return for the relevant period. relevant period. Maximum limit No Maximum limit No High water mark Yes High water mark Yes Frequency of payment Calculated and accrued, if Frequency of payment Calculated and accrued, if and calculation applicable, in the daily unit and calculation applicable, in the daily unit price and paid monthly based price and paid monthly based on the rolling annual returns. on the rolling annual returns. The Diversified Income Fund, Global Impact Bond Example of how fees apply to an investor Fund, Global Sustainability Fund and Sustainability Fund do not charge a performance fee. Mel invests $10,000 in the Devon Trans-Tasman Fund. She is not charged an establishment fee or Various individual action fees contribution fee. This brings the starting value of her A buy/sell spread (to fairly allocate the costs of buying investment to $10,000. and selling underlying assets) may be applicable on She is charged management and administration fees, investment and redemption, or on switches. These are which work out to about $131 (1.31% of $10,000) over the amounts determined at our discretion on account of year. These fees might be more or less if her account estimated costs which would be incurred if investments balance has increased or decreased over the year. of the relevant trust were acquired or realised to make an investment or pay a redemption. For more information Mel may also be charged a performance-based fee please refer to Devon’s “Other Material Information” if her Fund earned more than its hurdle rate. document (OMI) on Disclose at www.business.govt.nz/ Estimated total fees for the first year disclose, and Devon’s website at www.devonfunds.co.nz/ Fund charges: $131 buysell-spreads. The fees can be changed See the latest Fund Update for an example of the actual The existing fees may be changed or new fees imposed returns and fees investors were charged over the past year. in accordance with the Trust Deed and applicable law This example applies only to the Devon Trans-Tasman upon giving you 90 days written notice. We must publish Fund. If you are considering investing in other a quarterly Fund Update for each Fund showing the fees Funds within the Scheme, this example may not be actually charged during the most recent year. representative of the actual fees you may be charged. Fund Updates, including past fund updates, are available at www.devonfunds.co.nz. DEVON FUNDS MANAGEMENT LIMITED 11 What taxes will you pay? Each Devon Fund is a portfolio investment entity (PIE). More information relating to ‘taxes you will pay’ is in The amount of tax you pay is based on your prescribed the Other Material Information document which is investor rate (PIR). To determine your PIR, go to available at www.disclose-register.companiesoffice. www.ird.govt.nz/pir. If you are unsure of your PIR, we govt.nz. recommend you seek professional advice or contact the Inland Revenue Department. It is your responsibility to tell Devon your PIR when you invest or if your PIR changes. If you do not tell Devon, a default rate may be applied. If the rate applied to your PIE income is lower than your correct PIR, you will be required to pay any tax shortfall as part of the income tax year-end process. If the rate applied to your PIE income is higher than your PIR, any tax over-withheld will be used to reduce any income tax liability you may have for the tax year and any remaining amount will be refunded to you. We may change your PIR if Inland Revenue tell us to. 12 DEVON FUNDS MANAGEMENT LIMITED Who is involved? About Devon Devon Funds Management is an investment management company based in Auckland. Founded in 2010, we offer a range of funds to New Zealand investors to meet a variety of investment objectives. Devon is regulated by the Financial Markets Authority and holds a Managed Investment Scheme Manager license. Its operations are supported by industry leading fund administration, custodial and supervisory service providers. Devon is part of the Investment Services Group (ISG), which in turn is majority owned by Shaw and Partners Financial Services Limited (Australia). ISG provides investment administration and operation services to Devon. Other companies in the group include Shaw and Partners Financial Services Limited (Shaw and Partners), Select Wealth Management Limited, Clarity Funds Management Limited and TAHITO Limited. More information about Devon, its funds, and key people is available on our website at www.devonfunds.co.nz. Contact Details: Devon Funds Management Limited Level 17 HSBC Tower 188 Quay Street Auckland 1010 Telephone: 0800 944 049 (free call) or +649 925 3990 E-mail: enquiries@devonfunds.co.nz Information about key personnel for the Funds can be found on our website www.devonfunds.co.nz. Who else is involved? Role Name Description Supervisor and The New Zealand Guardian Supervisor of the Devon Investment Funds under the Financial Markets Conduct Act Custodian Trust Company Limited 2013, responsible for supervising us as Manager of the Funds. Sub-Custodian BNP Paribas Fund Services Appointed by the Supervisor to hold the assets of the Funds on behalf of investors. Australasia Pty Limited Administration Apex Group Limited Appointed by us to provide various administration functions in respect of the Funds, Manager including registry, unit pricing and fund accounting. Administration Investment Services Group Appointed by us to provide administration functions which include investor Manager (ISG) onboarding, transaction processing, operational management, and investment oversight to the Funds. Adviser JBWere (NZ) Pty Limited Appointed by us to provide investment advice for the Diversified Income Fund. Investment Wellington Management Wellington Management is a globally integrated investment management firm and is Manager Funds (Ireland) plc the investment manager of the Wellington Global Impact Bond Fund and Wellington Global Stewards Fund, in which the Devon Global Impact Bond Fund and Devon Global Sustainability Fund invest respectively. DEVON FUNDS MANAGEMENT LIMITED 13 How to complain. Any complaints about the Funds can be made to us at the If you have made a complaint to us and it has not been address above. resolved within 40 days, or if you are dissatisfied with the You can also send your complaints to the Supervisor at: proposed resolution, you can refer it to: The New Zealand Guardian Trust Company Limited Insurance and Financial Services Ombudsman Scheme Level 6, 191 Queen Street, Auckland 1010 Level 8, Shamrock House PO Box 274, Shortland Street, Auckland 1140 79 – 81 Molesworth Street Telephone: +649 909 501 Wellington (Call free) 0800 888 202 Devon is a member of Insurance and Financial Services (Wellington) 04 499 7612 Ombudsman Scheme which is an independent dispute resolution scheme approved by Ministry of Commerce Insurance and Financial Services Ombudsman and Consumer Affairs. Scheme will not charge a fee to any complainant to investigate or resolve a complaint. Further information about referring a complaint to Insurance and Financial Services Ombudsman Scheme can be found at www.ifso.nz Where you can find more information. Further information relating to the Devon Investment We are required to publish quarterly Fund Updates for Funds (for example, financial statements) is available each Fund. The Fund Updates show the returns, and on the offer register and the scheme register at the total fees actually charged to investors, during the www.business.govt.nz/disclose. previous year. The latest Fund Updates are available at A copy of the information on the offer register and the www.devonfunds.co.nz. We will also give you copies of scheme register is available on request to the Registrar. those documents free of charge on request to any of our A copy of that information can also be obtained by contact details set out above. contacting us at: You will also be sent an annual tax statement which will Devon Funds Management Limited include the amount of PIE income allocated to you and Level 17 the amount of tax paid at your chosen PIR. You will also HSBC Tower be asked to confirm your IRD number and PIR. 188 Quay Street Auckland 1010 Telephone: 0800 944 049 (free call) or +649 925 3990 E-mail: enquiries@devonfunds.co.nz How to apply. If you are making an investment directly with Devon then you can either apply directly on our website at https://devonfunds.co.nz/how-to-apply or complete the application form at the back of this PDS. 14 DEVON FUNDS MANAGEMENT LIMITED Glossary. BENCHMARK the standard against which the performance of a Fund is compared. CORPORATE BOND a debt security issued by a company or other entity. DIVIDEND YIELD how much a company pays out in dividends each year relative to its share price. EQUITIES a share representing an ownership interest in an entity (generally companies). FIXED INTEREST debt security, such as a bond, that is issued by an entity and makes interest securities payments. A fixed interest security pays a specified rate of interest that does not generally change over the life of the instrument. The face value is scheduled to be returned at the end payment date. GOVERNMENT BOND a debt security issued by a national government. HEDGING investment structure to reduce the volatility of price movements in an asset. SECURITIES any financial asset. YIELD the income return on an investment i.e. the interest or dividends received. Yield is usually expressed as a percentage of the value of the investment. DEVON FUNDS MANAGEMENT LIMITED 15 How to complete the Application Form. If you need help with understanding the application Regular Contributions process or the documents you need to provide, please Please complete the application form and direct debit contact us on 0800 944 049 (free call) or +649 925 form. The initial contribution should be entered as the 3990 or by email at enquiries@devonfunds.co.nz Lump Sum, with subsequent contributions entered as regular contributions. The NZ$10,000 minimum applies Investment instructions for the initial contribution and NZ$100 minimum per The Anti-Money Laundering and Countering Financing quarter for subsequent regular payments. We retain the of Terrorism Act 2009 (AML/CFT Act) came fully into right to alter these minimums at any time. force on 30 June 2013. The following application forms and requests for documentation comply with the new Please post your completed application form to: requirements, however in certain circumstances we Devon Funds Management Limited may need to collect extra information from you and P O Box 106 039 anyone who is acting on your behalf for the purposes Auckland City 1143 of the AML/CFT Act. Identification The Parliament of New Zealand enacted the AML/CFT Act 2009 for the purposes: We are required to verify your identity and your address by law. a) to detect and deter money laundering and the financing of terrorism; and If you are over 18 years, we will need certified photocopies of acceptable forms of identification to b) to maintain and enhance New Zealand’s verify your identity which will include: international reputation; and c) To contribute to public confidence in the financial system. • Current New Zealand passport; OR The AML/CFT Act applies to banks and most financial institutions, and it is essential that we comply. • Current international passport; OR Sometimes this may mean that we won’t be able to • New Zealand firearms licence; OR complete your investment instructions or meet your • New Zealand driver’s licence or international needs until all of the necessary information is obtained. driver’s permit PLUS one of the following: We are committed to protecting the privacy of your – New Zealand birth certificate; OR information and we will continue to ensure all identity – Overseas birth certificate; OR and other personal information you provide will be used and managed in accordance with the Privacy Act 1993. – New Zealand certificate of citizenship; OR – Certificate of citizenship issued by a foreign If you have any questions or concerns in respect of the Government; OR new requirements under the AML/CFT Act please feel free to contact us. – Current credit card, debit card, or eftpos card signed by you and issued by a registered New Zealand bank Lump Sum and a bank statement issued by a registered New If you are an existing client, please supply your account Zealand bank dated within the previous 12 months name and Unit Holder number as a reference when (New Zealand driver’s licence only). crediting funds. To invest, complete, sign and return the application form attached to this Product Disclosure Statement. You can pay by: • Direct credit (from a New Zealand registered bank only) to the following account: 02-0192-0455631-00 in the name of ‘The New Zealand Guardian Trust Company Limited O/A Devon Funds Management Limited’. We will not be held liable for insufficiently referenced payments. Cash will not be accepted. 