# PG High Conviction Fund
**Provider:** PG Investments (https://pginvestments.nz)
**Source:** https://wholesaleinvestor.co.nz/funds/pg-high-conviction-fund
**Facts JSON:** https://wholesaleinvestor.co.nz/api/im/pg-high-conviction-fund/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://pginvestments.nz/2026-03-pg-funds-pds/
**Published:** 2026-03-01
**Pages:** 22
**Extracted via:** pdftotext on 2026-05-19
                                                                    DATE OF ISSUE / 31 MARCH 2026




                   Product
                   Disclosure
                   Statement
                   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.disclose-register.companiesoffice.govt.nz.
                   PG Funds has prepared this document in
                   accordance with the Financial Markets
                   Conduct Act 2013. You can also seek advice
                   from a financial advice provider to help you
                   make an investment decision.


                   This replacement Product Disclosure
                   Statement supersedes the Product
                   Disclosure Statement dated 14 August 2025.




ISSUED BY
PG FUNDS LIMITED
  PERPETUAL GUARDIAN INVESTMENTS




01.
Key Information
Summary

What is this?
This is a managed investment scheme. Your money will be pooled with other investors’ money and invested in various
investments. PG Funds Limited (PG Funds, we, us or our) will invest your money and charge you a fee for its services.
The returns you receive are dependent on the investment decisions of PG Funds and the performance of the investments.
The value of those investments may go up or down. The types of investments and the fees you will be charged are
described in this document.

WHAT WILL YOUR MONEY BE INVESTED IN?
The PG Funds scheme offers five Funds for you to invest in. This Product Disclose Statement covers the Funds in the
summarised table below. More information about the investment target and strategy for each Fund is provided in Section 3
“Description of your investment options”




             PG STRATEGIC                            PG HIGH                                 PG INCOME
             GROWTH FUND                         CONVICTION FUND                         OPPORTUNITIES FUND


                                                The Fund’s primary objective
       The Fund aims is to achieve             is to achieve long-term capital
  long-term capital growth by investing                                                  The Fund aims to provide
                                               appreciation through strategic
     predominantly in international                                                    a higher level of income from
                                              investment in a select group of
      equities, including Exchange                                                  a diversified investment portfolio of
                                                New Zealand and Australian
       Traded Funds (ETFs) listed                                                    equity and fixed income securities
                                             equities. The strategy allows the
                                                                                    alongside moderate capital growth
         throughout the world.             Fund to navigate market fluctuations
                                                                                             over the long-term.
                                            while aiming for sustained growth
                                                    over extended periods.


             RISK INDICATOR¹                          RISK INDICATOR¹                      RISK INDICATOR ¹
  POTENTIALLY              POTENTIALLY     POTENTIALLY              POTENTIALLY     POTENTIALLY               POTENTIALLY
  LOWER RETURNS         HIGHER RETURNS     LOWER RETURNS         HIGHER RETURNS     LOWER RETURNS          HIGHER RETURNS

   1     2     3   4     5     6     7      1     2     3   4    5     6     7       1     2     3   4     5     6     7

  LOWER RISK                 HIGHER RISK   LOWER RISK                HIGHER RISK    LOWER RISK                 HIGHER RISK




       ESTIMATED ANNUAL                         ESTIMATED ANNUAL                         ESTIMATED ANNUAL
         FUND CHARGES*                            FUND CHARGES*                            FUND CHARGES

               1.20%                                    1.20%                                    0.95%




                                                                              PRODUCT DISCLOSURE STATEMENT / 01
   PERPETUAL GUARDIAN INVESTMENTS




01.
Key Information
Summary

continued

                                 PG GLOBAL                                                         PG NEW ZEALAND
                             ALTERNATIVES FUND                                                        BOND FUND

  The Fund aims to deliver attractive long-term returns by investing in a diversified
   portfolio of global alternative assets. These may include, but are not limited to,           The Fund is designed to provide
    alternative equity strategies, absolute return Funds, and other non-traditional           regular income from predominantly
   investments. The Fund is designed to complement traditional equity and bond                  New Zealand investment grade
  holdings by providing exposure to differentiated sources of return with a focus on                    corporate bonds.
             capital growth, diversification, and risk-adjusted outcomes.


                                   RISK INDICATOR¹                                                   RISK INDICATOR¹
                        POTENTIALLY               POTENTIALLY                                POTENTIALLY                POTENTIALLY
                        LOWER RETURNS          HIGHER RETURNS                                LOWER RETURNS           HIGHER RETURNS


                         1     2     3    4     5     6     7                                 1     2     3    4     5     6     7

                        LOWER RISK                  HIGHER RISK                              LOWER RISK                  HIGHER RISK



                              ESTIMATED ANNUAL                                                    ESTIMATED ANNUAL
                                FUND CHARGES*                                                       FUND CHARGES


                                     1.67%                                                                0.65%
1. The risk indicator is based on the market index over the five years to 31 March 2025, as the Fund did not exist at a retail level
before this PDS. As a result, it may be a less reliable indicator of the Fund’s potential future volatility.

See Section 4 “What are the risks of investing?” 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 financial advice or use the risk profiler tool at www.sorted.org.nz/tools/investor-kickstarter.

*The estimated annual Fund charges for the PG Strategic Growth Fund, PG High Conviction Fund and PG Global Alternatives
Fund include estimated performance-based fees. See Section 5 “What are the fees?” for more information on these fees.

WHO MANAGES THE FUNDS?
The manager of the Funds is PG Funds. See Section 7 “Who is involved” for more information.

WHAT ARE THE RETURNS?
The return on your investment comes from a combination of any increase or decrease in the value of your units in the
Funds, which reflects changes in the value of the underlying assets of the Funds. Some Funds may also pay monthly
distributions. See Section 3 “Description of your investment options” for further details on which Funds pay distributions.

HOW CAN YOU GET YOUR MONEY OUT?
Your investment in the Funds is redeemable. Minimum and maximum redemption amounts may apply, and redemption
requests must be made by logging into the online portal at pginvestments.admins.co.nz and selecting the sell button
which will list the investment(s) you own. We may also suspend or defer redemptions in certain circumstances (where we
in conjunction with the Supervisor believe it would not be practicable to redeem).




                                                                                    PRODUCT DISCLOSURE STATEMENT / 02
  PERPETUAL GUARDIAN INVESTMENTS




01.
Key Information
Summary

continued

   Further information about
   redeeming your investment
   can be found in Section 2 (How
   does this investment work?).


Your investment in the Funds can be sold but there is no established market for trading these financial products. This
means that you may not be able to find a buyer for your investment.

HOW WILL YOUR INVESTMENT BE TAXED?
The Funds under the Scheme are all portfolio investment entities (PIEs).
The amount of tax you pay in respect of a PIE is based on your prescribed investor rate (PIR). To determine your PIR, go to
www.ird.govt.nz/roles/portfolio-investment-entities/using-prescribed-investor-rates. See Section 6 (What
taxes will you pay?) for more information.

WHERE CAN YOU FIND MORE KEY INFORMATION?
PG Funds is required to publish quarterly updates for each Fund. The updates show the returns, and the total fees actually
charged to investors, during the previous year. The latest Fund updates are available at pginvestments.nz. PG Funds will
also give you copies of those documents on request.




                                                                              PRODUCT DISCLOSURE STATEMENT / 03
Product Disclosure
Statement

contents

01   KEY INFORMATION SUMMARY                   1

02   HOW DOES THIS INVESTMENT WORK?            5

03   DESCRIPTION OF YOUR INVESTMENT OPTIONS    7

04   WHAT ARE THE RISKS OF INVESTING?         13

05   WHAT ARE THE FEES?                       15

06   WHAT TAXES WILL YOU PAY?                 18

07   WHO IS INVOLVED?                         18

08   HOW TO COMPLAIN                          19

09   WHERE YOU CAN FIND MORE INFORMATION      19

10   HOW TO APPLY                             20




                                               PERPETUAL GUARDIAN INVESTMENTS / 04
   PERPETUAL GUARDIAN INVESTMENTS




02.
How does this
Investment Work

Legal structure of the Funds
The PG Funds Scheme is a managed investment scheme, and each Fund is established as a trust, governed by a trust
deed. The trust deeds are available at www.disclose-register.companiesoffice.govt.nz.

