36
Bentham Global Income Fund Product Disclosure Statement 30 September 2017 Bentham Global Income Fund ARSN 105 898 271 APIR CSA0038AU Responsible Entity Fidante Partners Services Limited ABN 44 119 605 373 AFSL 320505

Long Form PDS NZ Master Shell - · PDF fileAboutthisProductDisclosureStatement(PDS) ThisdocumentprovidesinformationtohelpinvestorsandtheiradvisersassessthemeritsofinvestingintheBenthamGlobal

Embed Size (px)

Citation preview

Bentham Global Income Fund

Product Disclosure Statement30 September 2017

Bentham Global Income FundARSN 105 898 271APIR CSA0038AU

Responsible EntityFidante Partners Services LimitedABN 44 119 605 373AFSL 320505

About this Product Disclosure Statement (PDS)

This document provides information to help investors and their advisers assess the merits of investing in the Bentham GlobalIncome Fund (ARSN 105 898 271) (Fund). No other Fund is offered in this PDS. You should read this document in full beforemaking an investment decision.

In preparing this PDS we did not take into account your particular investment objectives, financial circumstances or needs. Asinvestors’ needs and aspirations differ, you should consider whether investing in the Fund is appropriate for you in light of yourparticular objectives, financial circumstances or needs. You should also obtain independent advice before investing in the Fund,particularly about individual matters such as taxation, retirement planning and investment risk tolerance.

Updated information

The information in this PDS is up-to-date at the time of preparation. However, some information and terms (see below) can changefrom time to time. If a change is considered materially adverse, we will issue a supplementary or new PDS.

For updated or other information about the Fund (such as performance), please consult your financial adviser, visit our website,or call our Investor Services team. We will also send unitholders a copy of any incorporated information and updated informationfree of charge upon request.

Important notices

Fidante Partners Services Limited (ABN 44 119 605 373, AFSL 320505) (Fidante Partners, we, our, us, Responsible Entity) isthe Responsible Entity of the Fund and issuer of this PDS. Our ultimate parent is Challenger Limited (ABN 85 106 842 371). Wehave appointed Bentham Asset Management Pty Ltd (ABN 92 140 833 674, AFSL 356199) (Bentham or the investmentmanager)as the investment manager of the Fund.

Neither Fidante Partners, nor any related entity, nor Bentham, guarantees the repayment of your capital or the performance ofyour investment or any particular taxation consequences of investing.

Fidante Partners authorises the use of this PDS as disclosure to investors and potential investors who wish to access the Fundeither directly (Direct Investors), or through an IDPS operator (Indirect Investors). This PDSmay also be used for direct investmentby IDPS operators. Please refer to ‘Indirect investors’ in 'Additional information'.

By investing in the Fund, you confirm that you have received a copy of the current PDS to which this investment relates, that youhave read it and agree to the terms contained in it, and that you agree to be bound by the terms of the current PDS and the currentconstitution of the Fund (each as amended from time to time).

The offer or invitation to subscribe for units in the Fund under this PDS is only available to persons receiving this PDS in Australiaor New Zealand and is subject to the terms and conditions described in this PDS. The information in this PDS is of a general natureand is based on our understanding of the Australian tax laws, as at the date of this document, as they relate to Australian residentindividual taxpayers who hold their investment on capital account and does not take into account the tax treatment of New Zealandresident taxpayers.

The information in this PDS is up-to-date at the time of preparation. However, some information can change from time to time. Ifa change is considered materially adverse we will issue a replacement PDS. For updated or other information about the Fund(such as performance), please contact your financial adviser, call our Investor Services team, or visit our website. We will sendyou a copy of the updated information free of charge upon request.

Consent

Bentham has provided consent to the statements about it in the form and context in which it is included. Benthamwas not otherwiseinvolved in the preparation and distribution of this PDS and is not responsible for the issue of this PDS, nor is it responsible forany particular part of this PDS other than those parts that refer to it. Bentham has not withdrawn its consent before the date of thisPDS.

Table of contents

4About Bentham

5Features at a glance

7How we invest your money

10Risks of investing in managed investment schemes

13Fees and other costs

20Making, withdrawing, and monitoring your investment

27How managed investment schemes are taxed

29Additional information

32Glossary

34Important information for New Zealand investors

Contact detailsInvestor Services team 13 51 53 (during Sydney business hours) or +612 9994 7000 from outsideAustralia (during Sydney business hours)

Phone

[email protected]

02 9994 6666Fax

Fidante Partners Reply Paid 86049 Sydney NSW 2001Mail

www.fidante.com.auWebsite

Bentham Global Income Fund 3

Bentham is a specialist fixed interest and creditinvestment manager. Bentham actively manages anumber of high yielding funds with varying risk profiles.The portfolios are designed to generate income whilediversifying risk in global credit markets. Bentham’s goalis to deliver higher income to investors than can generallybe achieved in traditional fixed interest and equitymarkets.