16 DEVON FUNDS MANAGEMENT LIMITED Investor Complete Individual Form 1 Trusts Form 1 and Form 2 Companies, Sole Traders, Partnerships, Limited Partnerships and Co-Operatives Form 1 and Form 3 Address verification If you are aged 16 or 17 years and you are married, in a de facto relationship or a civil union, then you will be To verify your address, certified photocopies of required to sign the Application Form. We do not need acceptable documents which set out your name and your parent/guardian to provide identification or to sign current address and are dated within the previous six the Application Form, but we will need you to provide a months include: copy of your marriage or civil union licence (or proof of • Power or home phone bill; OR the de facto relationship). • Rates bill; OR • Bank account statements; OR Certification of documents • IRD statements; OR We will accept photocopied documents certified by • Car registration documents. someone who is over 16 years of ages and is one of the following: Identification of a minor • Commonwealth representative (as defined in the If you are under 18 years of age, we will require identity Oaths and Declarations Act 1957); OR verification for both you and your parent(s)/guardian(s). • An employee of the Police who holds the office of If you are aged 15 or under, both parents/all legal constable (as defined in section 4 of the Policing guardians will be required to sign the Application Form Act 2008); OR on your behalf and provide proof of their identity. You will • Justice of the peace; OR also be required to provide proof of your identity. This • Registered medical doctor; OR means you will need to provide a certified photocopy of • Kaumātua; OR documents that contain the following information: • Registered teacher; OR • Your identity and address. This document must set • Minister of religion; OR out the minor’s name and current address and be dated within the previous six months (for example a • Lawyer (as defined in the Lawyers and bank statement); AND Conveyancers Act 2006); OR • Both of your parents/all of your guardians identity • Notary public; OR and address. These documents must set out your • New Zealand Honorary consul; OR parents/guardians names and current address(es) • Member of Parliament; OR and be dated within the previous six months and • Chartered accountant (within the meaning could include: of section 19 of the New Zealand Institute of – Bank statement; OR Chartered Accountants Act 1996). – Power or home phone bill; OR The person certifying your document must not be: – Rates bill; OR • related to you; for example, your parent, child, – IRD statement; OR brother, sister, aunt, uncle or cousin; OR – Car registration documents. • your spouse or partner; OR • PLUS proof of guardianship which can include: • a person who lives at the same address as you. – Your birth certificate; OR If sufficient identification and address verification is not provided your application will be rejected and your – Guardianship order; OR payment returned. Payments returned to investors will – Deceased parents death certificate and a will not be eligible to accrue any interest. appointing these people as your guardian; OR – If all of the above is not possible, a statutory Distribution instructions declaration confirming that these people are Please mark the distribution method. If no choice is your guardians. made, distributions will be automatically re-invested. If you are aged 16 or 17 years, your will be required to sign the Application Form and provide proof of your Your bank account and branch number may be found identity and address. One parent/guardian will also be on your bank statement. required to sign the Application Form and provide proof of identity and address. DEVON FUNDS MANAGEMENT LIMITED 17 Application Form checklist. Have you: F Copy of resident withholding tax exemption certificate (if applicable). F Completed all of your contact details. F Completed Form 1 and Form 3. F Provided your nominated bank account details. F Signed and dated the signature declaration section. Partnership Account F If paying by direct credit, please send funds F Original or original certified bank encoded deposit electronically to: The New Zealand Guardian slip, bank statement or confirmation from your Trust Company Limited O/A Devon Funds bank verifying the account name and number. Management account number 02-0192- 0455631-00 F Certified forms of identification and address verification for Partner. F Completed your Prescribed Investor Rate. F Original certified copy of Partnership Deed. F Provided your proof of identification together with other documentation as outlined below. F Copy of resident withholding tax exemption certificate (if applicable). Documentation checklist F Completed Form 1 and Form 3. Please use this checklist to ensure you provide the correct documentation with your application form. Refer Trust Account to ‘How to complete the application form’ on page 17 for F Original or original certified bank encoded deposit acceptable forms of identification. slip, bank statement or confirmation from your bank verifying the account name and number. Individual or Joint Account F Certified forms of identification and address F Original or original certified bank encoded deposit verification for each Trustee. slip, bank statement or confirmation from your bank verifying the account name and number. F Copy of resident withholding tax exemption certificate (if applicable). F Certified forms of identification and address verification for each applicant. F Certified copy of Trust Deed and all amendments. F Original certified Power of Attorney and Certificate F Completed Form 1 and Form 2. of Non-revocation (applicable if your Authorised Representative has been granted authority by virtue Estate Account of a Power of Attorney). F Original or original certified bank encoded deposit F Copy of resident withholding tax exemption slip, bank statement or confirmation from your bank certificate (if applicable). verifying the account name and number. F Completed Form 1. F Certified forms of identification and address verification for each executor. Company Account F Original certified copy of Probate. F Original or original certified bank encoded deposit F Copy of resident withholding tax exemption certificate slip, bank statement or confirmation from your (if applicable). bank verifying the account name and number. F Completed Form 1. F Certified forms of identification and address verification for each Company Director/Authorised Representative. F Copy of authority to act. F Copy of the Certificate of Incorporation. 18 DEVON FUNDS MANAGEMENT LIMITED 2 April 2026 Devon Investment Funds Need assistance? Application All Applicants Form 1 (FORM 1: PAGE 1 OF 4) Free call 0800 944 049 This is an application to invest in: Single lump sum investment Regular investment Regular investment (please tick appropriate boxes) (minimum $10,000) amount Start date Devon Alpha Fund $ $ 20 MM YYYY Devon Australian Fund $ $ 20 MM YYYY Devon Diversified Income Fund $ $ 20 MM YYYY Devon Dividend Yield Fund $ $ 20 MM YYYY Devon Global Impact Bond Fund $ $ 20 MM YYYY Devon Global Sustainability Fund $ $ 20 MM YYYY Devon Sustainability Fund $ $ 20 MM YYYY Devon Trans-Tasman Fund $ $ 20 MM YYYY Existing Devon Customer No Yes (Please provide your investor number) What is the nature and purpose of the investment, for example, income generation, capital gain or retirement savings? 1. Investor details COMPANY NAME PIR Rate 0% 10.5% 17.5% 28% (Please complete Form 3) (tick one) (Please list names of Directors in Form 3) Company IRD number TRUST NAME PIR Rate 0% 10.5% 17.5% 28% (Please complete Form 2) (tick one) (Please list names of Trustees in Form 2) Trust IRD number Does the entity have any controlling persons? No Yes (If yes, details of the controlling person must be provided in Form 2 and/or 3) Companies, Sole Traders, Partnerships, Limited Partnerships, Co-Operatives and Trusts please go to Form 1 section 2. INDIVIDUAL 1 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: Occupation PIR Rate (Please tick one) 10.5% 17.5% 28% Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation Source of Funds/Wealth. Please tell us the original source of the funds/wealth you are investing with us. Property sale Gift/Inheritance Business activity Accumulated savings Personal income Other (describe below) Please provide details include dates and amounts. For example, sale of family home at address for amount on date. Note we may need proof or additional information to support your application. DEVON FUNDS MANAGEMENT LIMITED 19 2 April 2026 Application All Applicants Form 1 (FORM 1: PAGE 2 OF 4) 1. Investor details (continued) INDIVIDUAL 2 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: Occupation PIR Rate (Please tick one) 10.5% 17.5% 28% Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation Source of Funds/Wealth. Please tell us the original source of the funds/wealth you are investing with us. Property sale Gift/Inheritance Business activity Accumulated savings Personal income Other (describe below) Please provide details include dates and amounts. For example, sale of family home at address for amount on date. Note we may need proof or additional information to support your application. INDIVIDUAL 3 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: Occupation PIR Rate (Please tick one) 10.5% 17.5% 28% Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation Source of Funds/Wealth. Please tell us the original source of the funds/wealth you are investing with us. Property sale Gift/Inheritance Business activity Accumulated savings Personal income Other (describe below) Please provide details include dates and amounts. For example, sale of family home at address for amount on date. Note we may need proof or additional information to support your application. 20 DEVON FUNDS MANAGEMENT LIMITED 2 April 2026 Application All Applicants Form 1 (FORM 1: PAGE 3 OF 4) 2. Postal address Please tick this box if your address for service is through your advisor. Name Postal address Postcode Home phone ( ) Work phone ( ) Mobile phone Email address NB: By signing this application you agree to receive all communication from Devon Funds via email Please tick if you would like to receive communications via the post instead of email 3. Advisor details Name Company Postal address Postcode Work phone ( ) Mobile phone Email address 4. Nominated Bank Account This bank account will be used for distributions and/or redemptions. Name of bank Bank branch Account name with bank Account number - - - NB: Funds can only be paid to a New Zealand bank account DISTRIBUTION INSTRUCTIONS Reinvest distributions in additional units OR Direct credit to nominated account 5. Authorised Person / Investment on behalf of a minor Physical Address Title First names Surname Date of birth DD/MM/YYYY Relationship to Applicant Country of Residence IRD number PIR Rate (Please tick one) 10.5% 17.5% 28% Company name Company number (if applicable) (if applicable) Home phone ( ) Work phone ( ) Mobile phone Email address Evidence of (Please refer to page 17 Identity provided for our requirements) Signature of authorised person SIGN HERE Date signed DD/MM/YYYY DEVON FUNDS MANAGEMENT LIMITED 21 2 April 2026 Application All Applicants Form 1 (FORM 1: PAGE 4 OF 4) The Privacy Act This statement relates to the personal information that you are providing to the Manager by way of the application and any subsequent personal information which you may provide in the future. The personal information you have supplied may be used by the Manager and the Supervisor (and related entities thereof) for the purposes of enabling the Manager to arrange and manage your investment, and to contact you in relation to your investment. The manager will provide you (on request) with the name and address of any entity to which information has been disclosed. You have the right to access all personal information held about you by the Manager. If any of the information is incorrect, you have the right to have it corrected. You acknowledge that you are authorised to provide personal information on behalf of the applicant and evidence of this authority is provided (in the case of a parent/guardian/other providing information about the applicant). You agree that your/each of your names and addresses may be used by Devon Funds Management Limited to provide you with newsletters and other information about the Fund(s) and other products and services. 