A managed investment scheme allows your money to be pooled with that of other investors, giving you access to a
potentially wider range of investments.

The assets of one Fund are not available to meet the liabilities of any other Fund established by PG Funds.

Your investments are held independently of PG Funds by Adminis NZ Limited as independent custodian, meaning it holds
the assets on your behalf. The New Zealand Guardian Trust Company Limited is the Supervisor of the Funds. Their role
as Supervisor of the Funds is to actively supervise PG Funds’ performance of its functions and issuer obligations, and the
financial position of PG Funds and each of the Funds.

Each Fund is divided into units and you invest by buying units. The more you invest the more units you get. Each unit is of
equal value and each unit shares equally in the gains and losses, income and expenses of the relevant Fund. The value of
units goes up and down according to the changing value of the assets, less liabilities, in the Funds. The units do not give
you legal ownership of the Fund’s assets but they do give you rights to the returns from the assets.

DISTRIBUTIONS
Some of the Funds pay distributions. Distributions are cash payments of a portion of the income earnt by the Fund.
Distributions are paid to your nominated bank account, or reinvested in further units. Buy / Sell spreads (detailed in Section
5 “What are the fees?”) are not applied to distributions. See Section 3 “Description of your investment options” for further
details on which Funds pay distributions.

INVESTMENT PHILOSOPHY
We believe sound investment returns to investors can be made through effective assessment of both quantitative
and qualitative measures to identify companies and investments. We have our own signposts through our investment
approach to identify high-quality companies for investment and likewise, warning signs that help us ward off
undesirable investments.

MAKING INVESTMENTS
You can make an investment in a Fund by completing the online application form at pginvestments.nz.

The current minimum amounts you can invest into the PG Funds Scheme is $1,000.

WITHDRAWING YOUR INVESTMENTS
You can withdraw all or part of your investment in a Fund at any time by logging into the online portal at pginvestments.
admins.co.nz and selecting the sell button which will list the investment(s) you own. You may sell either a dollar or
unit amount.

Withdrawals will normally be processed and payment occur within 10 business days of receipt of the completed
withdrawal process.




                                                                                PRODUCT DISCLOSURE STATEMENT / 05
   PERPETUAL GUARDIAN INVESTMENTS




02.
How does this
Investment Work

continued
We may, with prior notice to the Supervisor, suspend withdrawal requests or defer payment of withdrawals where, due to
certain circumstances arising (for examples, political or market conditions), we form the opinion that it is not practicable, or
would be prejudicial to the general interests of unitholders, or that suspension is desirable for the Fund(s).

The Funds have the below maximum redemption gates per investor account.

 FUND NAME                                               MAXIMUM REDEMPTION GATE                           PERIOD

 PG Strategic Growth Fund                                             $10 million                     Rolling four weeks

 PG High Conviction Fund                                              $10 million                     Rolling four weeks

 PG Income Opportunities Fund                                         $10 million                     Rolling four weeks

 PG Global Alternatives Fund                                          $10 million                     Rolling four weeks

 PG New Zealand Bond Fund                                             $10 million                     Rolling four weeks




HOW TO SWITCH BETWEEN FUNDS
You can switch between Funds. This will be considered a withdrawal from one Fund and an application for units in another
Fund. All the conditions and restrictions on applications and withdrawals will apply.




                                                                                PRODUCT DISCLOSURE STATEMENT / 06
 PERPETUAL GUARDIAN INVESTMENTS




03.
Description of your
Investment Options


PG STRATEGIC GROWTH FUND

PG HIGH CONVICTION FUND

PG INCOME OPPORTUNITIES FUND

PG GLOBAL ALTERNATIVES FUND

PG NEW ZEALAND BOND FUND




                                  PERPETUAL GUARDIAN INVESTMENTS / 07
PERPETUAL GUARDIAN INVESTMENTS




PG Strategic Growth Fund
                                                                      POTENTIALLY                                  POTENTIALLY
                                                                      LOWER RETURNS                             HIGHER RETURNS



Risk Indicator*                                                         1          2       3     4        5       6         7
                                                                      LOWER RISK                                     HIGHER RISK




OBJECTIVE / DESCRIPTION
The Fund aims to achieve long-term capital growth by predominantly investing in international equities, including
Exchange Traded Funds (ETFs) listed globally.


INVESTMENT STRATEGY
The Fund follows an active management strategy, investing in a concentrated portfolio of typically 10 to 50
predominantly international companies. This focused approach enables selective investment decisions and
avoids passive replication of any specific index. While the primary focus is on international markets, the Fund
may also invest in Australasian equities when opportunities arise. It is generally expected to be fully invested;
however, the Fund may hold cash or cash equivalents at times to manage risk and maintain flexibility. The
overarching objective is to achieve long-term capital growth through careful selection and active management
of high-quality global investment opportunities.


 ASSET CLASS                                                                                                  TARGET

 Cash and Cash Equivalents                                                                                      2%

 International Equities                                                                                         98%


MINIMUM RECOMMENDED HORIZON
5 years


PERFORMANCE BENCHMARK
MSCI World Index (Price Return, in NZD)
While the Fund uses this as a benchmark, it is managed without strictly following or being tied to it.


DISTRIBUTIONS
Monthly distributions will be paid where income from underlying investments are available.




*The risk indicator is based on the market index over the five years to 31 March 2025, as the Fund did not exist at a retail
level before this PDS. As a result, it may be a less reliable indicator of the Fund’s potential future volatility. See Section 4
“What are the risks of investing?” 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 financial advice or use the
risk profiler tool at www.sorted.org.nz/tools/investor-kickstarter.




                                                                                       PRODUCT DISCLOSURE STATEMENT / 08
PERPETUAL GUARDIAN INVESTMENTS




PG High Conviction Fund
                                                                      POTENTIALLY                                  POTENTIALLY
                                                                      LOWER RETURNS                             HIGHER RETURNS



Risk Indicator*                                                         1          2       3     4        5       6         7
                                                                      LOWER RISK                                     HIGHER RISK




OBJECTIVE / DESCRIPTION
The Fund’s primary objective is to achieve long-term capital appreciation through strategic investment in a select
group of New Zealand and Australian equities. The strategy allows the Fund to navigate market fluctuations while
aiming for sustained growth over extended periods.


INVESTMENT STRATEGY
The Fund employs an active management strategy, focusing on a select group of typically 10 to 30 companies
listed in Australia and New Zealand. This focused approach enables careful selection and management of
investments, rather than passively replicating an index. While the Fund primarily invests in Australasian markets,
it retains the ability to invest in shares listed outside this region. It is generally expected to be fully invested;
however, cash or cash equivalents may be held at times to reduce risk and increase flexibility. The primary
objective of the Fund is to achieve long-term capital growth.


 ASSET CLASS                                                                                                  TARGET

 Cash and Cash Equivalents                                                                                      2%

 Australasian Equities                                                                                          98%


MINIMUM RECOMMENDED HORIZON
5 years


PERFORMANCE BENCHMARK
50% S&P / NZ All Shares (Price Return, in NZD)
50% S&P / ASX 200 (Price Return, in NZD)

While the Fund uses this as a benchmark, it is managed without strictly following or being tied to it.


DISTRIBUTIONS
Monthly distributions will be paid where income from underlying investments are available.




*The risk indicator is based on the market index over the five years to 31 March 2025, as the Fund did not exist at a retail
level before this PDS. As a result, it may be a less reliable indicator of the Fund’s potential future volatility. See Section 4
“What are the risks of investing?” 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 financial advice or use the
risk profiler tool at www.sorted.org.nz/tools/investor-kickstarter.