Bentham’s investment philosophy is based on a strongcredit culture and a systematic investment process, witha focus on the preservation of principal and protectionagainst downside risk. The founders of Benthampreviously worked together as part of the CreditInvestment Group of Credit Suisse Alternative CapitalInc. They are still managing the same portfolios. If youwould like more information on Bentham, please visittheir website www.benthamam.com.

About the Responsible EntityFidante Partners is the Responsible Entity of the Fund.As Responsible Entity, we issue units in the Fund andare legally responsible to the unitholders of the Fund forits operation.

Fidante Partners forms long-term alliances with talentedinvestment professionals to create, grow and supportspecialist, boutique funds management businesses. Wehave appointed Bentham as the investment manager ofthe Fund. We provide back office, marketing, distribution,administration, and compliance support services toBentham, allowing Bentham the freedom to focus oninvesting and managing the assets of the Fund.

A related entity of Fidante Partners has a partial equitystake in Bentham. Neither we, nor any of our relatedentities, nor Bentham, guarantee the repayment of yourcapital or the performance of your investment or anyparticular taxation consequences of investing.

Significant features and benefits ofthe Fund

Active management: Investments are activelymanaged with allocations across different creditsectors with a focus on generating stable income.Diversification: The Fund allows access toinvestment opportunities and diversification thatindividual investors usually cannot access on theirown.Global focus: The Fund provides more investmentopportunities and diversity when compared withdomestic fixed income markets.Experienced investment team: The Fund offersaccess to investment professionals who specialise indomestic and global credit markets.Diversified income: The Fund invests in at least 400different issuers thereby offering diversified sourcesof income and returns.Income: The Fund aims to provide reliable andconsistent monthly income.

4 Bentham Global Income Fund

About Bentham

Refer to Section

‘Making,withdrawing andmonitoring yourinvestment’

Minimum transactionand balancerequirements1

$10,000 or $1,000 when a Regular Savings Plan is established.Initial investment

$1,000 or $100 per month when a Regular Savings Plan is established (withan initial investment of $1,000).

Additional investment

$1,000 (minimum balance must be maintained).Minimum withdrawal

$10,000 or $1,000 with a Regular Savings Plan.Minimum balance

If you are an indirect investor, you need to comply with any minimum transaction and balancerequirements of your IDPS operator.

Indirect investors

‘Fees and othercosts’

Fees and other costs2,3,4

NilContribution fee

NilWithdrawal fee

The management costs of the Fund are 0.77% p.a. of the net asset value ofthe Fund and are comprised of the following components:

Management fee: 0.72% p.a. of the net asset value of the Fund.

Indirect costs:We estimate the indirect costs of the Fund will be 0.00% p.a.of the net asset value of the Fund.

Recoverable expenses:We estimate the recoverable expenses of the Fundwill be 0.05% p.a. of the net asset value of the Fund. We currently payinvestment expenses of the Fund from our management fee and do not recoverthese from the Fund. We may, however, recover any normal operatingexpenses and abnormal expenses from the Fund.

Management costs4

+0.35% / -0.35% per transaction. This amount may change if the estimate ofthe underlying transaction costs changes.

Buy/sell spread

‘Risks of investingin managedinvestmentschemes’

A degree of risk applies to all types of investments, including investments inthe Fund. The significant risks are described in ‘Risks of investing in managedinvestment schemes’.

Risks of investing in theFund

‘Making,withdrawing andmonitoring yourinvestment’

Making andwithdrawingyour investment

Generally, you can invest or withdraw at any time subject to certain limits inthe Fund’s constitution and this PDS.

Investment andwithdrawing

Valid transaction requests must be received by us prior to 3:00pm Sydneytime to be processed that day and withdrawal requests will usually be paidwithin five business days.

Transaction cut-off times

‘Additionalinformation’

Distribution payments

The Fund generally pays distributions monthly; however, there may be periodsin which reduced or no distributions are paid and we do not guarantee anylevel of distributions.

Frequency

Reinvested into the Fund as additional units or paid to your nominated account.For indirect investors, distributions will be paid to your IDPS operator as soonas practicable after the end of the distribution period.

Payment methods

Bentham Global Income Fund 5

Features at a glance

‘Additionalinformation’

Valuations and pricing

The Fund’s assets are usually valued each NSW business day.Valuing the Fund’s assets

Unit prices are usually calculated each NSW business day.Unit pricing

‘Making,withdrawing andmonitoring yourinvestment’

Investor reporting

We generally send transaction confirmations for investments and withdrawals.Transaction confirmations

We send quarterly periodic statements as at 31March, 30 June, 30 Septemberand 31 December with details of transactions and any income distributions.

Regular reporting

We send an annual tax statement.Annual tax reporting

1. We may, at our discretion, accept lower minimum transaction and balance amounts.

2. Unless otherwise stated, all fees and costs are quoted inclusive of any Goods and Services Tax (GST) and net of any input tax credits (ITCs) or reduced input taxcredits (RITCs) as applicable. Where available, the prescribed RITC rate is currently 55% or 75%, depending on the nature of the fee or cost incurred. Due to theimpact of GST, ITC and RITC calculations, actual fees may vary slightly from those stated, which may be rounded to two decimal places.