6. Declarations I/We have read and retained a copy of the attached Product Disclosure Statement and agree to be bound by the terms and conditions of the Trust Deed. I/We agree to the terms outlined above in relation to the Privacy Act and the supply of personal information. I/We understand that the Fund(s) is a vehicle for long term investment and as the Fund(s) invests in shares, the value of my/our investment is liable to fluctuations and may rise and fall from time to time. I/We understand the manner in which the fees will be deducted from my/our investment. This Product Disclosure Statement and the offer of securities has been made to me/us in New Zealand. I/We declare that the information provided on these documents is true and accurate. I/We understand and authorise Devon Funds Management Limited to disclose personal information of the signatories below for the purposes of FATCA compliance including complying with requests from regulatory authorities or as otherwise required by law. I /We understand and acknowledge that Devon may be required to obtain further information from me for the purposes of disclosure for FATCA compliance. This does not affect your statutory rights as per the privacy statement contained within application form 1 in the Devon Investment Funds Product Disclosure Statement. If I/We are signing as a trustee, we warrant that, at the time of signing, I/We are authorised under the relevant Trust Deed to provide the requested information. I/We will provide Devon Funds Management Ltd with further information if there is a change in circumstances which renders the above certification incorrect or unreliable. I/We declare that the information provided on this/these documents is true and accurate. I/We understand and authorise Devon Funds Management Limited to disclose personal information of the signatories below for the purposes of CRS compliance including complying with requests from regulatory authorities or as otherwise required by law. I /We understand and acknowledge that Devon may be required to obtain further information from me for the purposes of disclosure for CRS compliance. This does not affect your statutory rights as per the privacy statement above. If I/We are signing as a trustee, we warrant that, at the time of signing, I/We are authorised under the relevant Trust Deed to provide the requested information. I/We will provide Devon Funds Management Ltd with further information if there is a change in circumstances which renders the above certification incorrect or unreliable. I/We consent to Devon providing any information relating to the entity/individual’s CRS status or CRS matters to the New Zealand Inland Revenue Department. For the purpose of verifying my identity, I consent to the personal information that I have provided being used by Devon and Apex Group Limited (the Administration Manager) with (and, where necessary, disclosed to) the following sources for: New Zealand ID verification – (1) the NZTA for the purpose of checking the Driver Licence and MOTO databases; (2) the Department of Internal Affairs for the purpose of checking the Passport, Birth Certificate and Citizen Certificate databases; (3) Land Information New Zealand; (4) the Companies Office; (5) Centrix Group Limited and APLY Limited (and I authorise Centrix and APLY to use any information that they hold in their credit reporting bureau about me to compare the information that I have provided); and (6) the White Pages. Australian ID verification – (1) the Document Verification System (DVS) for the purpose of checking the Driver Licence, Passport, Medicare Card, Birth Certificate, Certificate of Registration by Descent, Citizenship Certificate, ImmiCard, Marriage Certificate and Visa databases; and (2) Centrix Group Limited and APLY Limited (and I authorise Centrix and APLY to use any information that they hold in their credit reporting bureau about me to compare the information that I have provided). Signature of applicant, trustee or director SIGN HERE Date signed DD/MM/YYYY Signature of applicant, trustee or director SIGN HERE Date signed DD/MM/YYYY Signature of applicant, trustee or director SIGN HERE Date signed DD/MM/YYYY Signature of applicant, trustee or director SIGN HERE Date signed DD/MM/YYYY Signature of applicant, trustee or director SIGN HERE Date signed DD/MM/YYYY Signature of applicant, trustee or director SIGN HERE Date signed DD/MM/YYYY Please mail this Application Form and other relevant documentation to: Devon Funds Management Ltd, P O Box 106 039, Auckland City 1143 Trusts, please complete Form 2 accompanying this application. Companies, Sole Traders, Partnerships, Limited Partnerships and Co-Operatives, please complete Form 3 accompanying this application. 22 DEVON FUNDS MANAGEMENT LIMITED 2 April 2026 Devon Funds Need assistance? Trust Certificate Form 2 (FORM 2: PAGE 1 OF 4) Free call 0800 944 049 Trust details Full name of Trust Address of Trust Postcode Country where Trust was established Type of Trust (eg. family, unit, charitable, estate) Date of establishment DD/MM/YYYY Is the Trust a registered US entity? No Yes Please list all countries the entity is a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where the entity is tax resident does not issue a TIN to its residents. Reason B: The entity has not been issued a TIN by country of tax residence (please include an explanation as to why a TIN was not issued to the entity in the table below). Reason C: The domestic law of the country where the entity is a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation ENTITY CLASSIFICATION For more inofrmation, please refer to the OECD website, the IRD or consult your tax advisor. Is the entity a Financial Institution? No, the entity is not a financial Institution Yes, the entity is a Financial Institution Please select which type of Financial Institution from the options below: The entity is a Depository Institution The entity is a Custodial Institution The entity is a Specified Insurance Company The entity is an Investment Entity Is the Investment Entity managed by anaother Financial Institution? Yes No If the Financial Institution has a Global Intermediary Identification Number (GIIN) please provide it below: If a GIIN is not available please indicate the reason: The entity is a Deemed Compliant Financial Institution The entity is an Exempt Beneficial Owner Other (please provide more detail): Is the entity’s primary business activity selling goods or services or is it a non-profit entity? Select ‘Yes’ if either: • The entity earns or intends to earn 50% or more of its total income from trading activities; and 50% or more of the entity’s assets produce or are held for producing trading income; OR • The entity is a non-profit entity and exempt from income tax in its country/jurisdiction of residence. Yes No Work phone ( ) Mobile phone Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Source of Funds/Wealth. Please tell us the original source of the funds/wealth you are investing with us. You will need to provide documents to support this, such as sales and purchase agreement, wills/probates, documents relating to gifting, business financials, payslips etc. Property sale Gift/Inheritance Business activity Accumulated savings Personal income Other (describe below) Please provide details include dates and amounts. For example, sale of family home at address for amount on date. Note we may need proof or additional information to support your application. DEVON FUNDS MANAGEMENT LIMITED 23 2 April 20265 Trust Certificate Form 2 (FORM 2: PAGE 2 OF 4) Trustees and beneficial ownership continued INDIVIDUAL 1 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: (Please (Please Independent Effective Beneficial Occupation PIR Rate tick one) 10.5% 17.5% 28% tick one) Trustee control owner Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation INDIVIDUAL 2 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: (Please (Please Independent Effective Beneficial Occupation PIR Rate tick one) 10.5% 17.5% 28% tick one) Trustee control owner Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation INDIVIDUAL 3 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: (Please (Please Independent Effective Beneficial Occupation PIR Rate tick one) 10.5% 17.5% 28% tick one) Trustee control owner Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation 24 DEVON FUNDS MANAGEMENT LIMITED 2 April 2026 Trust Certificate Form 2 (FORM 2: PAGE 3 OF 4) Trustees and beneficial ownership continued INDIVIDUAL 4 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: (Please (Please Independent Effective Beneficial Occupation PIR Rate tick one) 10.5% 17.5% 28% tick one) Trustee control owner Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation INDIVIDUAL 5 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: (Please (Please Independent Effective Beneficial Occupation PIR Rate tick one) 10.5% 17.5% 28% tick one) Trustee control owner Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation INDIVIDUAL 6 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: (Please (Please Independent Effective Beneficial Occupation PIR Rate tick one) 10.5% 17.5% 28% tick one) Trustee control owner Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation Continued on following page. DEVON FUNDS MANAGEMENT LIMITED 25 2 April 2026 Trust Certificate Form 2 (FORM 2: PAGE 4 OF 4) Declaration I/We, the Trustees of the above named Trust, properly constituted by a Trust Deed, do hereby solemnly acknowledge and certify that: 1. Current Trustees Each of the above named Trustees is a current and validly appointed Trustee of the Trust and there are no other trustee(s) of the Trust. 2. Power to Transact The Trustees have the power to apply to invest in the Fund/s and to enter into any related documentation. 3. Trustee Resolutions All trustee resolutions and approvals required by law and necessary pursuant to the above mentioned Trust Deed have been passed or given to enable the Trustees to invest in the Fund/s on behalf of the Trust. 4. Trustee Compliance The Trustee(s) in approving any transactions have acted in compliance with the duties imposed on the Trustee(s) at law. 5. Alteration to Trustees, Trustee Power and Trust Deed Where there is any alteration to the Trustee(s) named above or any change to the Trust Deed or any trustee power the Trustee(s) will notify Devon in writing immediately and forward a new Trustee Certificate with required identification documentation. 6. Validity of Transactions The investment instructions provided by the Trustees are binding on the Trustees, and the terms and conditions of investing in the Fund/s any related documentation reenforceable against the Trustees. 7. Execution of Documents The Application Form, Trust Certificate and Direct Debit Authority (if applicable) have been properly signed by the Trustees. 8. No Invalidity There are no circumstances, which would invalidate any of the transactions or the Application Form, Trust Certificate and Direct Debit form. Signature of Date signed Signature of Date signed SIGN HERE SIGN HERE 1st trustee DD/MM/YYYY 2nd trustee DD/MM/YYYY Signature of Date signed Signature of Date signed SIGN HERE SIGN HERE 3rd trustee DD/MM/YYYY 4th trustee DD/MM/YYYY Signature of Date signed Signature of Date signed SIGN HERE SIGN HERE 5th trustee DD/MM/YYYY 6th trustee DD/MM/YYYY Please mail this Trust Certificate and other relevant documentation to: Devon Funds Management Ltd, P O Box 106 039, Auckland City 1143 26 DEVON FUNDS MANAGEMENT LIMITED 2 April 2026 Devon Funds Companies, Sole Traders, Partnerships, Limited Partnerships Need assistance? and Co-operatives Form 3 (FORM 3: PAGE 1 OF 4) Free call 0800 944 049 Details 1. Name of entity 2. Trading name (if different) 3. Company number (if applicable) 4. Is the company: A company that is listed on an exchange registered under Subpart 6 of Part 5 of the Financial Markets Conduct Act 2013 A government department named in Schedule 1 of the State Sector Act 1988* A local authority as defined in Section 5 of the local Government Act 2002* The New Zealand Police* The New Zealand Security Intelligence Service* No If you ticked YES to any of the above please go to question 12. * Supporting documentation required. If you ticked NO, please go to question 5. 5. Principle business address Postal address Postcode Registered office (if different) Postcode 6. Phone ( ) 7. Email 7. Date of establishment DD/MM/YYYY 9. Jurisdiction of establishment 8. Entities business and industry of operation (please be as specific as possible) 9. Source of Funds/Wealth. Please tell us the original source of the funds/wealth you are investing with us. Property sale Gift/Inheritance Business activity Accumulated savings Personal income Other (describe below) Please provide details include dates and amounts. For example, sale of family home at address for amount on date. Note we may need proof or additional information to support your application. 