                                                                                       PRODUCT DISCLOSURE STATEMENT / 09
PERPETUAL GUARDIAN INVESTMENTS




PG Income Opportunities Fund
                                                                      POTENTIALLY                                  POTENTIALLY
                                                                      LOWER RETURNS                             HIGHER RETURNS



Risk Indicator*                                                         1          2       3     4        5       6         7
                                                                      LOWER RISK                                     HIGHER RISK




OBJECTIVE / DESCRIPTION
The Fund aims to provide a higher level of income from a diversified investment portfolio of equity and fixed
income securities, alongside moderate capital growth over the long term.


INVESTMENT STRATEGY
The Fund combines quantitative analysis with qualitative, fundamental research across Australasian
investments. It primarily invests in select equities that typically offer compelling dividend yields, fixed interest
securities, and cash. Through this approach, the Fund provides diversification of investment types and income
streams, offering investors the potential for regular distributions.


 ASSET CLASS                                                                                                  TARGET

 Cash and Cash Equivalents                                                                                      2%

 Australasian Equities                                                                                          50%

 New Zealand Fixed Interest                                                                                     48%

MINIMUM RECOMMENDED HORIZON
3 years


PERFORMANCE BENCHMARK
NZ Official Cash Rate + 2.5%


DISTRIBUTIONS
Monthly distributions will be paid where income from underlying investments are available.




*The risk indicator is based on the market index over the five years to 31 March 2025, as the Fund did not exist at a retail
level before this PDS. As a result, it may be a less reliable indicator of the Fund’s potential future volatility. See Section 4
“What are the risks of investing?” 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 financial advice or use the
risk profiler tool at www.sorted.org.nz/tools/investor-kickstarter.




                                                                                       PRODUCT DISCLOSURE STATEMENT / 10
PERPETUAL GUARDIAN INVESTMENTS




PG Global Alternatives Fund
                                                                      POTENTIALLY                                  POTENTIALLY
                                                                      LOWER RETURNS                             HIGHER RETURNS



Risk Indicator*                                                         1          2       3     4        5       6         7
                                                                      LOWER RISK                                     HIGHER RISK




OBJECTIVE / DESCRIPTION
The Fund aims to deliver attractive long-term returns by investing in a diversified portfolio of global alternative
strategies through managed Funds. These may include, but are not limited to long/short strategies, event-driven
strategies, futures strategies and market neutral style premia strategies. The Fund is designed to complement
traditional equity and bond holdings by providing exposure to differentiated sources of return, with a focus on
capital growth, diversification, and risk-adjusted outcomes.


INVESTMENT STRATEGY
The Fund employs an active, multi-asset strategy focused on identifying and allocating capital to a carefully
selected group of global alternative investments. It invests through external Fund managers who demonstrate
strong alignment with the Fund’s objectives, possess specialist expertise, and maintain a disciplined investment
process. External managers are selected based on rigorous due diligence, including assessment of their track
record, investment philosophy, risk management practices, and structural alignment with investors.


 ASSET CLASS                                                                                                  TARGET

 Cash and Cash Equivalents                                                                                      2%

 Other                                                                                                          98%

MINIMUM RECOMMENDED HORIZON
5 years


PERFORMANCE BENCHMARK
NZ Official Cash Rate + 3%


DISTRIBUTIONS
None




*The risk indicator is based on the market index over the five years to 31 March 2025, as the Fund did not exist at a retail
level before this PDS. As a result, it may be a less reliable indicator of the Fund’s potential future volatility. See Section 4
“What are the risks of investing?” 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 financial advice or use the
risk profiler tool at www.sorted.org.nz/tools/investor-kickstarter.




                                                                                       PRODUCT DISCLOSURE STATEMENT / 11
   PERPETUAL GUARDIAN INVESTMENTS




   PG New Zealand Bond Fund
                                                                         POTENTIALLY                                  POTENTIALLY
                                                                         LOWER RETURNS                             HIGHER RETURNS



   Risk Indicator*                                                         1          2       3     4        5       6        7
                                                                         LOWER RISK                                    HIGHER RISK




   OBJECTIVE / DESCRIPTION
   The Fund is designed to provide regular income from predominantly New Zealand investment grade
   corporate bonds.


   INVESTMENT STRATEGY
   The Fund predominantly invests in select New Zealand corporate fixed interest securities. It employs active
   duration management, adjusting the portfolio’s sensitivity to interest rate changes based on market conditions
   and economic outlooks. This approach allows for tactical positioning in response to anticipated interest rate
   movements, potentially enhancing returns and mitigating risks associated with bond price fluctuations.


     ASSET CLASS                                                                                                 TARGET

     New Zealand Fixed Interest                                                                                   100%


   MINIMUM RECOMMENDED HORIZON
   3 years


   PERFORMANCE BENCHMARK
   Bloomberg NZ Bond Composite 0+ Yr (Total Return, in NZD)


   DISTRIBUTIONS
   Monthly distributions will be paid where income from underlying investments are available.




   *The risk indicator is based on the market index over the five years to 31 March 2025, as the Fund did not exist at a retail
   level before this PDS. As a result, it may be a less reliable indicator of the Fund’s potential future volatility. See Section 4
   “What are the risks of investing?” 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 financial advice or use the
   risk profiler tool at www.sorted.org.nz/tools/investor-kickstarter.




STATEMENT OF INVESTMENT POLICY AND OBJECTIVES (SIPO)
Further information about the Funds’ policies and objectives, as well as investment philosophy and strategy, can be found
in the Funds’ SIPO.

We can make changes to the SIPO at any time in accordance with the Trust Deed and the Financial Markets Conduct Act
2013. We will consult with the Supervisor prior to making any changes and will not implement any material change without
giving you at least one month’s prior notice.

The most current version of the Funds’ SIPO is available at www.disclose-register.companiesoffice.govt.nz.

Further information about the assets in the Funds can be found in the Fund Updates at pginvestments.nz.




                                                                                          PRODUCT DISCLOSURE STATEMENT / 12
   PERPETUAL GUARDIAN INVESTMENTS




04.
What are the risks
of Investing

understanding the risk indicator
Managed Funds in New Zealand must have a standard risk indicator. The risk indicator is designed to help investors
understand the uncertainties both for loss and growth that may affect their investment. You can compare Funds using the
risk indicator.

                                                             higher                            potentially
                                                                risk      07                   higher returns
Example
Risk
                                                                          06


indicator                                                                 05

                                                                                                         current
                                                                          04                   04        risk
                                                                                                         profile

                                                                          03


                                                                          02


                                                              lower       01                   potentially
                                                                risk                           lower returns



The completed risk indicators for the Funds covered by this PDS can be found in Section 3 “Description of your
investment options”.

The risk indicator is rated from 1 (low) to 7 (high). The rating reflects how much the value of the Fund’s assets goes up and
down (volatility). A higher risk generally means higher potential returns over time, but more ups and downs along the way.

To help you clarify your own attitude to risk, you can seek financial advice or work out your risk profile at www.sorted.
org. nz/tools/investor-kickstarter.

Note that even the lowest category does not mean a risk-free investment, and there may be other risks that are not
captured by this rating.

This risk indicator is not a guarantee of a Fund’s future performance. The Risk Indicator is based on the returns data for 5
years to 31 March 2025. While risk indicators are usually relatively stable, they do shift from time to time. You can see the
most recent risk indicators in the latest Fund Update for each Fund.




                                                                                PRODUCT DISCLOSURE STATEMENT / 13
  PERPETUAL GUARDIAN INVESTMENTS




04.
What are the risks
of Investing

continued
GENERAL INVESTMENT RISKS
Some of the things that may cause the Funds’ value to move up and down, which affect the risk indicator, are:




  Market risk

  The returns you receive from the Funds will be affected by the performance of the Funds’ investments, which may
  be affected by the performance of the investment markets generally. This risk includes movements in the general
  price level and demand and supply in the market in which the relevant investments are made, the sectors in which the
  investments are made, and economic and regulatory conditions, including market sentiment, inflation, interest rates,
  employment, political events, environmental and technological issues, and consumer demand both in New Zealand
  and globally.




  Currency risk

  A portion of the Funds’ investments may be invested in assets denominated in currencies other than New Zealand
  Dollars – e.g. Australian Dollars. Returns may be affected by movements between the New Zealand dollar and
  other currencies.