3. For certain Wholesale Clients (as defined in the Corporations Act 2001 (Cth)) we may, at our discretion, negotiate, rebate or waive all or part of our fees. Pleaserefer to 'Can fees be different for different investors?' in 'Fees and other costs'.

4. All estimates of fees and costs in this section are based on information available as at the date of this PDS and reflect the Responsible Entity's reasonable estimatesof the typical fees for the current financial year. All other management costs reflect the actual amount incurred for last financial year and the Responsible Entity'sreasonable estimates where information was not available as at the date of this PDS. Themanagement costs used in the example of annual fees and costs calculationis based on the actual management costs paid for the Fund for the previous financial year. All figures have been rounded to two decimal places. Please refer to‘Additional explanation of fees and costs’ for more information on management costs.

6 Bentham Global Income Fund

The Fund aims to provide exposure to global credit markets and to generate income with some potentialfor capital growth over the medium to long term. The Fund aims to outperform its composite benchmarkover the suggested minimum investment timeframe.

Investment returnobjective

At least three yearsMinimumsuggestedinvestmenttimeframe

50% Bloomberg AusBond Composite Bond Index50% Bloomberg AusBond Bank Bill Index

Benchmark

Medium risk – the Fund offers the potential for favourable returns over the long term with some incomebut could potentially exhibit moderate levels of volatility over the short to medium term.

Risk level

The Fund is managed by Bentham who seeks to provide a diversified exposure to domestic and globalcredit markets with a focus on generating stable investment income.

The Fund is intended to be suitable for investors seeking to invest for at least three years, with a preferencefor stable income with minimised risk of capital loss. Definitions of the important investment terms areprovided in the ‘Glossary’.

Investment approach

The Fund is actively managed and focused on generating stable investment income by providing adiversified exposure to domestic and global credit markets while managing interest rate risk and currencyrisk.

Bentham seeks to add value through actively managing allocations across different credit sectors, tradingof individual securities and managing its interest rate and currency risk.

Benthammanages the Fund on a top-down basis. Active asset allocations are made according to quarterlyforecasts of prospective risk-adjusted returns across a range of credit sectors. Drawing on a combinationof both experience and strong relationships with specialist investment managers, Bentham seeks outand identifies global investment opportunities in credit markets with the aim to generate income withsome potential for capital growth.

Bentham utilises a bottom-up analysis to select individual investments based on credit fundamentalsand market information.

The Fund must maintain a minimum investment of 50% in investment grade rated securities. Benthamaims to minimise credit risk with a focus on capital preservation and a high diversity of investments whichwould otherwise be difficult to achieve without access to global markets.

Investment universe and portfolio construction

The Fund invests in global credit and fixed interest markets. The Fund’s investments include, but are notlimited to, Australian and global hybrid securities, global high yield bonds, global syndicated loans,investment grade securities, global capital securities, asset backed securities, equities and derivatives.

The Fund uses derivatives as a risk management tool, including currency swaps, interest rate swapsand credit default swaps. The final portfolio reflects Bentham’s rigorous fundamental approach to creditportfolio management. Portfolio construction guidelines promote diversification and credit quality bylimiting the maximum portfolio exposure to any single non-investment grade security to 2% of the netasset value of the Fund. The Fund has a minimum exposure of 50% in investment grade securities.

The Fund may have a net short credit exposure which is not to exceed 35% of the portfolio. The Fundmay have up to 10% physical exposure to equity securities.

Currency strategy

Bentham aims to fully hedge any foreign currency exposure back to the Australian dollar. Please referto ‘Currency risk’ for additional information.

Description of theFund

Bentham Global Income Fund 7

How we invest your money

Max (%)Min (%)Asset class2

500Australian hybrids400Global hybrids (global/Euro convertible bonds)500Global loans (including syndicated loans)300Global high yield bonds750Investment grade credit (including global

corporate bonds and asset backed securities)300Cash

1These are asset allocation ranges for the Fund. If market movements, investments into or withdrawals from the Fund, or changes inthe nature of an investment, cause the Fund to move outside these ranges, or a limit set out in this PDS, this will be addressed by usor Bentham as soon as reasonably practicable.2These ranges are based on net exposures andmay vary in accordance with hedging. The Fund will also generally include an exposureto cash at bank.

Strategic assetallocation ranges1

Bentham believes ESG analysis can assist in the identification of risks which can significantly impactcredit worthiness.While Bentham takes into account environmental, social and governance considerationswhen buying, retaining or selling underlying investments, it does not adhere to any particular set ofstandards nor does Bentham have a predetermined view as to what constitutes an environmental, socialor ethical consideration, as these are determined on a case-by-case basis. Bentham’s consideration ofESG factors is detailed further below.

Labour standardsor environmental,social or ethicalconsiderations

The constitution of the Fund permits a wide range of investments and gives us, as Responsible Entity,broad investment powers. Wemay change the investment manager and/or vary the investment objectives,strategies, benchmarks, asset allocation ranges and processes of the Fund. We will give unitholderswritten notice of any material variation which we believe they would not have reasonably expected.