10. Please list all countries the entity is a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where the entity is tax resident does not issue a TIN to its residents. Reason B: The entity has not been issued a TIN by country of tax residence (please include an explanation as to why a TIN was not issued to the entity in the table below). Reason C: The domestic law of the country where the entity is a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation Continued on following page. DEVON FUNDS MANAGEMENT LIMITED 27 2 April 2026 Companies, Sole Traders, Partnerships, Limited Partnerships and Co-operatives Form 3 (FORM 3: PAGE 2 OF 4) Details continued ENTITY CLASSIFICATION For more information, please refer to the OECD website, the IRD or consult your tax advisor. Is the entity a Financial Institution? No, the entity is not a financial Institution Yes, the entity is a Financial Institution Please select which type of Financial Institution from the options below: The entity is a Depository Institution The entity is a Custodial Institution The entity is a Specified Insurance Company The entity is an Investment Entity Is the Investment Entity managed by anaother Financial Institution? Yes No If the Financial Institution has a Global Intermediary Identification Number (GIIN) please provide it below: If a GIIN is not available please indicate the reason: The entity is a Deemed Compliant Financial Institution The entity is an Exempt Beneficial Owner Other (please provide more detail): Is the entity’s primary business activity selling goods or services or is it a non-profit entity? Select ‘Yes’ if either: • The entity earns or intends to earn 50% or more of its total income from trading activities; and 50% or more of the entity’s assets produce or are held for producing trading income; OR • The entity is a non-profit entity and exempt from income tax in its country/jurisdiction of residence. Yes No 11. Beneficial ownership. Please include any person with a direct or indirect ownership of greater than 25% AND/OR any effective controller including Directors, Partnerships, etc. within the Individual sections below. INDIVIDUAL 1 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: (Please PIR Rate tick (Please Effective Beneficial Occupation one) 10.5% 17.5% 28% tick one) Director control owner Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation 28 DEVON FUNDS MANAGEMENT LIMITED 2 April 2026 Companies, Sole Traders, Partnerships, Limited Partnerships and Co-operatives Form 3 (FORM 3: PAGE 3 OF 4) INDIVIDUAL 2 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: (Please PIR Rate tick (Please Effective Beneficial Occupation one) 10.5% 17.5% 28% tick one) Director control owner Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation INDIVIDUAL 3 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: (Please PIR Rate tick (Please Effective Beneficial Occupation one) 10.5% 17.5% 28% tick one) Director control owner Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation INDIVIDUAL 4 Title First names Residential Address Surname Please include any aliases / maiden names Place of Date of birth DD/MM/YYYY Country of Residence Birth: (Please PIR Rate tick (Please Effective Beneficial Occupation one) 10.5% 17.5% 28% tick one) Director control owner Home phone ( ) Work phone ( ) Mobile phone Are you a US Citizen If yes, please provide your IRD number No Yes or Tax Resident? Social Security Number (SSN): Email address Evidence of identity (Please refer to page 17 and address provided for our requirements) Please list all countries where you are a tax resident. For each country, except New Zealand, you will need to provide a Tax ID Number (TIN) or equivalent in the table below. If a TIN is not available for that country, use the appropriate reason A, B or C. Reason A: The country where I am a tax resident does not issue a TIN to its residents. Reason B: I have not been issued a TIN by my country of tax residence (please include an explanation as to why a TIN was not issued to you in the table below). Reason C: The domestic law of the country where I am a tax resident does not require the collection of a TIN. Country of Tax Residency Tax ID Number (TIN) Enter Reason A, B or C if no TIN is available If you have selected Reason B please provide an explanation DEVON FUNDS MANAGEMENT LIMITED 29 2 April 2026 Companies, Sole Traders, Partnerships, Limited Partnerships and Co-operatives Form 3 (FORM 3: PAGE 4 OF 4) Declaration I/We, of the above entity, do hereby solemnly acknowledge and certify that: 1. Authority I/We are authorised to apply to invest on behalf of the entity. 2. Current Representatives The Persons named above are all of the current authorised representatives of the entity. 3. Authority to invest in the Fund/s The above mentioned have the authority to invest in the Fund/s on behalf of the entity and their instructions are binding on the entity. 4. Alteration to representatives Where there is any alteration to the representatives named above or any change to the entity, the representatives warrant that they will notify Devon in writing immediately with required identification. Signature of Signature of Date signed Date signed 1st Partner/Director/ SIGN HERE 2nd Partner/Director/ SIGN HERE Authorised person DD/MM/YYYY Authorised person DD/MM/YYYY Signature of Signature of Date signed Date signed 3rd Partner/Director/ SIGN HERE 4th Partner/Director/ SIGN HERE Authorised person DD/MM/YYYY Authorised person DD/MM/YYYY Signature of Signature of Date signed Date signed 5th Partner/Director/ SIGN HERE 6th Partner/Director/ SIGN HERE Authorised person DD/MM/YYYY Authorised person DD/MM/YYYY Please mail this Trust Certificate and other relevant documentation to: Devon Funds Management Ltd, P O Box 106 039, Auckland City 1143 30 DEVON FUNDS MANAGEMENT LIMITED 2 April 2026 Devon Funds Management Limited Direct Debit Authority Client Instructions I/We acknowledge that we have a copy of the Product Disclosure Statement and agree to be bound by the terms and conditions of the Trust Deed. Name of account to be debited Unit holder number (if an existing client) Frequency Monthly Quarterly Devon Alpha Fund NZ$ Start Date 20 MM YYYY Devon Australian Fund NZ$ Start Date 20 MM YYYY Devon Diversified Income Fund NZ$ Start Date 20 MM YYYY Devon Dividend Yield Fund NZ$ Start Date 20 MM YYYY Devon Global Impact Bond Fund NZ$ Start Date 20 MM YYYY Devon Global Sustainability Fund NZ$ Start Date 20 MM YYYY Devon Sustainability Fund NZ$ Start Date 20 MM YYYY Devon Trans-Tasman Fund NZ$ Start Date 20 MM YYYY Name of account to be debited Account details Bank Branch Number Account Number Suffix Bank AUTHORITY TO ACCEPT DIRECT DEBITS Branch (Not to operate as an assignment or an agreement) Address AUTHORISATION CODE 0207638 Information to appear on my / our bank statement Payer particulars D E V O N F U N D S Payer code Payer reference Account holder I/We authorise you, until further notice in writing, to debit my/our account with you with all amounts The New Zealand Guardian Trust Company Limited O/A Devon Funds Management Ltd (hereinafter referred to as the initiator) may initiate by direct debit. I/We acknowledge and accept that the Bank accepts this authority only upon the conditions listed on this form. Name of account holder(s) Signature SIGN HERE Date signed DD/MM/YYYY Signature SIGN HERE Date signed DD/MM/YYYY Office use only Approved For Bank Use Only Date Recorded Checked received: by: by: Bank stamp 0763 04 18 Original – Retain at Branch Copy – Forward to Initiator if requested DEVON FUNDS MANAGEMENT LIMITED 31 Conditions of this authority to accept Direct Debits 1. The Initiator: 1.1 Undertakes to give notice to the Acceptor of the commencement date, frequency and amount at least 10 calendar days before the first Direct Debit is drawn (but no more than 2 calendar months). This notice will be provided in writing (including by electronic means and SMS where the Customer has provided prior written consent (by electronic means including SMS) to communicate electronically). Where the Direct Debit System is used for the collection of payments which are regular as to frequency, but variable as to amounts, the Initiator undertakes to provide the Acceptor with a schedule detailing the amount and each payment date. In the event of any subsequent change to the frequency or amount of the Direct Debits, the Initiator has agreed to give advance notice of at least 30 days before the changes comes into effect. This notice must be provided in writing (including by electronic means and SMS where the Customer has provided prior written consent (including by electronic means including SMS) to communicate electronically). 1.2 May, upon the relationship which gave rise to this Authority being terminated, give notice to the Bank that no further Direct Debits are to be initiated under the Authority. Upon receipt of such notice the Bank may terminate this Authority as to future payments by notice in writing to me/us. 2. The customer may: 2.1 At any time, terminate this Authority as to future payments by giving notice of termination to the Bank and to the Initiator by means agreed by the customer, Bank and Initiator . 2.2 Stop payment of any Direct Debit to be initiated under this authority by the Initiator by giving written notice to the Bank prior to the Direct Debit being paid by the Bank. 2.3 Where a variation to the amount agreed between the Initiator and the customer from time to time to be Direct Debited has been made without notice being given in terms of clause 1.1 above, request the Bank to reverse or alter any such Direct Debit initiated by the Initiator by debiting the amount of the reversal or alteration of a Direct Debit back to the Initiator through the Initiator’s Bank PROVIDED such request is made not more than 120 days from the date when the Direct Debit was debited to my/our account. 3. The customer acknowledges that: 3.1 This authority will remain in full force and effect in respect of all Direct Debits passed to my/our account in good faith notwithstanding my/our death, bankruptcy or other revocation of this authority until actual notice of such event is received by the Bank. 3.2 In any event this authority is subject to any arrangement now or hereafter existing between me/us and the Bank in relation to my/our account 3.3 Any dispute as to the correctness or validity of an amount debited to my/our account shall not be the concern of the Bank except in so far as the Direct Debit has not been paid in accordance with this authority. Any other dispute lies between me/us and the Initiator. 3.4 Where the Bank has used reasonable care and skill in acting in accordance with this authority, the Bank accepts no responsibility or liability in respect of:- (a) the accuracy of information about Direct Debits on Bank statements; and (b) any variations between notices given by the Initiator and the amounts of Direct Debits. 3.5 The Bank is not responsible for, or under any liability in respect of the Initiator’s failure to give notice in accordance with 1(a) nor for the non-receipt or late receipt of notice by me/us for any reason whatsoever. In any such situation the dispute lies between me/us and the Initiator 3.6 Notice given by the Initiator in terms of clause 1(a) to the debtor responsible for the payment shall be effective. Any communication necessary because the debtor responsible for payment is a person other than me/us is a matter between me/us and the debtor concerned. 