  Credit risk

  The risk of a counterparty to the Funds being unable to meet its payment obligations.




  Liquidity risk

  The ability to sell assets to obtain cash in a timely manner can be impaired because of a lack of buyers, suspension
  of trading, or market events. Smaller securities can be affected by a lack of liquidity.




  Unlisted Equities

  Some of the Funds may invest in unlisted equity securities, which are not traded on public markets. These investments
  can be difficult to value, may be less transparent, and may involve higher uncertainty. In addition, they are generally less
  liquid and may take longer to sell, especially in adverse market conditions. The performance of unlisted equities can also
  be more volatile due to limited information, smaller scale, or concentration in particular industries or geographies.




                                                                                  PRODUCT DISCLOSURE STATEMENT / 14
     PERPETUAL GUARDIAN INVESTMENTS




05.
What are the
Fees
You will be charged fees for investing in the PG Funds. Fees are deducted from your investment and will reduce your
returns. If PG Funds invests into 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). Small differences in these fees can have a large impact on your
     investment over the long term

•    One off fees (currently none).

                                                   ESTIMATED
                                                                                ESTIMATED               ESTIMATED
                                                MANAGEMENT AND
    FUND NAME                                                                  PERFORMANCE            TOTAL ANNUAL
                                                 ADMINISTRATION
                                                                                   FEES               FUND CHARGES
                                                      FEE

    PG Strategic Growth Fund                             1.20%                       0.00%                  1.20%

    PG High Conviction Fund                              1.20%                       0.00%                  1.20%

    PG Income Opportunities Fund                         0.95%                        n/a                   0.95%

    PG Global Alternatives Fund                          1.40%                       0.27%                  1.67%

    PG New Zealand Bond Fund                             0.65%                        n/a                   0.65%



The estimated performance fees shown above are based on the performance of the market index over the last 5 years.

MANAGEMENT AND ADMINISTRATION CHARGES
Management and administrative charges are set out as a percentage of the Fund’s net asset value. Actual charges over the
past disclosure year are available in the latest Fund Updates.

The management and administration charges covers our management fee, underlying management fees (excluding ETF
management fees) and normal operating expenses of the Fund, including but not limited to Supervisor, custodial, Fund
accounting, unit pricing, registry, audit and legal fees. It excludes trading costs and tax

PERFORMANCE FEES
Whilst the retail Funds do not charge performance fees themselves, some of the underlying wholesale Funds charge
performance fees.

The performance fees are charged daily to the investor as a percentage of any returns above a set minimum return (the
hurdle rate) from the unit price when the last performance fee was paid (the high water mark). This is calculated after
deducting the base Fund fee but before tax and the performance fee itself.

The hurdle rate from the point of the high water mark is reviewed every year on 31 March. The Fund must exceed this
hurdle rate from the high water mark before any performance fee can be paid to the manager.




                                                                                  PRODUCT DISCLOSURE STATEMENT / 15
  PERPETUAL GUARDIAN INVESTMENTS




05.
What are the
Fees

continued
The specific performance fees, hurdle rates, and high-water marks for each Fund are listed in the table below.


                   PERFORMANCE         PERFORMANCE
                                                                                          HIGH                FREQUENCY
                      FEE (% OF          FEE CAP (%         HURDLE RATE
 FUND NAME                                                                               WATER                       OF
                       EXCESS          OF NET ASSET          OF RETURN
                                                                                          MARK                   PAYMENT
                       RETURN)              VALUE)

                                                                                A perpetual high
                                                             MSCI World         water mark applies
 PG Strategic                                                                   to the payment of the
                          10%                 2%             Index (Price
 Growth Fund                                                                    performance-based fee.
                                                            Return, in NZD)
                                                                                The high water mark
                                                                                is the unit price of the
                                                                                Fund at the last time
                                                                                the last performance
                                                                                fee was paid to the
                                                                                manager. Performance
                                                                                gains (if the high water
                                                                                mark is not achieved)            Annually on
                                                            A composite of      or performance losses             31 March
                                                            50% S&P/NZX         (relative to benchmark) are
 PG High                                                    All Index (Price    carried forward into the
 Conviction               10%                 2%            Return, in NZD)     next performance period.
 Fund                                                       and 50% S&P/        Performance fees may
                                                            ASX 200 (Price      accrue when below
                                                            Return, in NZD)     the high water mark,
                                                                                however are only payable
                                                                                once the high water
                                                                                mark is exceeded on a
                                                                                performance payment
                                                                                review date.

                                                                                A perpetual high
                                                                                water mark applies
                                                                                to the payment of the
 PG Global                                                                      performance-based fee.
                                                               RBA Cash
 Alternatives             10%                 n/a                               The high water mark               Monthly
                                                              Rate Target
 Fund*                                                                          is the unit price of the
                                                                                Fund at the time the last
                                                                                performance fee was
                                                                                crystallised and paid.

 PG Income
 Opportunities            n/a                 n/a                 n/a                       n/a                     n/a
 Fund

 PG New
 Zealand                  n/a                 n/a                 n/a                       n/a                     n/a
 Bond Fund

*This performance fee is charged by an externally managed Fund that the PG Global Alternative Fund invests into.



                                                                               PRODUCT DISCLOSURE STATEMENT / 16
   PERPETUAL GUARDIAN INVESTMENTS




05.
What are the
Fees

continued
BUY/SELL SPREADS
The buy/sell spreads are costs that you will incur when you transact. The buy spread is added to the daily unit price on
applications to the Fund and the sell spread is deducted from the unit price when you redeem from the Fund. The buy/sell
spreads are not paid to PG Funds or any underlying manager. The buy/sell spreads reflect the estimated costs of buying or
selling the underlying investments and may change over time with underlying market conditions.

The purpose of the buy/sell spread is to ensure transaction costs are fairly attributed to investors entering or exiting
each Fund.

Current buy/sell spreads are advertised on our website at pginvestments.nz. The Funds all have indicative buy/sell
spreads of 0.00%.

EXAMPLE OF HOW FEES APPLY TO AN INVESTOR
Andrew invests $10,000 in the PG High Conviction Fund. Currently there are no entry or exit fees and there is no buy or sell
spread applied to transactions in the Fund. Andrew’s full $10,000 is invested at the prevailing unit price.

He is charged management and administration fees, which work out to be $120 over the first year (1.20% of his $10,000
investment). These fees might be more or less if his account balance has increased or decreased over the year.

Andrew may also be charged a performance fee if his fund earned more than its target.

Estimated total fees for the first year (based on current fee structure)
Fund charges:       $120
Other charges:      None

What if a buy/sell spread is introduced?
If a buy spread of 0.15% were to apply in the future, it is incorporated in the unit price Andrew pays for his investment.
This equates to approximately $15 and is retained in the fund, not paid to us. This brings Andrew’s starting value of his
investment to approximately $9,985. The management and administration fees would then be calculated based on the
reduced investment amount.

See the latest fund update for an example of the actual returns and fees investors were charged over the past year.

This example applies only to the PG High Conviction Fund. If you are considering investing in other Funds, this example
may not be representative of the actual fees you may be charged.

THE FEES CAN BE CHANGED
The fees detailed above may change from time to time in accordance with the trust deed, which can be found on the
scheme register at www.disclose-register.companiesoffice.govt.nz

PG Funds must publish a Fund update for each Fund showing the fees charged during the most recent year. Fund updates,
including past updates, are available at pginvestments.nz.




                                                                                PRODUCT DISCLOSURE STATEMENT / 17
   PERPETUAL GUARDIAN INVESTMENTS




06.
What taxes will
You Pay?
Each Fund is a Portfolio Investment Entity (PIE). The amount of tax you pay is based on your Prescribed Investor Rate
(PIR). To determine your PIR, go to www.ird.govt.nz/roles/portfolio-investment-entities/using-prescribed-
investor-rates. If you are unsure of your PIR, we recommend you seek professional advice or contact the Inland Revenue
Department. It is your responsibility to tell PG Funds your PIR when you invest or if your PIR changes. If you do not tell
PG Funds, 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.