Changes toinvestment policy

Additional information about theFunds's investmentsBorrowings of the FundThe Fund’s constitution allows for borrowing; however,Benthamwill generally not borrow on behalf of the Fund,except from time to time to cover short-term cash flowneeds or if emergency or extraordinary situations arise.Borrowings may be from a variety of sources, includingrelated entities. Where funds are borrowed from relatedentities, the terms are set on a commercial and arm’slength basis.

The availability and terms of borrowings are subject tothe market for borrowings (including market conditionsin debt and other markets) and therefore borrowings maynot always be available. Lenders may refuse to provideborrowings, renew an existing borrowing facility or refuseto renew on commercially acceptable terms. This maybe for reasons specific to the Fund or due to market-wideevents.

We or Bentham may change the lending financialinstitution (if any) from time to time and may also seekto vary the terms of any borrowing facility where it isbelieved it would be in the best interests of unitholders.

Asset allocation rangesThe Fund gains exposure to various investment marketsand asset classes by investing into direct assets and/orindirectly via managed funds. References to assetallocations are references to the exposure of the Fund,not necessarily the physical unit or security held.

Refer to ‘How we invest your money’ for strategic assetallocations for the Fund.

If market movements, investments into or withdrawalsfrom the Fund, or changes in the nature of an investmentcause the Fund to exceed these asset allocations, or alimit set out in the PDS this will be addressed by us orBentham as soon as reasonably practicable.

Making investments directly or indirectlyThe Fund may make investments directly or indirectlyby investing in other funds (including funds related to, ormanaged by, a related entity) that have investmentobjectives and authorised investments that are consistentwith the Fund. This structure helps to minimisetransaction costs and can enhance diversification.

How the Fund uses derivativesThe Fund may, at times, invest in or obtain exposure toderivatives, such as futures and options, interest rateswaps, currency hedging and credit default swaps.

8 Bentham Global Income Fund

The term ‘derivative’ is used to describe any financialproduct that has a value that is derived from anothersecurity, liability, or index.

Derivatives may be used to gain exposure when theyoffer a more cost-effective way of purchasing theunderlying security. Derivatives can be used to implementinvestment decisions (including hedging), managing theduration of the Fund, and as a risk management tool(such as managing the effect of interest rates or foreigncurrency movements). They may also be used to adjustor implement investment decisions and to gain, or avoid,exposure to a particular market rather than purchasingphysical assets.

The Fund’s constitution permits the use of derivatives;however Bentham does not intend to gear the Fundthrough the use of derivatives. If market movements,investments into or withdrawals from the Fund, orchanges in the nature of an investment result in the Fundbeing geared through derivatives, this will be addressedby Bentham or us as soon as reasonably practicable.Where the Fund uses derivatives, Bentham aims tomanage the Fund so as to keep sufficient liquid assetsin the Fund to meet all obligations associated with thederivatives.

The use of derivatives may expose the Fund to certainrisks. Please refer to ‘Derivative risk’ for moreinformation.

Labour standards or environmental, social orethical considerationsBentham takes into account environmental, social, andgovernance (ESG) issues when buying, retaining orselling underlying investments. Bentham believes ESGanalysis can assist in the identification of risks which cansignificantly impact creditworthiness. Consideration ofESG issues alongside financial measures thereforeprovides Bentham with a more complete view of the risk/ return characteristics of potential investments.

In this regard, Bentham believes consideration of ESGfactors contributes to management of investment risksand long-term value preservation. Bentham reviewsinformation on ESG factors through the fundamentalcredit analysis process. ESG issues can affect the riskcharacteristics of potential investments in multiple waysdepending on the industry and / or the individualcompany. For example, ESG issues may be moreprominent in sectors with a significant carbon footprint,resource extraction industries, and heavy manufacturingindustries. ESG factors may also affect industry structureand competitive position, for example, the globaltransition of electricity production from fossil fuelgeneration to new energy technologies.

Bentham’s goal is to fully integrate ESG into the creditresearch process. The credit team review informationon ESG factors relevant to investment opportunitiesthrough the fundamental credit analysis process.Potentially material ESG issues are identified initiallythrough application of the Bentham ESG risk framework,which sets out ESG risk factors on an industry basis.Where deemed material to credit pricing/default risk,ESG factors are assessed in greater detail as part of thebottom-up credit risk analysis process. This entailsassessment of ESG factors in conjunction with qualitativerisk information, top-down sector selection and financialrisk metrics. Bentham’s approach anchors ESG analysisin fundamental investment decision processes.

While Bentham has an internal ESG policy, Benthamdoes not have a predetermined view as to whatconstitutes an environmental, social or ethicalconsideration as these are determined on a case-by-casebasis. Bentham is committed to ongoing improvementin ESG analysis and may update their investmentprocess from time to time to reflect their evolvingunderstanding of ESG.

Bentham Global Income Fund 9

All investments carry risk. Different strategies carrydifferent levels of risk depending on the assets that makeup the strategy. Generally, assets with the potential forthe highest long-term returns may also carry the highestlevel of risk.