4. The bank may: 4.1 In its absolute discretion conclusively determine the order of priority of payment by it of any monies pursuant to this or any other authority, cheque or draft properly signed by me/us and given to or drawn on the Bank. 4.2 At any time terminate this authority as to future payments by notice in writing to me/us. 4.3 Charge its current fees for this service in force from time to time. 32 DEVON FUNDS MANAGEMENT LIMITED For the informed investor. Devon Funds Management Limited Level 17, HSBC Tower 188 Quay Street Auckland 1010 Telephone: 0800 944 049 (free call) or +649 925 3990 enquiries@devonfunds.co.nz www.devonfunds.co.nz --- ## SIPO **Source PDF:** https://devonfunds.co.nz/sites/default/files/media-files/Devon_Investment_Funds_SIPO_2April_2026.pdf **Published:** 2026-04-02 **Pages:** 21 **Extracted via:** pdftotext on 2026-05-20 Statement of Investment Policy and Objectives (SIPO) 02.04.2026 ISSUER: DEVON FUNDS MANAGEMENT LIMITED DEVON ALPHA FUND DEVON AUSTRALIAN FUND DEVON DIVERSIFIED INCOME FUND DEVON DIVIDEND YIELD FUND DEVON GLOBAL IMPACT BOND FUND DEVON GLOBAL SUSTAINABILITY FUND DEVON SUSTAINABILITY FUND DEVON TRANS-TASMAN FUND This document gives you important information about this investment to help you decide whether you want to invest. There is other useful information about this offer on www.business.govt.nz/disclose. Devon Funds Management Limited has prepared this document in accordance with the Financial Markets Conduct Act 2013 (FMC Act). You can also seek advice from a financial advice provider to help you to make an investment decision. Contents. Introduction 3 Description of the Managed Investment Scheme (MIS) 4 Investment Philosophy 5 Investment Process 5 Investment Objectives and Strategies of our Funds 6 Investment Policies & Guidelines 14 Limit Breaks 17 Investment Performance Monitoring 17 Investment Strategy Review 18 SIPO Review and Monitoring 18 DEVON FUNDS MANAGEMENT LIMITED 1 Welcome to Devon Funds Management. Manager of the Devon Investment Funds Dear Investor Devon is an investment management business that specialises in building investment portfolios for our clients. Our highly qualified and experienced investment team is committed to helping our clients achieve their investment objectives. We believe our advantage lies in our people – a dedicated team of investment professionals with many years’ experience in the investment industry, both within Australasia and further afield. We’ve worked hard to assemble the right talent with the necessary skills and experience to manage our clients’ portfolios. It is the policy of Devon that investment staff can only invest in Australasian equities via the Devon Funds, ensuring our investment team’s decisions and our clients’ interests are aligned. We manage money on behalf of a diverse range of leading New Zealand clients, including large superannuation schemes, Community Trusts, charities, KiwiSaver schemes, Iwi, corporate pension schemes and individual investors. Our Values We appreciate that you have entrusted your hard earned wealth to us and take our fiduciary duty owed to you, as our client, very seriously. We believe that, on your behalf, we have an obligation to ensure that the businesses we invest in conduct themselves in accordance with the highest governance standards. Where these standards are not being demonstrated we will actively engage with the company to seek improvement. In our view, better returns can be achieved if the businesses we invest in are good corporate citizens who look after the interests of all stakeholders and operate in a sustainable manner. We are a signatory to the United Nations supported Principles for Responsible Investment (PRI). The PRI provides global principles and a framework to help us integrate the consideration of Environmental, Social and Governance (ESG) issues into our investment decision-making and portfolio construction framework. As part of this process we report annually to the PRI on our adherence to these policies. We are also a member of the Responsible Investment Association of Australasia (RIAA) and a founding member of the New Zealand Corporate Governance Forum which has been established to promote globally recognised governance standards in New Zealand. We are proud of what we have achieved at Devon in creating a leading investment management business and thank you for considering us as part of your wealth solution. Regards, Josh Wilson Chief Executive Officer, Devon Funds Management 2 DEVON FUNDS MANAGEMENT LIMITED Introduction. What is a SIPO? A Statement of Investment Policy and Objectives (SIPO) is a document that sets out the investment governance and management framework, philosophy, strategies and objectives of a Managed Investment Scheme and its investment funds. The most current version of the SIPO is available on the schemes register at www.business.govt.nz/disclose/ or at www.devonfunds.co.nz. Purpose of this SIPO This SIPO applies to the Devon Investment Funds Scheme (the Scheme) and plays an important role in ensuring the effectiveness of the overall accountability framework for the Scheme. It does this by clearly articulating the objectives and parameters of the Scheme and by being publically available, it allows better transparency for our stakeholders. The investment options offered under this SIPO are listed in the Description of Managed Investment Scheme (MIS) section on page 3. Effective date The effective date of this SIPO is 2 April 2026, replacing the SIPO dated 10 December 2024, and will be reviewed in accordance with our SIPO Review and Monitoring framework on page 16. Defined terms Devon Funds Management Limited is the Manager of the Devon Investment Funds and is referred to as “Devon”, “we”, “us” or “our” in this Document. Capitalised words that appear in this Document have the same meaning as given to them in the Devon offer documents, unless they are otherwise defined. Any reference to “you” or “your” refers to a person or entity who invests in a Fund. DEVON FUNDS MANAGEMENT LIMITED 3 Description of the Managed Investment Scheme (MIS) Our Family of Funds Devon Funds Management offer a range of Funds under this Managed Investment Scheme, which are designed to meet different investor needs. One aspect that all of our Funds have in common is our commitment to seeking out the best returns available in a careful and considered way. DEVON DEVON DEVON DEVON ALPHA AUSTRALIAN DIVERSIFIED DIVIDEND YIELD FUND FUND INCOME FUND FUND DEVON GLOBAL DEVON GLOBAL DEVON DEVON TRANS- IMPACT BOND SUSTAINABILITY SUSTAINABILITY TASMAN FUND FUND FUND FUND The Devon Alpha Fund, Devon Australian Fund, Devon Diversified Income Fund, Devon Dividend Yield Fund, Devon Global Impact Bond Fund, Devon Global Sustainability Fund, Devon Sustainability Fund and Devon Trans-Tasman Fund, collectively known as the Devon Investment Funds (the Funds) are unit trust funds managed by Devon. A unit trust fund is an investment that pools your money with other unit holders. We then apply the pooled money to buy investments under the oversight of the Supervisor. Your investment is the units of the unit trust fund that you subscribe for (your unit holding). Benefits of investing in our Managed Investment Scheme • Professional Management: Employing the expertise and resources of a professional manager may be beneficial if you do not have the time or skill to manage your own investments. • Diversification: By pooling together large amounts of money, we are able to invest in a portfolio of securities which allows for diversification with the aim of reducing the risk of your investment. It also provides access to markets and securities that might otherwise be out of reach. • Administrative Simplicity: Our Funds are Portfolio Investment Entities (PIEs). PIEs offer significant advantages from an administrative perspective. We take care of the paperwork involved in buying and selling securities, managing your dividends, interest, corporate actions, reporting and record keeping. • Tax Advantages: Our Funds are all PIEs for tax purposes, meaning that if you are a New Zealand resident unit holder and have supplied us with the correct PIR, tax is usually paid on your behalf at a rate approximating your marginal tax rate and there is no further tax to pay. PIE tax is capped at 28% which can be a benefit for 33% tax rate investors. 4 DEVON FUNDS MANAGEMENT LIMITED Investment philosophy. Investment Philosophy Our Investment Philosophy has been tested over many years and throughout all types of market conditions. In summary our approach to investing is to: • Take a long-term view; • Be active investors; • Bring a disciplined approach to risk management; and • Do our own research. Guided by this philosophy, we employ a rigorous and proven investment process designed to identify the best opportunities for investment and to ‘add value’ in a consistent manner for our clients. Investment process. Research We filter and identify investment opportunities through detailed industry and company analysis. Our investment decisions are based on independent sources of information. Regular access to executive management and industry contacts are an integral part of our investment process. We use research models to value each company we wish to invest in, subjecting them to rigorous analysis by focusing on their earnings, capital structure, free cash flow generation and growth prospects. Peer Review Our investment team conducts a review of each business to assess its industry structure, management quality, governance structures, competitive position and growth plans. Peer reviews are then conducted to ensure we use the full experience of our team to identify what we believe are the best possible investment opportunities. Portfolio Construction An important part of our process is our formal Investment Committee Meeting. Within this forum the investment team discuss new investment ideas, review existing holdings and conduct a thorough review of the risks facing our investments. This process is also integral to the construction of our portfolios with the best of those opportunities identified in the research process being included in the Funds. The key factors we take into account in building the Funds or portfolios are valuation, our assessment of the business, its risk characteristics, liquidity, our views on the economy and the identification of a catalyst to generate performance. The Funds are then constructed in accordance with their investment guidelines. Where required, we may seek independent specialist advice services to advise on specific asset classes. In these instances, we retain the ultimate decision making authority. Please refer to the objectives and strategies for the Diversified Income Fund on page 8 for more information. DEVON FUNDS MANAGEMENT LIMITED 5 Investment objectives and DEVON ALPHA FUND strategies of our Funds. Benchmark Official Cash Rate (OCR) +5% Investment Objective The Fund aims to generate capital growth over the long term by actively investing in a concentrated portfolio of New Zealand and Australian shares and holding cash when appropriate investment opportunities cannot be identified. Performance is measured in accordance with the Investment Performance Monitoring framework on page 15. Strategy The Fund invests in a concentrated portfolio of approximately 10-15 select companies listed on the New Zealand and Australian share markets. The Fund does not follow an equity index and is actively managed, which means that we make our own investment decisions rather than have the Fund passively follow an index. When appropriate investment opportunities cannot be identified, the Fund may hold cash or cash equivalent securities. The Fund aims to generate capital growth over the long term. The Fund is able to hold shares listed outside of Australasia and to short-sell shares (sell shares without owning them, on the expectation that prices will fall and could be purchased later for a lesser price). Investment limits 0-100% New Zealand shares (Australasian Equities) 0-100% Australian shares (Australasian Equities) 0-100% Cash, or cash equivalent securities. Target Asset Allocation 0-100% Australasian equities 0-100% Cash, or cash equivalent securities. Currency hedging The Fund has the ability to hedge its foreign currency exposure in a range from 0-100%. The Fund is typically hedged in accordance with our hedging policy which can be found in the Investment Policies and Guidelines section. Distributions The Fund pays distributions 6-monthly at our discretion. Authorised Investments* The authorised investments of the Alpha Fund are: • Equity and equity-like listed and unlisted securities including ordinary, preference and partly paid shares, convertible securities, warrants and options; • Derivatives; • Cash and bonds; • Pooled or unlisted funds investing in similar securities to those set out above; and • Any other investment permitted by the Supervisor from time to time. The Fund may short sell securities and utilise active currency management. *If we believe that it is in the best interests of our unit holders to vary the authorised investments either by excluding an investment, or adding any investment we may do so. Material changes are subject to certain procedural matters set out in the Trust Deed including notifying all unit holders and agreeing those changes with the Supervisor. We have absolute discretion under the Trust Deed to manage the investments within the guidelines set out in the Deed of Establishment and in this SIPO. 6 DEVON FUNDS MANAGEMENT LIMITED Investment objectives and DEVON AUSTRALIAN FUND strategies of our Funds. Benchmark S&P/ASX200 (Accumulation) index in NZD Investment Objective The Fund aims to generate capital growth over the long term by actively managing Australian equity investments. Performance is measured in accordance with the Investment Performance Monitoring framework on page 15. Strategy The Fund invests in a select portfolio of companies which are primarily Australian listed companies. The Australian market offers exposure to a number of sectors that are not available in New Zealand. The Australian Fund is actively managed, which means the holdings and investment returns may differ considerably from its benchmark. While the Fund tends to be fully invested in shares, it may hold some cash or cash equivalent securities. Investment limits 80-100% Australian shares (Australasian equities) 0-20% Cash, or cash equivalent securities. Target Asset Allocation 80-100% Australasian equities 0-20% Cash, or cash equivalent securities. Currency hedging The Fund has the ability to hedge its foreign currency exposure in a range from 0-100%. The Fund is typically unhedged in accordance with our hedging policy which can be found in the Investment Policies and Guidelines