07.
Who is
Involved?
ABOUT PG FUNDS
PG Funds Limited is the Manager of the Funds.
                                                                  PG Funds Limited
PG Funds can be contacted at:                                     Perpetual Guardian Tower
Telephone: +64 9 300 60 60                                        Level 23, 191 Queen Street,
Email: info@castlepointfunds.com                                  Auckland 1010, New Zealand


WHO ELSE IS INVOLVED?


 ROLE                            NAME                        DESCRIPTION

                                 The New Zealand             Independent supervisor of the Funds under the Financial
 Supervisor                      Guardian Trust              Markets Conduct Act 2013, responsible for supervising PG
                                 Company Limited             Funds Limited as manager of the Funds.

                                                             Independent entity appointed by the Supervisor to hold Fund
 Custodian                       Adminis NZ Limited
                                                             assets on behalf of investors.

                                                             Appointed by PG Funds Limited to perform various administrative
 Administrator                   Adminis NZ Limited          duties delegated to it, including unit pricing, registry and
                                                             Fund accounting.

                                                             Manager of the PG Funds managed investment scheme under
 Manager                         PG Funds Limited
                                                             the Financial Markets Conduct Act 2013.


 Underlying                      Perpetual Guardian          The entity that manages the wholesale Funds underlying the
                                 Investments Limited
 Investment Manager                                          retail Funds in this SIPO.
                                 (PG Investments)




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   PERPETUAL GUARDIAN INVESTMENTS




08.
How to
Complain
In the first instance complaints about your investment can be made to PG Funds (contact details in Section 7 –
Who is involved?).

If we are unable to resolve your complaint you may choose to contact the Supervisor:

The New Zealand Guardian Trust Company Limited
Address: Level 6                             Telephone: 0800 300 299
           191 Queen Street                  E-mail: ct-auckland@nzgt.co.nz
           Auckland 1010

We and the Supervisor are members of the independent dispute resolution scheme Financial Services Complaints Limited
(FSCL). If you have made a complaint to the Supervisor, and it has not been resolved (within two months, or if you are
dissatisfied with the proposed resolution), you can refer it to FSCL at:

Financial Services Complaints Limited (FSCL)
Address: Level 4 101 Lambton Quay            Telephone: 0800 347 257
           PO Box 5967                       E-mail: complaints@fscl.org.nz
           Wellington 6140			

FSCL will not charge you to investigate or resolve a complaint.
Further information about referring a complaint to FSCL can be found at www.fscl.org.nz.




09.
Where you can find
More Information
Further information relating to PG Funds, including financial statements, is available on the Disclose Register at
www.disclose-register.companiesoffice.govt.nz.

Copies of information on the Disclose Register are also available on request from the Registrar of Financial
Service Providers.

Fund Updates relating to each of the Funds and other information is also available at pginvestments.nz.

You will not be charged any fee to access this information.




                                                                               PRODUCT DISCLOSURE STATEMENT / 19
  PERPETUAL GUARDIAN INVESTMENTS




10.
How to
Apply
The easiest way to apply is online at pginvestments.nz. Please follow the instructions and make sure you have all the
required information on hand, and feel free to contact us if you have any questions.

Telephone: 0800 673 659

Email: contact@pginvestments.nz

PG Funds Limited
Perpetual Guardian Tower
Level 23, 191 Queen Street,
Auckland 1010, New Zealand




      apply here                         pginvestments.nz




                                                                              PRODUCT DISCLOSURE STATEMENT / 20
    Intelligent
investing for today
  and the future.


   PGINVESTMENTS.NZ


---
## SIPO
**Source PDF:** https://pginvestments.nz/2026-03-pg-funds-sipo/
**Published:** 2026-03-01
**Pages:** 17
**Extracted via:** pdftotext on 2026-05-20
Statement of
Investment Policy
and Objectives
for the PG Funds

Issued by PG Funds Limited
Effective Date 27 March 2026
contents


01   INTRODUCTION                     02

02   GOVERNANCE AND MONITORING        03

03   INVESTMENT PHILOSOPHY            03

04   KEY INVESTMENT PROCESSES         04

05   DESCRIPTION OF ASSET CLASSES     08

06   FUND SCHEDULES                   09

		PG Strategic Growth Fund            10

		
 PG High Conviction Fund              11

		     PG Income Opportunities Fund   12

		PG Global Alternatives Fund         13

		     PG New Zealand Bond Fund       14
    PERPETUAL GUARDIAN INVESTMENTS




01. Introduction
What is a Statement of Investment Policy and Objectives (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 or portfolios.

The most current version of this SIPO, along with other documentation relevant, is available on the Disclose Register at:
www.disclose-register.companiesoffice.govt.nz.


Who is involved
    ROLE                       NAME                  DESCRIPTION

                               The New Zealand       Independent supervisor of the Scheme (defined below) under the
    Supervisor                 Guardian Trust        Financial Markets Conduct Act 2013, responsible for
                               Company Limited       supervising PG Funds Limited as manager of the Scheme.

                                                     Independent entity appointed by the Supervisor to hold assets on
    Custodian                  Adminis NZ Limited
                                                     behalf of investors.

                                                     Appointed by PG Funds to perform various administrative duties
    Administrator              Adminis NZ Limited
                                                     delegated to it, including unit pricing, registry and Fund accounting.


                                                     Manager of the Scheme under the Financial Markets Conduct
    Manager                    PG Funds Limited
                                                     Act 2013.

                               Perpetual Guardian
    Underlying                                       The entity that manages the wholesale Funds underlying the retail
                               Investments Limited
    Investment Manager                               Funds in this SIPO.
                               (PG Investments)



Description of the Scheme and Funds
The PG Funds scheme (Scheme) is a managed investment scheme under the Financial Markets Conduct Act 2013,
managed by PG Funds Limited (we, us, our).

PG Funds Limited was founded in 2013, and in 2024, it was acquired by the Perpetual Guardian Group (PG Group). PG
Investments is the investment management company of the PG Group. PG Investments provides a full suite of investment
products and services to a wide range of clients of both the PG Group and other organisations.

Each Fund which falls under the Scheme is a separate trust. The Funds which fall under the Scheme, covered in this
document are the:

•    PG Strategic Growth Fund
•    PG High Conviction Fund
•    PG Income Opportunities Fund
•    PG Global Alternatives Fund
•    PG New Zealand Bond Fund
(each a Fund, and together the Funds).




                                                            STATEMENT OF INVESTMENT POLICY AND OBJECTIVES                     / 02
  PERPETUAL GUARDIAN INVESTMENTS




02. Governance and monitoring
Governance Structure
Board of Directors: The Board of Directors provides overall oversight, meeting quarterly as guided by the Board Charter.
Its responsibilities include monitoring compliance through the Compliance Assurance Programme, overseeing risk
management practices, reviewing investment performance, and addressing other key areas. In addition, the Board
evaluates overall performance each quarter, maintaining a focus on long-term investment decisions.

Board Audit, Risk, and Compliance Committee (BARCC): This is a sub-committee of the PG Group Board. It meets
three times a year and is responsible for overseeing risk management, assurance, internal controls, audit functions, and
compliance with applicable laws, regulations, and internal policies across the PG Group.

Investment Committee (IC): A management-level committee that meets quarterly to oversee the management of
investment strategies, monitor portfolio performance, and ensure adherence to investment guidelines.


Investment Performance Oversight
The Investment Committee conducts regular reviews of portfolio performance to ensure outcomes align with the Funds’
objectives and benchmarks. These reviews prioritise long-term performance, assessing results against the overarching
goals of the investment strategies.


Investment Strategy Review
The Investment Committee undertakes an annual review of the Funds’ investment strategies to ensure they remain
appropriate and aligned with the Funds’ objectives. This process considers market conditions, economic developments,
and any other relevant factors. Changes to the strategies are implemented only when necessary to address significant
shifts in circumstances or opportunities.