When investing in a managed investment scheme, it isimportant to note that the value of assets in the managedinvestment scheme and the level of returns will vary. Noreturn is guaranteed. Future returns may differ from pastreturns and investors may lose some or all of their moneyinvested. Additionally, laws (including tax laws) that affectmanaged investment schemesmay change in the future,which may have an adverse effect on the returns ofmanaged investment schemes.

Your level of acceptable risk will vary compared to otherinvestors’ risk appetite and depends upon a range offactors such as your age, your investment timeframe,how comfortable you feel about exposing your investmentto risk, the nature and size of other investments you hold,and the extent to which the Fund fits into your overallfinancial plan.

New Zealand investors need to be aware there aredifferences in how securities are regulated underAustralian laws. For example, the disclosure of fees maybe different and the rights, remedies and compensationarrangements available to New Zealand investors maydiffer.

Risks of investing in managed investment schemesExplanationRisk

The Fund enters into derivatives arrangements that require it to deliver (or 'post') collateral to thederivative counterparty or clearer. As a result, the Fund may be exposed to certain risks in respect ofthat collateral including the credit risk of the counterparty or clearer. In the event the counterparty orclearer becomes insolvent at a time it holds collateral posted by the Fund, the Fund will be an unsecuredcreditor and will rank behind preferred creditors.

Collateral risk

The Fund is, to a certain extent, reliant on external providers in connection with its operation andinvestment activities. There is a risk with these arrangements that the other party to a contract (suchas a derivatives contract, physical security trade or foreign exchange contract) fails to perform itscontractual obligations either in whole or in part. This may result in the investment activities of the Fundbeing adversely affected.

Counterparty risk

The risk that the issuer of the fixed interest security is unable or unwilling to make interest and/or capitalrepayments in full and/or on time, or may not meet other financial obligations. Causes of such a failureinclude an issuer encountering financial difficulties such as insolvency.

Credit risk is generally considered to be lower with investment grade credit quality fixed incomesecurities. Fixed income securities rated below investment grade credit quality generally have a higherrisk of default.

Emerging markets debt is generally below investment grade and usually has a higher risk of default.Bentham monitors, on an ongoing basis, the financial position of issuers whose securities are held bythe Fund.

Credit risk

The Fund may invest in securities outside Australia. These securities can be valued in currencies otherthan Australian dollars. A change in the value of these currencies relative to the Australian dollar canaffect the value of the investment. For example, a rise in the Australian dollar relative to other currenciesmay negatively impact the value of the investment. Conversely, a decline in the Australian dollar relativeto other currencies may positively impact the value of the investment.

Bentham adopts currency hedging strategies in an aim to reduce, or remove completely, the impactof these currency movements on the value of the investment. However, it should be noted that suchhedging strategies could also reduce the potential for increased gains where the value of that currencyincreases relative to the Australian dollar. Please refer to ‘Currency strategy’ under 'How we investyour money' for information on Bentham’s currency management strategy.

Currency risk

10 Bentham Global Income Fund

Risks of investing in managed investmentschemes

The value of a derivative is linked to the value of an underlying asset and can be highly volatile. Whilethe use of derivatives offers the opportunity for higher gains, it can also magnify losses to the Fund.Risks associated with using derivatives might include the value of the derivative failing to move in linewith that of the underlying asset, potential illiquidity of the derivative, the Fund not being able to meetpayment obligations as they arise and the risk that the other party with whom the derivative contractis held will fail to perform its contractual obligations (known as ‘counterparty risk’).

Bentham does not intend to gear the Fund through the use of derivatives. Bentham aims to keepderivative risk to a minimum by:

constantly monitoring the Fund’s use of derivatives;aiming to ensure that the Fund keeps sufficient liquid assets to meet all obligations, costs, liabilitiesand potential losses associated with derivatives; andentering into derivative contracts with reputable counterparties.

Derivative risk

The value of an equity security (also known as a share) may be affected by market sentiment and otherfactors that may impact the performance of the actual company over short or extended periods of time.Investing in shares of a company will expose an investor to many of the risks to which the individualcompany is itself exposed. They include many factors, such as changes in management, actions ofcompetitors and regulators, changes in technology and market trends. Share markets tend to move incycles, and the individual share price of a security may fluctuate.

Such risk is considered by Bentham through its investment process and managed by maintaining adiversified portfolio of securities. Investment returns from international shares are also affected byexchange rate fluctuations. The currency exposure from the Fund’s international equity investmentsmay be hedged or partially hedged into the Australian dollar. Refer to 'Currency strategy' under 'Howwe invest your money' for more information.

Equity security risk

Fixed interest securities are affected by many of the other risks outlined in this section, such as interestrate risk and credit risk. The impact of interest rate risk will largely depend on the term to maturity ofthe security (refer to ‘Interest rate risk’ for more information).

Credit risk is generally considered to be low with investment grade fixed income securities and higherfor non-investment grade securities (refer to ‘Credit risk’ for more information).

The value of a security (including its cash flow) may also be affected by:

changes in the security’s credit risk premium;ratings upgrades or downgrades by ratings agencies (e.g. when a borrower’s financial position hasimproved or deteriorated);defaults (i.e. when a borrower fails to pay interest or principal when it is due); andrecovery risk (the severity of the capital loss incurred as a result of a default).