section. Distributions The Fund pays distributions 6-monthly at our discretion. Authorised Investments* The authorised investments of the Australian Fund are: • Equity and equity-like listed and unlisted securities including ordinary, preference and partly paid shares, convertible securities, warrants and options; • Derivatives; • Cash and bonds; • Pooled or unlisted funds investing in similar securities to those set out above; and • Any other investment permitted by the Supervisor from time to time. The Fund may short sell securities and utilise active currency management. *If we believe that it is in the best interests of our unit holders to vary the authorised investments either by excluding an investment, or adding any investment we may do so. Material changes are subject to certain procedural matters set out in the Trust Deed including notifying all unit holders and agreeing those changes with the Supervisor. We have absolute discretion under the Trust Deed to manage the investments within the guidelines set out in the Deed of Establishment and in this SIPO. DEVON FUNDS MANAGEMENT LIMITED 7 Investment objectives and DEVON DIVERSIFIED INCOME FUND strategies of our Funds. Benchmark 75% Bloomberg New Zealand Bond Composite 0-5 Year Index and 25% 50:50 composite of the S&P/NZX50 (Gross) Index and the S&P/ASX200 (Accumulation) Index fully hedged to NZD. Investment Objective The Fund aims to give investors access to a diverse and carefully selected portfolio of high yielding investments and aims to outperform its benchmark on a rolling 12-month basis. Performance is measured in accordance with the Investment Performance Monitoring framework on page 15. Strategy The Fund invests in a carefully selected portfolio of government and corporate bonds, cash, listed property, infrastructure and utility companies, high yielding equities, credit securities and other yielding financial assets. We utilise our expertise in Australasian equities either directly or through our Managed Investment Schemes. We employ the specialist services of the JBWere Fixed Interest team to advise on fixed interest security selection and aid in portfolio construction. We have control over this investment process. Investment limits 0-100% Fixed Interest securities 0-40% Listed equities (Australasian equities) 0-100% Cash or cash equivalent securities 0-10% High Yield Credit (Other). Target Asset Allocation 0-100% New Zealand fixed interest 0-40% Australasian equities 0-100% Cash or cash equivalent securities 0-10% Other. Currency hedging The Fund has the ability to hedge its foreign currency exposure in a range from 0-100%. The Fund is typically hedged in accordance with our hedging policy which can be found in the Investment Policies and Guidelines section. Distributions The Fund pays distributions quarterly at our discretion. Authorised Investments* The authorised investments of the Diversified Income Fund are: • Equity and equity-like listed and unlisted securities including ordinary, preference and partly paid shares, convertible securities, warrants and options; • New Zealand or overseas: cash, term deposits, bank bills, bonds, or other interest bearing securities; • Exchange Traded Funds; • Credit products; • Pooled or unlisted funds investing in similar securities to those set out above; • Derivatives; and • Any other investment permitted by the Supervisor from time to time. The Fund may utilise active currency management. *If we believe that it is in the best interests of our unit holders to vary the authorised investments either by excluding an investment, or adding any investment we may do so. Material changes are subject to certain procedural matters set out in the Trust Deed including notifying all unit holders and agreeing those changes with the Supervisor. We have absolute discretion under the Trust Deed to manage the investments within the guidelines set out in the Deed of Establishment and in this SIPO. We engage the specialist services of the JBWere (NZ) PTY Ltd (JBWere) Fixed Interest team to advise on fixed interest security selection and aid in portfolio construction for the fixed interest portion of the Diversified Income Fund. While we retain the ultimate decision making authority, we will generally implement the advice of JBWere. 8 DEVON FUNDS MANAGEMENT LIMITED Investment objectives and DEVON DIVIDEND YIELD FUND strategies of our Funds. Benchmark Trans-Tasman Equity Index hedged, which is a 50:50 composite of the S&P/NZX50 (Gross) index and the S&P/ASX200 (Accumulation) Index fully hedged to NZD. A 50:50 composite means 50% of the S&P/NZX50 (Gross) and 50% of the S&P/ASX200 (Accumulation) Index. Investment Objective The Fund invests in a well-researched portfolio of shares with the objective of generating an above market average dividend yield while providing some growth to maintain capital value in real terms. Performance is measured in accordance with the Investment Performance Monitoring framework on page 15. Strategy The Fund invests in a select portfolio of New Zealand and Australian listed equity securities chosen for their attractive dividend yields, with some growth prospects to maintain the dividend yield and capital value in real terms. The Dividend Yield Fund is actively managed, which means the holdings and investment returns may differ considerably from its benchmark. Investment limits 0-100% New Zealand shares (Australasian equities) 0-100% Australian shares (Australasian equities) 0-10% Cash or cash equivalent securities. Target Asset Allocation 90-100% Australasian equities 0-10% Cash, or cash equivalent securities. Currency hedging The Fund has the ability to hedge its foreign currency exposure in a range from 0-100%. The Fund is typically hedged in accordance with our hedging policy which can be found in the Investment Policies and Guidelines section. Distributions The Fund pays distributions quarterly at our discretion. Authorised investments* The authorised investments of the Dividend Yield Fund are: • Equity and equity-like listed and unlisted securities including ordinary, preference and partly paid shares, convertible securities, warrants and options; • Derivatives; • Cash and bonds; • Pooled or unlisted funds investing in similar securities to those set out above; and • Any other investment permitted by the Supervisor from time to time. The Fund may utilise active currency management. *If we believe that it is in the best interests of our unit holders to vary the authorised investments either by excluding an investment, or adding any investment we may do so. Material changes are subject to certain procedural matters set out in the Trust Deed including notifying all unit holders and agreeing those changes with the Supervisor. We have absolute discretion under the Trust Deed to manage the investments within the guidelines set out in the Deed of Establishment and in this SIPO. DEVON FUNDS MANAGEMENT LIMITED 9 Investment objectives and DEVON GLOBAL IMPACT BOND FUND strategies of our Funds. Benchmark Bloomberg Global Aggregate Index in NZD, 100% hedged to NZD. Investment Objective The Fund aims to deliver long-term total returns in excess of the index by investing in a diverse portfolio of global bonds. Strategy The Fund invests into the Wellington Global Impact Bond Fund, managed by Wellington Management. Wellington Management seeks to understand the world’s social and environmental problems and to identify and invest primarily in debt issued by companies and organisations that they believe are addressing these needs in a differentiated way through their core products, services and projects. The Wellington Global Impact Bond Fund aims to improve access to, and the quality of, basic life essentials, reduce inequality and mitigate the effects of climate change. They seek to identify securities which it believes fall into three primary impact categories: life essentials, human empowerment and the environment. Within these categories the Fund will invest across “Impact Themes” including, but not limited to the following: • Life Essentials: affordable housing, clean water and sanitation, health, sustainable agriculture and nutrition. • Human Empowerment: digital divide, education and job training, financial inclusion, safety and security. • Environment: alternative energy, resource efficiency and resource stewardship While the underlying Wellington Fund tends to be fully invested in global bonds, when there are few compelling investment opportunities the Fund may hold some cash or cash equivalent securities. Investment limits 0-100% Global fixed interest and cash. (sectors/issuers: government, quasi-sovereign, agency, supranational, municipal, corporate, mortgage and securitised). 0-20% Emerging markets. Target Asset Allocation 0-100% Global fixed interest and cash. Currency hedging The Fund has the ability to hedge its foreign currency exposure in a range from 0-100%. The Fund is typically hedged in accordance with our hedging policy which can be found in the Investment Policies and Guidelines section. Distributions The Fund pays distributions quarterly at our discretion. Authorised Investments* The authorised investments of the Global Impact Bond Fund are: • Cash, cash equivalents and fixed interest; • Derivatives; and • Any other investment permitted by the Supervisor from time to time. The Fund may utilise active currency management. *If we believe that it is in the best interests of our unit holders to vary the authorised investments either by excluding an investment, or adding any investment we may do so. Material changes are subject to certain procedural matters set out in the Trust Deed including notifying all unit holders and agreeing those changes with the Supervisor. We have absolute discretion under the Trust Deed to manage the investments within the guidelines set out in the Deed of Establishment and in this SIPO. 10 DEVON FUNDS MANAGEMENT LIMITED Investment objectives and DEVON GLOBAL SUSTAINABILITY FUND strategies of our Funds. Benchmark MSCI All Country World Index in NZD, 50% hedged to NZD. Investment Objective The Fund aims to deliver long-term total returns in excess of the index by investing in a selective portfolio of global equities. Strategy The Fund invests into the Wellington Global Stewards Fund, managed by Wellington Management. Wellington Management seeks to invest in companies globally, that generate high return on capital relative to their peers, and whose management teams and boards display exemplary stewardship to sustain those returns over time. Wellington define stewardship as how companies balance the interests of all stakeholders (customers, employees, communities and the supply chain) in the pursuit of profits and how they incorporate material environmental, social and governance (ESG) risks and opportunities in their corporate strategy. The underlying Wellington Fund differentiates itself by: Long-term horizon – the intention is to hold stocks for over 10 years. The belief is the longer the holding period, the greater the potential performance benefits from superior stewardship. Highly selective – typically 35-45 stocks, only relying on their own internal ESG research. Active engagement – holding those in charge of investee companies to account and encouraging companies to commit to net zero carbon emissions by 2050 in alignment with the Paris Agreement. While the underlying Fund tends to be fully invested in global equities, when there are few compelling investment opportunities the Fund may hold some cash or cash equivalent securities. Investment limits 0-100% Global equities. 0-20% Emerging markets. 0-20% Cash or cash equivalent securities. Target Asset Allocation 90-100% Global equities. 