SIPO Review and Monitoring
The SIPO is reviewed at least annually, with additional updates made as needed. Any revisions are formally documented,
approved by the Board, and submitted to the Disclose Register. Senior management oversees the review process, with
input from the compliance and investment teams to ensure the SIPO remains aligned with regulatory requirements, the
Scheme’s Trust Deed, and the Funds’ overall objectives.
Ongoing compliance monitoring ensures adherence to the SIPO, with any breaches promptly reported to the
Supervisor in accordance with legal and contractual obligations. Updates to the SIPO are dated to indicate their
effective period, and the most current version is accessible via the Disclose Register (www.disclose-register.
companiesoffice.govt.nz) and our website.




03. Investment philosophy
We believe sound investment returns to investors can be made through effective assessment of both quantitative
and qualitative measures to identify companies and investments. We have our own signposts through our investment
approach to identify high-quality companies for investment and likewise, warning signs that help us ward off
undesirable investments.




                                                            STATEMENT OF INVESTMENT POLICY AND OBJECTIVES                  / 03
  PERPETUAL GUARDIAN INVESTMENTS




04. Key investment processes
Valuation and pricing
The valuation of underlying securities and the pricing of each Fund is outsourced to the Administrator. These functions
are carried out by the Administrator daily and we have adopted the Administrator’s unit pricing policy and framework, unit
pricing taxation policy and asset and liability valuation policy. The objective of this policy is to ensure that the investment
portfolios are fairly valued and priced, there is appropriate oversight of the outsourced pricing and valuation function, and
we comply with Financial Markets Authority requirements and the Scheme’s Trust Deed.


Conflicts of interest
Conflicts of interest occur when our investment managers’ interests may conflict with those of our clients. We are
committed to acting honestly, fairly, and professionally to ensure our clients’ best interests are upheld at all times.

To manage potential or actual conflicts of interest, we follow a Conflicts of Interest Policy that outlines processes for
identifying, declaring, and monitoring conflicts. We take all reasonable steps to prevent conflicts wherever possible and
ensure fairness to investors if they arise. Our Conflicts of Interest Policy is available on the Disclose Register at: www.
disclose-register.companiesoffice.govt.nz.

COMMON AREAS OF POTENTIAL CONFLICT AND HOW WE MANAGE THOSE:
•	Broker Selection - We are committed to achieving “best execution” for all securities transactions carried out on behalf
   of our clients.

•	Trade Allocation - All clients are treated equitably, and no client receives preferential treatment. Securities are allocated
   fairly to ensure consistent and fair treatment across all accounts.

•	Proxy Voting – We vote proxies in the best interests of our clients If a conflict of interest arises, we may abstain from
   voting, ask clients to vote on their own behalf, or engage an independent third party to vote on behalf of our clients.

Our approach ensures that conflicts are managed transparently and fairly, maintaining the integrity of our investment
process and prioritising the interests of our clients.


Investment
EQUITY INVESTMENT PROCESS
Our approach to investing in company shares is guided by four core criteria:

1. Business Quality – Emphasis on strong management and sustainable practices.
2. Financial Structure – Evaluation of factors such as debt levels and margins.
3. Industry Trends – Analysis of key drivers and challenges within the company’s broader industry.
4. Growth Opportunities – Identification of opportunities specific to the company.

To construct portfolios aligned with our philosophy, our investments employ a combination of top-down and bottom-up
analyses, supported by ongoing research and monitoring.




                                                              STATEMENT OF INVESTMENT POLICY AND OBJECTIVES                       / 04
  PERPETUAL GUARDIAN
  PERPETUAL GUARDIANINVESTMENTS
                     INVESTMENTS




INVESTMENT PROCESS STEPS

 1. Top-Down Analysis - We begin by screening a broad universe of companies using filters based on our core criteria, such
    as earnings, margins, and leverage. We also research key industry themes to evaluate growth prospects, structural
    dynamics, challenges, and risks.
 2. Bottom-Up Analysis - Next, we take a closer look at the candidates identified through our top-down screening. We assess
    individual company factors, including the quality of management and the company’s position within its industry.
 3. SWOT Analysis and Ranking - We then apply a Strengths, Weaknesses, Opportunities, and Threats (SWOT) analysis to
    each company. Using this, we rank the candidates and identify the most suitable investments for inclusion in our portfolios.
 4. Ongoing Monitoring and Risk Assessment - We continually review and assess the individual investments in our portfolios,
    as well as the industries they belong to. This ensures our investment process remains dynamic and responsive to changes
    in market conditions, while staying true to our investment philosophy.




The complete investment process is shown below:




                            Ongoing                                                   Universe
                            relative value                                            Screening
                            assessment        4. Review                               Industry
                                                                 1. Analysis          Themes
                                              and Risk
                                                                 Top Down
                                              Assessment
                                              Monitoring




                                              3. Security        2. Analysis
                                              Assessment         Bottom Up
                            SWOT              Bottom Up                               Management
                            analysis
                                                                                      Industry
                            Relative
                                                                                      position
                            ranking




FIXED INTEREST INVESTMENT PROCESS

We undertake a top down and bottom-up approach to fixed interest investing. From the top down we assess the
macroeconomic environment, in conjunction with geopolitical considerations, and monetary and fiscal policies driving the
relative attractiveness of fixed income investments. From the bottom up we undertake an appraisal of issuers. The process
steps are described in detail below:

Our fixed income strategy combines top-down macroeconomic analysis with bottom-up issuer assessment to construct
robust portfolios.




                                                            STATEMENT OFOF
                                                              STATEMENT  INVESTMENT POLICY
                                                                           INVESTMENT POLICYAND
                                                                                             ANDOBJECTIVES
                                                                                                 OBJECTIVES // 05
                                                                                                               05
    PERPETUAL GUARDIAN INVESTMENTS
   PERPETUAL GUARDIAN
   PERPETUAL  GUARDIANINVESTMENTS
                        INVESTMENTS




INVESTMENT
INVESTMENTPROCESS
           PROCESSSTEPS
                   STEPS
1. Macro Analysis (Top-Down) - We evaluate global and domestic macroeconomic conditions, considering factors such
  1. Macro Analysis (Top-Down) - We evaluate global and domestic macroeconomic conditions, considering factors such as
    as geopolitical influences, trade dynamics, and central bank policies. We analyse yield curves to uncover key investment
      geopolitical influences, trade dynamics, and Central Bank policies. We analyse yield curves to uncover key investment
    themes and identify potential opportunities in the fixed income market.
      themes and identify potential opportunities in the fixed income market.
   Yield
2.2.      Curve
      Yield      Assessment
             Curve  Assessment (Bottom-Up)
                                   (Bottom-Up)-We-We
                                                   review  current
                                                       review      market
                                                               current     pricing of
                                                                         market       assets
                                                                                 pricing of to
                                                                                            assetsassess  their relative
                                                                                                     to assess            value. From
                                                                                                                  their relative   value.there,
                                                                                                                                           From
    we  select
      there, webonds
                selecthat bestthat
                        bonds   alignbest
                                      withalign
                                           our with
                                               strategy,
                                                      ourfocusing
                                                          strategy,onfocusing  such as
                                                                       factors on       sector,
                                                                                   factors such  credit quality,credit
                                                                                                   as sector,    maturity,  and duration.
                                                                                                                        quality, maturity, and
3. Sduration.
      ecurity Assessment (Bottom-Up) - We use our STATIC framework to score issuers, evaluating their stability,
      Security Assessment
  3.transparency,    business (Bottom-Up)
                               position, and -independent
                                                We use our STATIC
                                                              ratings. framework    to score
                                                                        This structured       issuers,helps
                                                                                         approach       evaluating
                                                                                                              us make their  stability,
                                                                                                                          informed
      transparency, business position, and independent ratings. This structured approach helps us make informed decisions
    decisions about the bonds we include in our portfolios. STATIC stands for Stable, Too important to fail, Alignment with
      about the bonds we include in our portfolios. STATIC stands for Stable, Too important to fail, Alignment with guidelines,
    guidelines, Transparency, Institutional support, and Creditworthiness—providing a consistent, repeatable framework to
      Transparency, Institutional support, and Creditworthiness—providing a consistent, repeatable framework to assess credit
    assess credit strength.
      strength.
4.4.Ongoing
      OngoingMonitoring
                Monitoring- -We
                              Wecontinually
                                    continuallymonitor
                                                monitor macroeconomic
                                                          macroeconomic    factors,
                                                                             factors,portfolio
                                                                                       portfoliopositioning,
                                                                                                  positioning,andandissuer  ratings.
                                                                                                                       issuer  ratings. This
    This  allows
      allows      us to
              us to     maintain
                    maintain      alignment
                             alignment    withwith
                                                ourour  investment
                                                    investment        objectives
                                                                  objectives  andand   proactively
                                                                                   proactively      manage
                                                                                                 manage    riskrisk
                                                                                                                 in ain a dynamic
                                                                                                                      dynamic     market
      environment.
    market environment.