Investment returns from international fixed interest securities (and related derivatives) are also affectedby fluctuations in exchange rates (refer to ‘Currency risk’).

A further risk relevant to fixed interest securities is ‘prepayment risk’ where certain debt securities canbe prepaid at the option of the issuer. There is no assurance that proceeds received from a prepaymentcan be invested in similar securities generating the same level of return.

Fixed interest andcredit investments risk

Bentham Global Income Fund 11

Fund risk refers to specific risks associated with the Fund, such as termination and changes to feesand expenses. Wemay close the Fund to further investments if, for example, we consider it appropriategiven the investment objective and investment strategy of the Fund. We may also terminate the Fundby notice to unitholders.

Your investment in the Fund is governed by the terms of the constitution and the PDS of the Fund(each as amended from time to time), the Corporations Act 2001(Cth), and other laws. The value ortax treatment of an investment in the Fund or its underlying assets, or the effectiveness of the Fund’strading or investment strategy may also be adversely affected by changes in government policies(including taxation), regulations and laws, or changes in generally accepted accounting policies orvaluation methods. Such changes could also make some investors consider the Fund to be a lessattractive investment option than other investments, prompting greater than usual levels of withdrawals,which could have adverse effects on the Fund.

There is also a risk that investing in the Fund may give different results from holding the underlyingassets of the Fund directly because of:

income or capital gains accrued in the Fund at the time of investing; andthe consequences of investment and withdrawal decisions made by other investors in the Fund; forexample, a large level of withdrawals from the Fund may lead to the need to sell underlying assetswhich would potentially realise income and/or capital gains.

We aim to manage these risks by monitoring the Fund and by acting in investors’ best interests. In theevent of winding up the Fund, we will realise all the Fund’s assets, which will generally result in thecrystallisation of tax positions (both income and capital) at that time.

Fund risk

Fixed interest securities (such as bonds) can be affected by movements in interest rates. For example,the capital value or income of a bond may be adversely affected when interest rates rise or fall. Forexample, when interest rates rise, the value of the bond tends to fall and vice versa. Generally, thelonger the maturity (or duration) of the bond, the greater the impact that changes in interest rates willhave on the value of that bond.

Interest rate risk

The absence of established market or a shortage of buyers for an investment can result in a loss if theholder of the investment needs to sell it within a particular timeframe.

If an investor or a group of investors in the Fund with exposure to less liquid assets seek to make largewithdrawals, then selling assets to meet those withdrawals may result in a detrimental impact on theprice we receive for those assets. In certain circumstances, we may be required to suspend withdrawals(refer to ‘Withdrawal risk’) to allow sufficient time for a more orderly liquidation of assets to meet thewithdrawals.

Liquidity risk

The possibility for an investor to experience losses due to factors that affect the overall performanceof the financial markets. These events may include changes in economic, social, political conditionsalong with changes in technology, the environment and market sentiment.

Often assets from less developed regions or markets display higher levels of volatility of investmentreturn than assets in mature markets.

Market risk

If a situation occurs where the assets that the Fund invests in are no longer able to be readily boughtand sold, or market events reduce the liquidity of a security or asset class, there is a risk that thegenerally applicable timeframe of five business days for meeting withdrawal requests may not be ableto be met. This is because it may take longer to sell these types of investments at an acceptable price.In this case, withdrawals from the Fund may take significantly longer than the generally applicabletimeframe.

The maximum timeframe in which we, as Responsible Entity, have to meet a withdrawal request is setout in the constitution of the Fund. Where the Fund is not liquid (as defined in the Corporations Act2001 (Cth)), you may only withdraw when we make an offer to withdraw to all investors, as requiredby the Corporations Act 2001 (Cth). Please refer to ‘Additional information about withdrawing’ for furtherinformation about an investor’s ability to withdraw when the Fund is liquid, including the timeframes,and an investor’s ability to withdraw if the Fund is not liquid.

Withdrawal risk

12 Bentham Global Income Fund

Consumer advisory warningDid you know?

Small differences in both investment performance and fees and costs can have a substantial impact on your longterm returns. For example, total annual fees and costs of 2% of your account balance rather than 1% could reduceyour final return by up to 20% over a 30 year period (for example, reduce it from $100,000 to $80,000). You shouldconsider whether features such as superior investment performance or the provision of better member services justifyhigher fees and costs. You may be able to negotiate to pay lower contribution fees and management costs whereapplicable. Ask the fund or your financial adviser.

To find out more

If you would like to find out more, or see the impact of the fees based on your own circumstances, the AustralianSecurities and Investments Commission (ASIC) website (www.moneysmart.gov.au) has amanaged funds fee calculatorto help you check out different fee options.

This table shows fees and other costs that you may be charged and applies to the Fund offered through this PDS.These fees and costs may be deducted from your money, from the returns on your investment or from the Fund assetsas a whole. Taxes are set out under ‘How managed investment schemes are taxed’ in this document. You shouldread all the information about fees and costs because it is important to understand their impact on your investment.