0-10% Cash, or cash equivalent securities. Currency hedging The Fund has the ability to hedge its foreign currency exposure in a range from 0-100% The Fund is typically hedged in accordance with our hedging policy which can be found in the Investment Policies and Guidelines section. Distributions We do not make any cash distributions from the Fund. Authorised investments* The authorised investments of the Global Sustainability Fund are: • Equity and equity-like listed and unlisted securities including ordinary, preference and partly paid shares, convertible securities, warrants and options; • Derivatives; • Cash or cash equivalent securities; • Pooled or unlisted funds investing in similar securities to those set out above; and • Any other investment permitted by the Supervisor from time to time. *If we believe that it is in the best interests of our unit holders to vary the authorised investments either by excluding an investment, or adding any investment we may do so. Material changes are subject to certain procedural matters set out in the Trust Deed including notifying all unit holders and agreeing those changes with the Supervisor. We have absolute discretion under the Trust Deed to manage the investments within the guidelines set out in the Deed of Establishment and in this SIPO. DEVON FUNDS MANAGEMENT LIMITED 11 Investment objectives and DEVON SUSTAINABILITY FUND strategies of our Funds. Benchmark 50:50 composite of the S&P/NZX50 (Gross) Portfolio Index and the S&P/ASX200 (Accumulation) index hedged to NZD. Investment Objective This Fund aims to generate capital growth over the long term by actively managing your New Zealand and Australian equity investments. The Fund also aims to deliver an MSCI ESG rating greater than the MSCI ESG rating of the Benchmark. Performance is measured in accordance with the Investment Performance Monitoring framework on page 15. Strategy The Fund will look to invest in those companies that score highly on overall environmental, social and corporate governance performance. The Fund also employs an ethical screen that will exclude companies where more than 10% of business revenue is derived from the manufacture of alcohol, gambling, pornography and the exploration, extraction, refining or processing of fossil fuels1. The Fund will also employ an ethical screen that will exclude companies where any business revenue is derived from the manufacture or sale of armaments2, production and manufacture of tobacco and tobacco-based products or nicotine alternatives3, and any company involved in whaling activities or on human rights watchlists as stated by MSCI. The Fund is actively managed, which means the holdings and returns may differ considerably from its benchmark. While the Fund tends to be fully invested in shares, when there are few compelling investment opportunities the Fund may hold some cash or cash equivalent securities. Investment limits 0-100% New Zealand shares (Australasian equities) 0-100% Australian shares (Australasian equities) 0-10% Cash, or cash equivalent securities. Target Asset Allocation 90-100% Australasian equities 0-10% Cash, or cash equivalent securities. Currency hedging The Fund has the ability to hedge its foreign currency exposure in a range from 0-100%. The Fund is typically hedged in accordance with our hedging policy which can be found in the Investment Policies and Guidelines section. Distributions The Fund pays distributions 6-monthly at our discretion. Authorised Investments* The authorised investments of the Sustainability Fund are: • Equity and equity-like listed and unlisted securities including ordinary, preference and partly paid shares, convertible securities, warrants and options; • Derivatives; • Cash and bonds; • Pooled or unlisted funds investing in similar securities to those set out above; and • Any other investment permitted by the Supervisor from time to time. The Fund may short sell securities and utilise active currency management. The Fund may utilise active currency management. *If we believe that it is in the best interests of our unit holders to vary the authorised investments either by excluding an investment, or adding any investment we may do so. Material changes are subject to certain procedural matters set out in the Trust Deed including notifying all unit holders and agreeing those changes with the Supervisor. We have absolute discretion under the Trust Deed to manage the investments within the guidelines set out in the Deed of Establishment and in this SIPO. 1 For companies involved in the exploration, extraction, refining, processing, or trading of fossil fuels, this applies to companies where more than 10% of business revenue is derived from coal or oil, including unconventional oil and unconventional gas. The Fund will also exclude: • companies where more than 50% of business revenue is derived from the production of dedicated equipment or services for the fossil fuel sector. • companies where more than 10% of business revenue is derived from the production of electricity if the company has a generation mix dominated by coal. 2 For companies involved in the manufacture and sale of armaments, the Fund will exclude: • companies involved in the development and production of biological and chemical weapons, depleted uranium ammunition/armour, anti-personnel mines or cluster munitions/sub-munitions and their key components. • companies (including their subsidiaries and investments) involved in the development, production and maintenance of nuclear weapons. 3 Tobacco-based products or nicotine alternatives includes: • Electronic nicotine delivery systems (ENDS) as defined by the US Food and Drug Administration (e.g. ‘vaping’ devices, e-cigarettes) alternatively described as nicotine vaping products (NVP) • Dissolvable and non-combustible tobacco products (e.g. nicotine pouches, snuff) • Shisha and water pipes 12 DEVON FUNDS MANAGEMENT LIMITED Investment objectives and DEVON TRANS-TASMAN FUND strategies of our Funds. Benchmark Trans-Tasman Equity Index unhedged, which is a 50:50 composite of the S&P/NZX50 (Gross) index and the S&P/ASX200 (Accumulation) Index unhedged to NZD. A 50:50 composite means 50% of the S&P/NZX50 (Gross) and 50% of the S&P/ASX200 (Accumulation) Index. Investment Objective This Fund aims to generate capital growth over the long term by actively managing your New Zealand and Australian equity investments. Performance is measured in accordance with the Investment Performance Monitoring framework on page 15. Strategy The Fund invests in a select portfolio of well researched companies which are primarily New Zealand and Australian listed companies. The Trans-Tasman Fund is actively managed, which means the holdings and returns may differ considerably from its benchmark. While the Trans-Tasman Fund tends to be fully invested in shares, when there are few compelling investment opportunities the Fund may hold some cash or cash equivalent securities. Investment limits 0-100% New Zealand shares (Australasian equities) 0-100% Australian shares (Australasian equities) 0-50% Cash or cash equivalent securities. Target Asset Allocation 50-100% Australasian equities 0-50% Cash, or cash equivalent securities. Currency hedging The Fund has the ability to hedge its foreign currency exposure in a range from 0-100%. The Fund is typically unhedged in accordance with our hedging policy which can be found in the Investment Policies and Guidelines section. Distributions The Fund pays distributions 6-monthly at our discretion. Authorised Investments* The authorised investments of the Trans-Tasman Fund are: • Equity and equity-like listed and unlisted securities including ordinary, preference and partly paid shares, convertible securities, warrants and options;. • Derivatives; • Cash and bonds; • Pooled or unlisted funds investing in similar securities to those set out above; and • Any other investment permitted by the Supervisor from time to time. *If we believe that it is in the best interests of our unit holders to vary the authorised investments either by excluding an investment, or adding any investment we may do so. Material changes are subject to certain procedural matters set out in the Trust Deed including notifying all unit holders and agreeing those changes with the Supervisor. We have absolute discretion under the Trust Deed to manage the investments within the guidelines set out in the Deed of Establishment and in this SIPO. DEVON FUNDS MANAGEMENT LIMITED 13 Investment policies and guidelines. The security of your funds is important to us. Your funds Responsible Investment Policy. This is to ensure that are held by an external Custodian who is appointed there is no likelihood of the fund gaining economic by the independent Supervisor and therefore we don’t exposure to a company via derivatives that would have handle any of your funds directly. In addition, our otherwise been excluded from the portfolio. business, internal processes and controls and the Funds are audited annually by PricewaterhouseCoopers. Corporate Governance & Voting Policy We believe that we follow best practice with respect to Responsible Investing corporate governance and voting policies. We vote on all Our Responsible Investment Policy can be found at resolutions where we have the authority to do so. www.devonfunds.co.nz/responsible-investment-policy We form our own views on proposed resolutions and We apply two responsible investing strategies when will ensure that voting is consistent with our policy. managing client funds – Environmental, Social & However, we will not seek to interfere with the executive Governance (ESG) integration and active ownership. operations of the companies we hold. We will continue We have always included ESG issues in our investment to provide appropriate advice and support when process and have actively engaged with companies requested by such companies and at company meetings when we hold that stock in our Funds or portfolios, as and presentations. we believe this is the most effective way to deal with We may enlist the services of external research responsible investing. Where these standards are not providers to access independent advice on proxy voting being demonstrated, we will actively engage with the and corporate governance issues in order to determine company to seek improvement. In our view, it makes our voting intentions. investment sense for the businesses we invest in to be good corporate citizens who look after the interests of We vote all proxies on behalf of our Funds. The objective all stakeholders and operate in a sustainable manner. of voting is to support proposals and director nominees that maximise the value of a Fund or portfolio’s We use MSCI’s Portfolio ESG Analytics and Portfolio investments over the long term. The proposals that Carbon Analytics tool to perform a quarterly screen the Fund or portfolios receive are frequently complex. of portfolios. MSCI ESG ratings are a comprehensive As such, the guidelines adopted provide a rigorous measure of a company’s long-term commitment to framework for assessing each proposal. Under the socially responsible investments and ESG investment guidelines, each proposal must be evaluated on its standards. In particular, the MSCI ESG ratings focus merits, based on the particular facts and circumstances on a company’s exposure to financially relevant ESG that are presented. risks. MSCI ESG Ratings range from leader (AAA, AA), average (A, BBB, BB) to laggard (B, CCC). Our practice seeks to ensure that proxy voting decisions (www.msci.com/sustainable-investing/esg-ratings). are suited to individual Funds or portfolios. For most We incorporate these ratings into our decision making. proxy vote proposals, particularly those involving For the Devon Sustainability Fund, we aim to achieve an corporate governance, the evaluation will result in the MSCI ESG rating greater than the MSCI ESG rating of same position being taken across all of the Funds. In the Benchmark. some cases, however, Funds or portfolios may vote differently, depending upon the nature and objective of We are a signatory to the United Nations supported each Fund or portfolio and its composition. Principles for Responsible Investment (PRI). The PRI provides global principles and a framework to help Conflicts of Interest and Related Party us integrate the consideration of ESG issues into our Transactions investment decision-making and portfolio construction Conflicts of interest arise when the interests of our framework. As part of this process we report annually to employees conflict with some or all of the interests of the PRI on our adherence to these policies. our clients. We are also a member of the Responsible Investment Devon has in place a Conflicts of interest Policy to Association of Australasia (RIAA) and a founding manage potential or actual conflicts of interest in a way member of the New Zealand Corporate Governance that is fair to investors. This policy provides the process Forum which has been established to promote globally to identify, declare and monitor a potential conflict of recognised governance standards in New Zealand. interest. If and when derivative products are used within We will not enter into transactions with related parties the funds, these products are also covered by our who may benefit from those arrangements, except as 14 DEVON FUNDS MANAGEMENT LIMITED Investment policies and guidelines. Continued... agreed with our Supervisor and as permitted under the • Once a trade has been allocated, no subsequent provisions of the FMC Act. We provide the Supervisor adjustments or changes to the original allocation are with quarterly reporting on related party transactions. allowed without Compliance approval; and More information can be found in our Other Material • Trade executions must be entered promptly in the Information document, which is available on the offer trading and/or accounting systems. register at www.business.govt.nz/ disclose Liquidity Alternative Forms of Remuneration Liquidity is considered as part of our investment (Soft Dollar Benefits) valuation process. Each Fund holds a level of cash, in line with its investment parameters, for liquidity It is our policy not