This ongoing process is shown below:




                                 Ongoing                                                       Macroeconomic
                                 relative value                                                Analysis
                                 assessment                                                    Market Risk
                                                    4. Review
                                                                                               Cycle Phase
                                                    and Risk               1. Analysis
                                                    Assessment             Top Down
                                                    Monitoring



                                                    3. Security            2. Yield Curve
                                 Relative           Assessment             Assessment
                                 Value              Bottom Up              Bottom Up
                                                                                                 Shape of
                                 Assessment
                                                                                                 Yield Curve
                                 (Buy the
                                 “Best Bond”)




ALL INVESTMENT FUNDS
For both equity and New Zealand fixed interest our Investment Team meetings bring together all our recommendations
where investment ideas are formally presented and peer reviewed for potential implementation. These meetings are designed
to promote collaboration on investment decisions and leverage the team's experience and knowledge, both in New Zealand
and overseas, held amongst the team. The individual manager is responsible for final selection of the securities to include
within the specific portfolio they are responsible for.




                                                                    STATEMENT OFOF
                                                                      STATEMENT  INVESTMENT POLICY
                                                                                   INVESTMENT POLICYAND
                                                                                                     ANDOBJECTIVES
                                                                                                         OBJECTIVES // 06
                                                                                                                       06
    PERPETUAL GUARDIAN INVESTMENTS




External managers
When we engage third-party managers, we undertake a rigorous selection and monitoring process to ensure they align
with our investment objectives and philosophy. Our due diligence process focuses on identifying managers who share our
values and commitment to disciplined, high-quality investment practices.

Key Considerations in Manager Selection:
•     A well-defined and disciplined investment process.
•     An investment style that aligns with our philosophy and the objectives of the Funds.
•     The experience and capability of the investment team.
•     A proven performance track record.
•     Accessibility and transparency of the investment management team.
•     Robust governance and compliance frameworks.
•     The liquidity of the investment vehicle and its ability to meet the Funds’ liquidity requirements.

Once a manager is appointed, we regularly assess their performance, holdings, and adherence to their stated
investment process and disclosures. This review ensures the manager’s approach continues to align with our
expectations and Fund objectives.

Any concerns identified during our assessments are promptly addressed with the manager for resolution. We periodically
report our findings to the Investment Committee and retain the discretion to add or remove managers as required to best
serve the interests of our investors.


Rebalancing
Rebalancing is the process used to keep the portfolio aligned with its intended investment structure. Each asset in the
portfolio has a target position, with bands set around that target (also called “permitted ranges”) to accommodate national
market movements.

Over time, changes in asset values can cause portfolio weights to move away from their targets. If an asset moves outside
its permitted band, the portfolio may no longer reflect the desired risk and return profile.

To address this, a Rebalancing Policy is followed. The portfolio is monitored daily, and when an asset breaches its band,
trades are made to return it closer to target. This typically involves reducing positions that have increased in weight and
adding to those that have decreased.

Key features of the rebalancing process:

- Target positions with bands – Each asset has a defined target and associated tolerance band. Rebalancing is triggered
    when weights move outside these bands.

- Daily monitoring – The portfolio is reviewed daily, or in response to significant market movements.

- Efficient execution – Rebalancing is carried out with consideration for transaction costs, liquidity, and tax impacts.

- Consistent application – The approach is applied uniformly across all relevant portfolios to ensure fairness
    and consistency.

This disciplined process supports the Funds’ long-term investment strategy by maintaining alignment with their intended
risk profile and investment objectives.




                                                                STATEMENT OF INVESTMENT POLICY AND OBJECTIVES                 / 07
  PERPETUAL GUARDIAN INVESTMENTS




Short selling, borrowing, derivatives
and foreign currency exposures
The table below outlines each Fund’s permitted use of short selling, borrowing, derivatives, and foreign currency exposure.
The Funds are unhedged by default with respect to foreign currency exposure but may choose to hedge this exposure
when considered beneficial. Derivatives may be used to adjust exposure to underlying assets, including for the purpose
of leverage. Foreign currency derivative positions are not required to be cash-backed; however, such positions are actively
monitored and regularly closed out to manage risk.



                                                                                                        FOREIGN
 FUND                                 SHORT SELL       BORROW CASH          DERIVATIVES
                                                                                                CURRENCY EXPOSURE



 PG Strategic Growth Fund                   No                 No                 Yes                    0-100%



 PG High Conviction Fund                    No                 No                 Yes                    0-100%



 PG Income Opportunities Fund               No                 No                 Yes                    0-100%



 PG Global Alternatives Fund                No                 No                 Yes                    0-100%



 PG New Zealand Bond Fund                   No                 No                 Yes                      n/a




                                                            STATEMENT OF INVESTMENT POLICY AND OBJECTIVES                     / 08
  PERPETUAL GUARDIAN INVESTMENTS




05. Description of Asset Classes
Each Fund has different limits and target exposures across asset classes. The definitions of these asset classes are
provided below. Where a Fund invests in other internally managed Funds, we apply a look-through approach to identify
the underlying exposures. For externally managed Funds, classification is based on the predominant exposure of the
underlying investments in line with the definitions below.




  ASSET CLASS                         DESCRIPTION OF ASSET CLASS




  Cash and Cash Equivalents           Cash at bank.




                                      New Zealand dollar denominated fixed interest securities, loans, interest rate
  New Zealand Fixed Interest
                                      swaps, term deposits and other yield-bearing investments.



                                      Fixed interest securities, loans, interest rate swaps, term deposits and other yield-
  International Fixed Interest
                                      bearing investments based outside New Zealand.



                                      Australasian-based equity including ordinary, preference and partly paid shares,
  Australasian Equities
                                      convertible securities, warrants and exchange-traded Funds (ETFs).


                                      Equity based outside New Zealand and Australia, including ordinary, preference
  International Equities              and partly paid shares, convertible securities, warrants and exchange traded
                                      Funds (ETFs).



                                      Equities which are not listed on a public stock-exchange. These could fall under
  Unlisted Equities
                                      Australian, New Zealand or International Equities.


                                      Futures, options, commodities, long/short strategies, event-driven strategies,
  Other                               market neutral style premia strategies and other investments that do not meet the
                                      criteria of the above categories.




                                                             STATEMENT OF INVESTMENT POLICY AND OBJECTIVES                    / 09
PERPETUAL GUARDIAN INVESTMENTS




06. Fund Schedules

PG STRATEGIC GROWTH FUND

PG HIGH CONVICTION FUND

PG INCOME OPPORTUNITIES FUND

PG GLOBAL ALTERNATIVES FUND

PG NEW ZEALAND BOND FUND




                                 STATEMENT OF INVESTMENT POLICY AND OBJECTIVES   / 10
  PERPETUAL GUARDIAN INVESTMENTS




PG Strategic Growth Fund
OBJECTIVE/DESCRIPTION
The Fund aims to achieve long-term capital growth by investing predominantly in international equites, including Exchange
Traded Funds (ETFs) listed throughout the world.

STRATEGY
The Fund employs an active management strategy, focusing on a select group of between typically 10 and 50
predominantly international companies. This focused approach allows careful selection and management of investments
and not passively investing to replicate any given index. While the Fund primarily invests in international markets, it retains
the ability to invest in shares in Australasia. Typically, the Fund will be fully invested however cash or cash equivalents may
be held to reduce risk and increase flexibility. The primary objective of the Fund is to achieve long-term capital growth.