How and when paidAmountType of fee or cost

Fees when your money movesin or out of the Fund1

Not applicableNilEstablishment fee: The fee toopen your investment

Not applicableNilContribution fee: The fee oneach amount contributed to yourinvestment

Not applicableNilWithdrawal fee: The fee on eachamount you take out of yourinvestment

Not applicableNilExit fee: The fee to close yourinvestment

This includes:

Management Fee: The management fee component is 0.72% p.a. of the netasset value of the Fund. The Management Fee is calculated and accrued dailyand paid monthly in arrears from the Fund's assets on or around the lastbusiness day of the month.

Indirect costs: The indirect costs component is 0.00% p.a. of the net assetvalue of the Fund4. Indirect costs are deducted from the assets, accrued dailyin the net asset value, and then paid periodically. Please refer to 'Indirect costs'in the 'Additional explanation of fees and costs' section.

Recoverable expenses: The recoverable expenses component is 0.05% p.a.of the net asset value of the Fund4. Recoverable expenses other thaninvestment expenses are deducted from the Fund's assets, accrued daily andpaid monthly on or around the last business day of the month. Investmentexpenses are paid out of the management fee. Please refer to 'Recoverableexpenses' in the 'Additional explanation of fees and costs' section.

0.77% p.a.of the netasset valueof the Fund

Management costs2,3,4

The fees and costs for managingyour investment

Bentham Global Income Fund 13

Fees and other costs

How and when paidAmountType of fee or cost

Not applicableNil

Service fees5

Switching fee: The fee forchanging investment options

1. An allowance for transaction costs may apply to investments into, and withdrawals from, the Fund (refer to ‘Buy/sell spreads’ below).

2. Unless otherwise stated, all fees and costs are quoted inclusive of any Goods and Services Tax (GST) and net of any input tax credits (ITCs) or reduced input taxcredits (RITCs) as applicable. Where available, the prescribed RITC rate is currently 55% or 75%, depending on the nature of the fee or cost incurred. Due to theimpact of GST, ITC and RITC calculations, actual fees may vary slightly from those stated, which may be rounded to two decimal places.

3. For certain Wholesale Clients (as defined in the Corporations Act 2001 (Cth)) we may, at our discretion, negotiate, rebate or waive all or part of our fees. Pleaserefer to 'Can fees be different for different investors?' in 'Fees and other costs'.

4. All estimates of fees and costs in this section are based on information available as at the date of this PDS and reflect the Responsible Entity's reasonable estimatesof the typical fees for the current financial year. All other management costs reflect the actual amount incurred for last financial year and the Responsible Entity'sreasonable estimates where information was not available as at the date of this PDS. Themanagement costs used in the example of annual fees and costs calculationis based on the actual management costs paid for the Fund for the previous financial year. All figures have been rounded to two decimal places. Please refer to‘Additional explanation of fees and costs’ for more information on management costs.

5. Please refer to ‘Additional explanation of fees and costs’ and 'Other payments' for more information on costs that may be payable.

14 Bentham Global Income Fund

Example of annual fees and costs for the FundA managed funds fee calculator can also be used to calculate the effect of fees and costs on account balances.

This table gives an example of how fees and costs in the Fund can affect your investment over a one-year period.You should use this table to compare this product with other managed investment products.

Balance of $50,000 with a contribution of $5,000 during the yearAmountExample

For every additional $5,000 you put in, you will be charged $0.$0Contribution fees

And, for every $50,000 you have in the Fund, you will be charged $385 each year.0.77% p.a. of thenet asset value ofthe Fund

Plus Managementcosts1,2,3,4,5

If you had an investment of $50,000 at the beginning of the year and you put in anadditional $5,000 during that year, you would be charged fees of:

$3854,5

What it costs you will depend on the investment option you choose and thefees you negotiate with your fund or financial adviser.

Equals Cost of Fund

This example assumes that the $5,000 contribution is made at the end of the year and the value of theinvestment is otherwise consistent, therefore the management costs associated above are calculated

using the $50,000 balance only. Please note that this is just an example. In practice, actual investment balanceswill vary daily and the actual fees and expenses we charge are based on the value of the Fund, which alsofluctuates daily.1. An allowance for transaction costs may apply to investments into, and withdrawals from, the Fund (refer to ‘Buy/sell spreads’ below).

2. Unless otherwise stated, all fees and costs are quoted inclusive of any Goods and Services Tax (GST) and net of any input tax credits (ITCs) or reduced input taxcredits (RITCs) as applicable. Where available, the prescribed RITC rate is currently 55% or 75%, depending on the nature of the fee or cost incurred. Due to theimpact of GST, ITC and RITC calculations, actual fees may vary slightly from those stated, which may be rounded to two decimal places.

3. For certain Wholesale Clients (as defined in the Corporations Act 2001 (Cth)) we may, at our discretion, negotiate, rebate or waive all or part of our fees. Pleaserefer to 'Can fees be different for different investors?' in 'Fees and other costs'.