to pay or receive any soft dollar purposes ensuring the ability to meet investor cash benefits. flows, fees and expenses, taxation payments, trading Trading and Rebalancing and re-balancing requirements. Cash holdings are reconciled and monitored daily, by our operations and All Funds are actively managed and Portfolio Managers compliance team, and signed off by a senior manager. have full discretion for trading investments for the Where necessary, we have the ability to transact to Funds within agreed limits. Trading will typically ensure there is sufficient liquidity for each Fund. occur when a Fund experiences a large cash flow, the investment thesis changes, market prices move or there If there remains an appropriate risk adjusted return is a change in an underlying security’s investment available then we will consider that security for case. Investment allocations and targets are set by the portfolios. Smaller, illiquid securities are typically investment team in line with each Fund’s investment smaller active positions in the portfolios. Typically all limits at our discretion. All holdings are reconciled portfolios will hold some cash for liquidity purposes. daily, by the operations and compliance team, and are Currency Hedging signed off by a senior manager. We rebalance as required to keep the Funds within the approved investment The Funds face currency risk when we invest in ranges and according to Fund allocations and targets. securities denominated in foreign currencies. Fund values may be negatively or positively impacted by the We have a duty to execute orders fairly. As a matter of appreciation or depreciation of that currency in New policy, we aggregate, and then allocate trade orders to Zealand dollar terms. This is because the value of the clients’ accounts in a fair and timely manner. In general, Fund is calculated in New Zealand dollar terms. trades may be aggregated subject to the conditions and restrictions as per our Compliance Guide. If an We may seek to mitigate the risk of currency exposures aggregated order at a particular broker is filled at by offsetting the impact of currency fluctuations by several different prices, through multiple trades, then the use of foreign exchange forward contracts that will an average price will be calculated for all trades and all lock in an exchange rate for a currency transaction at participants must receive the average price. a future date, known as ‘currency hedging’. Currency hedging provides some protection against changes in We must act in accordance with the following principles currency exchange rates. We actively manage currency when allocating securities among portfolios: exposure at our discretion on a per Fund basis and in • We have a fiduciary duty to ensure that trades are line with each Fund’s investment parameters. allocated fairly and equitably among all clients Our currency exposure and hedging levels are without giving unfair preference to any particular monitored by our operations and compliance team on Fund or portfolio; a daily basis and is signed off by a senior manager each • Allocation decisions may not be influenced by fee day. Currency hedges are rebalanced as required. arrangements; • Funds or portfolios with similar characteristics Borrowing should receive similar allocations. However, The Fund’s Establishment Deeds allow us to make all allocations across similar Funds or portfolios decisions relating to borrowing by or lending from any may differ for legitimate reasons, including client Fund (including stock lending). As at the date of this restrictions, cash availability and avoiding small or SIPO no borrowing has occurred for any of the Funds odd-lot allocations; Our policy is that borrowing is not permitted, however this may change in the future, in consultation with the Supervisor. DEVON FUNDS MANAGEMENT LIMITED 15 Investment policies and guidelines. Continued... Investment Risk • The administrator (Apex) reconciles their records with the records of the custodian; and Our Investment Risk policy recognises that investment risk exists and is a normal part of investing. Optimal • We reconcile our records with that of the investment returns are derived by clearly identifying, administrator (Apex). understanding and then managing investment risk. We Incident Management ensure that investment risk is monitored and managed All incidents are recorded and reported to the operations by: and compliance team immediately. These are reviewed • Measuring our exposure to individual investments, and escalated appropriately including regulatory sectors, countries and currencies and put in place disclosure if required. It is the responsibility of the exposure limits that are appropriate for each Fund; operations and compliance team to assess the incident • Measuring the tracking error on a quarterly basis; and determine whether it triggers any self-reporting or other obligations. Incidents are recorded internally on a • Running a Portfolio Analytics System over the Fund breach/incident register and all breaches are reported on a quarterly basis; and to the Audit, Risk and Compliance Committee on a • Reviewing the Funds at our regular Investment monthly basis or as required depending on the level Committee Meeting. of the breach in line with the limit breaks procedures An investment in a Fund should be regarded as a outlined in the Limit Breaks section. long-term proposition. There are no guarantees that the objectives of a Fund will be achieved. We refer to External Investment Managers investment risk as the probability that the value of an As at the date of this SIPO we work with the following investment could fall and therefore your return could be investment managers: negative. • Wellington Management Key Person Risk Wellington Management is a globally integrated investment management firm and is the investment People are a critical component to our business. Our manager of the Wellington Global Impact Bond Fund policy for managing key person risk is to ensure that: and Wellington Global Stewards Fund, in which the • All roles have a person clearly identified as a backup; Devon Global Impact Bond Fund and Devon Global • The back up person is highly skilled in the key Sustainability Fund invest in respectively. person’s role; When selecting an external manager, we take the • We have close and open communication with all following criteria into consideration: staff; • A sound and disciplined investment process. • All staff are treated with respect and remunerated • Investment style is consistent with Devon’s fairly; and investment philosophy. • We build a degree of latency into our organisation so • Experience and capability of investment team. that capacity exists to manage the departure of a key person if this should occur. • Performance and track record. • Access to the investment management team. Settlement Risk • Governance and compliance arrangements. We have adopted a settlement process, in combination Devon will consider the suitability and performance of with the Fund’s custodian, and administrator (Apex), to any external investment manager from time to time and ensure all settlements occur as per agreed contracts. On reserves the right to add further managers and remove a daily basis: any manager. Where Devon has appointed an external • All trades are signed off by two Portfolio Managers manager, we will periodically assess the holdings of the and a senior member of the operations and external manager’s portfolio to determine whether in compliance team; our view, the holdings remain consistent with what is in • The signed trade is checked internally against the their disclosure documents. We will report our analysis brokers Electronic Trade Confirmation (ETC); to the Investment Committee, and in the event we • ETC’s are sent via SWIFT to the Fund’s custodian; develop any concerns, these will be raised promptly with the Investment Manager for further discussion. • The trade sheet is used to generate a trade file which is emailed to the Fund administrator (Apex); 16 DEVON FUNDS MANAGEMENT LIMITED Limit breaks. Identifying limit breaks breaks is maintained by the operations and compliance team. Judgement for materiality of the limit break Under section 167(1) of the FMC Act, a ‘limit break” is resides with senior management who will consider: a material breach of any limits set out in the SIPO on either: • The cause of the limit break; • the nature or type of investments that can be made; • The economic impact on the investor(s); or • The frequency of the identified limit break type; • the proportion of each type of assets that may be • How long the breach went on for; invested in. • How quickly the breach was rectified after we Limit breaks are considered in the context of the became aware of that breach; and relevant Fund, within the Managed Investment Scheme. • Whether the breach involves related-party SIPO limits are monitored at both pre-trade and post transactions. trade stages by a combination of external software and internally developed proprietary checks and is Reporting limit breaks monitored by the operations and compliance team. Any Limit breaks are reported to the Supervisor as follows: limit breaks are reported on an exceptions basis and a (a) If a limit break is not corrected within 5 working daily compliance report is prepared by the operations days after we become aware of it, then the Supervisor and compliance team. will be notified as soon as practicable after expiry of the If a position requires amendment, the operations and 5 working day period; compliance team will proceed to remedy the position by (b) All limit breaks (regardless of whether they have raising the issue with the relevant Portfolio Manager been corrected or not), each quarter. who will then take necessary action. A register of limit Investment performance monitoring. All unit price movements are assessed daily against tolerance ranges. Investment performance is monitored on a monthly basis against the Fund’s benchmark and is measured over 1 month, 3 months, 6 months, 1, 2, 3 and 5 years. Fund performance is calculated (net of fees but before tax) by the operations and compliance team and all members of the investment team and compliance team receive a monthly fund performance report. The Board evaluates performance on a quarterly basis. We focus on making long term investment decisions and consequently greater focus is given to assessing performance numbers over 3-year periods and longer. DEVON FUNDS MANAGEMENT LIMITED 17 Investment strategy review. The Investment Strategy is reviewed at least annually and is the responsibility of our Investment Committee. The investment strategy framework is designed for the long term and consequently it is unlikely that changes will be made on a regular basis. SIPO review and monitoring. This SIPO is reviewed at least annually and any changes are submitted to the register (Disclose). The SIPO is reviewed by a member of the senior management team with assistance from the compliance and investment teams. Any changes to the SIPO will be signed off by the Board after consultation with the Supervisor. Adherence with this SIPO is monitored regularly and any breaches will be reported to the Supervisor as required under the Trust Deed and relevant legislation. Once the SIPO has been reviewed, the updated or amended SIPO will contain an effective or commencement date. The most current version of the SIPO is available on the schemes register at www.business.govt.nz/disclose/ or at www.devonfunds.co.nz. In addition to the annual review, the SIPO may be reviewed, updated or amended at any time. Thank you for taking the time to read this SIPO. If you have any questions, please don’t hesitate to contact us at: enquiries@devonfunds.co.nz 18 DEVON FUNDS MANAGEMENT LIMITED Directory. Manager Supervisor Devon Funds Management Limited The New Zealand Guardian Trust Company Limited Level 17 Level 6 HSBC Tower 191 Queen Street 188 Quay Street Auckland 1010 Auckland 1010 PO Box 274 PO Box 105 609 Shortland Street Auckland 1143 Auckland 1140 Telephone: 0800 944 049 (free call) or +649 925 3990 Telephone: 0800 300 299 Email: enquiries@devonfunds.co.nz or Website: www.devonfunds.co.nz Registrar/Administration manager Apex Group Limited Directors Level 25 Paul Anthony Glass QBE Centre Mel Tony Firmin 125 Queen Street Slade Brownlie Robertson Auckland 1010 June Ngahiwi McCabe Lance Jenkins Administration manager Investment Services Group Limited Level 17 HSBC Tower 188 Quay Street Auckland 1010 PO Box 105 609 Auckland 1143 Solicitors DLA Piper Level 4, Deloitte House 20 Customhouse Quay Wellington 6011 Auditors PricewaterhouseCoopers 188 Quay Street Auckland 1010 DEVON FUNDS MANAGEMENT LIMITED 19 For the informed investor. Devon Funds Management Limited Level 17, HSBC Tower 188 Quay Street Auckland 1010 Telephone: 0800 944 049 (free call) or +649 925 3990 enquiries@devonfunds.co.nz www.devonfunds.co.nz