MINIMUM RECOMMENDED INVESTMENT TIME FRAME
5 years

PERFORMANCE BENCHMARK
MSCI World Index (Price Return, in NZD)

While the Fund uses this as a benchmark, it is managed without strictly following or being tied to it.

MARKET INDEX
This Fund is not managed against a specific market index. Nevertheless, we reference the following as a market index for
the Fund.

MSCI World Index (Price Return, in NZD)

TARGET AND PERMITTED RANGES


                                                                                                              PERMITTED
 ASSET CLASS                                                                             TARGET
                                                                                                               RANGES

 Cash and Cash Equivalents                                                                  2%                   0-30%

 International Equities                                                                     98%                 70-100%

 Australasian Equities                                                                      0%                   0-30%

 International Fixed Interest                                                               0%                   0-20%

 Unlisted Equities                                                                          0%                   0-10%




                                                              STATEMENT OF INVESTMENT POLICY AND OBJECTIVES                   / 11
  PERPETUAL GUARDIAN INVESTMENTS




PG High Conviction Fund
OBJECTIVE/DESCRIPTION
The Fund’s primary objective is to achieve long-term capital appreciation through strategic investment in a select group
of New Zealand and Australian equities. The strategy allows the Fund to navigate market fluctuations while aiming for
sustained growth over extended periods.

STRATEGY
The Fund employs an active management strategy, focusing on a select group of between typically 10 and 30 companies
listed in Australia and New Zealand. This focused approach allows careful selection and management of investments and
not passively investing to replicate an index. While the Fund primarily invests in Australasian markets, it retains the ability
to invest in shares listed outside this region. Typically, the Fund will be fully invested however cash or cash equivalents
may be held to reduce risk and increase flexibility. The primary objective of the Fund is to achieve long-term capital growth.

MINIMUM RECOMMENDED INVESTMENT TIME FRAME
5 years

PERFORMANCE BENCHMARK
50% S&P / NZ All Shares (Price Return, in NZD)

50% S&P / ASX 200 (Price Return, in NZD)

While the Fund uses this as a benchmark, it is managed without strictly following or being tied to it.

MARKET INDEX
50% S&P / NZ All Shares (Price Return, in NZD)

50% S&P / ASX 200 (Price Return, in NZD)

While the Fund uses this as a market index, it is managed without strictly following or being tied to it.

TARGET AND PERMITTED RANGES


                                                                                                               PERMITTED
 ASSET CLASS                                                                              TARGET
                                                                                                                RANGES

 Cash and Cash Equivalents                                                                   2%                    0-30%

 Australasian Equities                                                                       98%                 70-100%

 Unlisted Equities                                                                           0%                    0-10%

 International Equities                                                                      0%                    0-30%

 International Fixed Interest                                                                0%                    0-30%




                                                              STATEMENT OF INVESTMENT POLICY AND OBJECTIVES                       / 12
  PERPETUAL GUARDIAN INVESTMENTS




PG Income Opportunities Fund
OBJECTIVE/DESCRIPTION
The Fund aims to provide a higher level of income from a diversified investment portfolio of equity and fixed income
securities alongside moderate capital growth over the long-term.

STRATEGY
The Fund combines quantitative analysis overlayed with qualitative, fundamental research across Australasian
investments. The Fund primarily invests in select equities that typically offer compelling dividend yields, fixed interest
securities and cash. Through this approach the Fund provides diversification of investment types and income streams and
providing investors with the potential for regular distributions.

MINIMUM RECOMMENDED INVESTMENT TIME FRAME
3 years

PERFORMANCE BENCHMARK
NZ Official Cash Rate + 2.5%

MARKET INDEX
While this Fund is not managed against a specific market index, the following is provided as its returns are likely to be
useful to investors when assessing the performance of the Fund as a whole.

50% Bloomberg NZ Bond Composite 0+ Yr (Total Return, in NZD)

25% S&P / ASX 200 (Price Return, in NZD)

25% S&P / NZ All Shares (Price Return, in NZD)

TARGET AND PERMITTED RANGES


                                                                                                              PERMITTED
 ASSET CLASS                                                                             TARGET
                                                                                                               RANGES

 Cash and Cash Equivalents                                                                   2%                   0-30%

 Australasian Equities                                                                      50%                  20-80%

 New Zealand Fixed Interest                                                                 48%                   0-60%

 International Equities                                                                      0%                   0-40%

 International Fixed Interest                                                                0%                   0-40%

 Unlisted Equities                                                                           0%                   0-10%




                                                               STATEMENT OF INVESTMENT POLICY AND OBJECTIVES                 / 13
  PERPETUAL GUARDIAN INVESTMENTS




PG Global Alternatives Fund
OBJECTIVE/DESCRIPTION
The Fund aims to deliver attractive long-term returns by investing in a diversified portfolio of global alternative strategies
through managed Funds. These may include but are not limited to equity long/short strategies, fixed interest strategies
focused on factors such as capital structure or rate spreads, global macro strategies such as thematics and relative value,
and style premia strategies such as value, momentum and interest carry. The Fund is designed to complement traditional
equity and bond portfolios by providing exposure to differentiated sources of return with a focus on capital growth,
diversification, and risk-adjusted outcomes.

STRATEGY
The Fund employs an active, multi-asset strategy focused on identifying and allocating capital to a carefully selected group
of global alternative investments. The Fund invests through external Fund managers who demonstrate strong alignment
with the Fund’s objectives, possess specialist expertise, and maintain a disciplined investment process. External managers
are selected based on rigorous due diligence, including assessment of their track record, investment philosophy, risk
management practices, and structural alignment with investors.

MINIMUM RECOMMENDED INVESTMENT TIME FRAME
5 years

PERFORMANCE BENCHMARK
NZ Official Cash Rate + 3%

MARKET INDEX
While this Fund is not managed against a specific market index, the following information is provided because the returns
may still be helpful for investors when assessing the Fund’s overall performance. The weightings shown are based on an
estimated look-through of the Fund’s underlying managed Fund exposures. However, when categorising underlying Funds
into asset classes for the Target and Permitted Ranges, externally managed Funds are classified based on the predominant
exposure of their underlying investments.
45% MSCI World (Price Return, in NZD)
20% Bloomberg Global Agg Total Return Index (Price Return, in NZD)
35% S&P / NZX Bank Bills 90-Day Index (Total Return, in NZD)

TARGET AND PERMITTED RANGES
The Fund targets exposures to the following investments:


                                                                                                              PERMITTED
 ASSET CLASS                                                                              TARGET
                                                                                                               RANGES

 Cash and Cash Equivalents                                                                   2%                   0-20%

 Other                                                                                      98%                  80-100%

 International Equities                                                                      0%                   0-50%




                                                              STATEMENT OF INVESTMENT POLICY AND OBJECTIVES                      / 14
  PERPETUAL GUARDIAN INVESTMENTS




PG New Zealand Bond Fund
OBJECTIVE/DESCRIPTION
The Fund is designed to provide regular income from predominantly New Zealand investment grade corporate bonds.

STRATEGY
The Fund predominantly invests in select New Zealand corporate fixed interest securities. The Fund employs active
duration management, adjusting the portfolio’s sensitivity to interest rate changes based on market conditions and
economic outlooks. This approach allows for tactical positioning in response to anticipated interest rate movements,
potentially enhancing returns and mitigating risks associated with bond price fluctuations.

MINIMUM RECOMMENDED INVESTMENT TIME FRAME
3 years

PERFORMANCE BENCHMARK
Bloomberg NZ Bond Composite 0+ Yr (Total Return, in NZD)

MARKET INDEX
Bloomberg NZ Bond Composite 0+ Yr (Total Return, in NZD)

TARGET AND PERMITTED RANGES


                                                                                                         PERMITTED
 ASSET CLASS                                                                          TARGET
                                                                                                          RANGES

 Cash and Cash Equivalents                                                                0%                0-20%

 New Zealand Fixed Interest                                                             100%               80-100%




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PGINVESTMENTS.NZ
