The public interest is best served by access to markets in which participants can make well-informed choices free from undue constraints. Markets can only be free and efficient if they exclude those who act dishonestly and unfairly or otherwise distort their proper functioning.

As a member of the Financial Services Council, MPG Funds Management Limited (AFSL 227114) (“MPG”) seeks to comply with FSC Standard No: 1 Code of Ethics & Code of Conduct (version dated 4 May 2018).  MPG’s Code of Ethics and Code of Conduct are set out below.

Code of Ethics

The General Duty – the public interest:

MPG has an overriding general duty to establish and maintain a strong ethical foundation for the market in financial products and services and its investment activities.

Specific Duties – subject to the general duty:

Primacy of Investors

MPG gives primacy to the duty owed to its Investors.

Fairness and equity

MPG treats all stakeholders in a manner that is fair and equitable.

Trustworthiness

MPG will:

• conduct its affairs in a manner that merits the trust and good opinion of Investors and other stakeholders; and
• establish and publish its ethical frameworks; nominating core values and principles that define the elements of their internal culture and to regulate dealing(s) with all stakeholders.

Applying a high standard of conduct

MPG will:

• ensure that the tasks performed are undertaken honestly and with due care, competence and diligence;

• ensure its people are properly trained and perform their duties and obligations to a high standard of professionalism; and

• develop and maintain a high standard of risk and compliance practice and implement solid foundations for the management and oversight of that practice; periodically review its effectiveness, and promptly and transparently address any deficiencies which are identified.

Managing conflicts of interest or duty

MPG will not allow conflicts of interest or duty to influence our actions. In addressing any competing interests MPG will ensure that:

• Investors’ interests are of paramount importance in all decisions and transactions;
• the execution of Investors’ requirements comes before attention is given to those of MPG;
• MPG’s conduct contributes to markets operating in an efficient and informed manner;
• MPG places its duty to Investors ahead of those owed to their shareholders and/or others; and
• MPG avoids circumstances where we may be perceived to have a conflict.

In accordance with the Rule of Law

MPG will give effect to the spirit as well as the letter of the law.

Code of Conduct

Applying the Code of Ethics

MPG will apply all of the tenets of the Code of Ethics specified above.

Fair and appropriate competition

While vigorous competition within the industry is encouraged, MPG will always compete fairly and in a manner that increases trust and confidence in the Financial Services Sector and its subsectors.

Providing clear, concise and effective disclosure

MPG will provide disclosures to Investors and potential Investors that are clear, concise and effective (whether in written or non-written form) and in a manner consistent with any relevant laws.

If practicable, such disclosure should extend beyond the minimum requirements of any relevant law, contain relevant information and be presented so as to enable the Investors to make an informed decision and not be misleading. This enables sound investment decisions to be made by Investors and potential Investors and should include, but not be limited to, disclosures about any conflicts of interest and disclosures of any fees and charges that are likely to be incurred.

Managing Conflicts

At a minimum, MPG will actively address its obligations, in relation to conflicts, as arise under the law.

MPG will have in place adequate arrangements to assess existing and potential areas of conflict arising from internal or external interests or duties by identifying:

• circumstances that may cause a conflict of interest at an individual, business or entity level;
• behaviour that may affect the independence of decisions at an individual, business, entity, product or service level; and

• any other matters or circumstances which may give rise to any potential conflicts.

Confidentiality & Appropriate Use of Information

MPG has an obligation to comply with all relevant privacy laws in Australia and overseas (where applicable).

Without limiting any other legal obligations, MPG will respect and preserve confidential information by adopting and implementing a proactive and measured approach to:

• safeguarding information regarding their Investors that is in its possession;
• avoiding the misuse of private information obtained in the course of its business activities; and

• keeping, as reasonably practicable, up to date with the latest cyber security measures to keep Investor data safe.

Private information is not to be misused to gain an improper commercial or personal advantage.

MPG will neither create nor use false or misleading information by act or omission.

Development of talent

In addition to any relevant legal requirements, MPG will comply with its obligation to have in place, and to make reasonable efforts to implement, proper processes intended to ensure that our people (including agents engaged in service delivery):

• have appropriate standards of skill and competence;
• are well supervised;
• are diligent and take proper care when discharging our duties and obligations toward Investors and other stakeholders; and
• are supported to develop the relevant knowledge, skills and dispositions through access to training and education.

MPG will comply with its obligation to have in place, and to make reasonable efforts to implement, proper processes intended to ensure that we do not hire a person who:

• is unethical;
• lacks integrity; or
• has otherwise brought, or could bring, MPG or the industry into disrepute.

Promotion and support of ethical decision-making behaviours through sound corporate governance

MPG will explicitly support the FSC standards of ethical and professional conduct, and of corporate governance.

MPG will reinforce appropriate ethical behaviours and practices at all levels by:

• developing and embedding an ethical decision-making framework;
• utilising training or other measures to embed and promote a culture of ethical decision making;
• evaluating and refining our organisational culture; and
• providing and championing ‘in confidence’ and safe, ‘whistle-blower-type’ reporting mechanisms for raising concerns about what is perceived to be inappropriate practice.