4. All estimates of fees and costs in this section are based on information available as at the date of this PDS and reflect the Responsible Entity's reasonable estimatesof the typical fees for the current financial year. All other management costs reflect the actual amount incurred for last financial year and the Responsible Entity'sreasonable estimates where information was not available as at the date of this PDS. Themanagement costs used in the example of annual fees and costs calculationis based on the actual management costs paid for the Fund for the previous financial year. All figures have been rounded to two decimal places. Please refer to‘Additional explanation of fees and costs’ for more information on management costs.

5. Please refer to ‘Additional explanation of fees and costs’ and 'Other payments' for more information on costs that may be payable.

Bentham Global Income Fund 15

Additional explanation of fees andcostsManagement costsAll estimates of fees and costs in this section are basedon information available as at the date of this PDS andreflect the Responsible Entity's reasonable estimates ofthe typical fees for the current financial year. All othermanagement costs reflect the actual amount incurredfor last financial year and the Responsible Entity'sreasonable estimates where information was notavailable as at the date of this PDS.These amounts areinclusive of GST less reduced input tax credits. Youshould refer to the Fund's website at www.fidante.com.aufrom time to time for any updates which are not materiallyadverse to investors.

The total management costs for the Fund, include themanagement fee, indirect costs, and recoverableexpenses. They do not include the transactional andoperational costs (i.e. buy/sell spreads) of the Fund orthe transactional and operational costs of underlyingassets (as set out below). Management costs are payablefrom the Fund’s assets and are not paid directly fromyour account.

For details of the maximum fees permitted under theconstitution of the Fund, please refer to ‘Maximumallowable fees’.

Management feeThis is the fee charged for managing the investments,overseeing the Fund’s operations and providing accessto the Fund. The management fee is calculated daily asa percentage of the net asset value of the Fund andpayable monthly in arrears.

Indirect costsIndirect costs are those amounts paid from the assetsof the Fund that we know or, where required, reasonablyestimate will reduce the return of the Fund or the amountor value of the income of, or property attributable to, theFund or an underlying managed fund in which the Fundinvests. Indirect costs do not include the managementfee or recoverable expenses as set out in this section.For example, indirect costs include charges of anunderlying fund where the Fund invests in assetsindirectly.

Where the Fund can invest in assets indirectly throughother managed funds, indirect costs are deducted fromthe assets of the interposed vehicle in which the Fundinvests, accrued daily in the interposed vehicle's netasset value, and then paid periodically.

Themanagement costs set out in the table above includeindirect costs of 0.00% p.a. of the Fund's net asset value,which is the amount actually incurred by the Fund for theprevious financial year including the Responsible Entity'sreasonable estimates where information was unavailableat the date of this PDS.

Recoverable expenses

Normal operating expensesUnder the constitution of the Fund, we are entitled torecover costs incurred in the performance of our dutiesas Responsible Entity of the Fund and in theadministration and management of the Fund. Thesenormal operating expenses include charges, fees,expenses, commissions, liabilities, and losses associatedwith the Fund.

The management cost set out in the table above includenormal operating expenses of 0.05% p.a. of the Fund'snet asset value, which is the amount actually incurredby the Fund for the previous financial year including theResponsible Entity's reasonable estimates whereinformation was unavailable at the date of this PDS. Thisamount is not an indication or guarantee of the amountthat may be charged in the future. Normal operatingexpenses, and therefore total management costs, mayvary each year.

Abnormal expensesWe may recover abnormal expenses (such as costs ofunitholder meetings, changes to the Fund’s constitutionand defending or pursuing legal proceedings) from theFund. Whilst it is not possible to estimate such expenseswith certainty, we anticipate that the events that give riseto such expenses will not occur regularly. Incircumstances where such events do occur, we maydecide not to recover these abnormal expenses from theFund.

Themanagement costs set out in the table above includeabnormal expenses of 0.00% p.a. of the net asset valueof the Fund, which is the amount actually incurred by theFund for the previous financial year including theResponsible Entity's reasonable estimates whereinformation was unavailable at the date of this PDS.

At the date of this PDS, there is no intention to hold aunitholder meeting nor are we aware of any legalproceedings the Fund may be a part of that may requireus to recover associated abnormal expenses from theFund. This amount is not an indication or guarantee ofthe amount that may be charged in the future. Abnormalexpenses, and therefore total management costs, mayvary each year.

16 Bentham Global Income Fund

Abnormal expenses recovered from the Fund, if any, willbe paid from the Fund's assets when they are incurred.

Investment expensesWe currently pay the standard investment managementcosts of the Fund from the management fee.

Transactional and operational costsTransactional and operational costs are the costsassociated with the buying and selling of the Fund'sassets. These costs include brokerage, settlement costs,clearing costs, stamp duty and other government taxesor charges and include the transactional and operationalcosts incurred by the underlying assets.

The transactional and operational costs incurred by theFund for the last financial year were 0.14% p.a. of thenet asset value of the Fund, including the ResponsibleEntity's reasonable estimates where information wasunavailable at the date this PDS. This cost is made upof two components, explicit transaction costs (forexample, brokerage, settlement costs, clearing costs,stamp duty and other government taxes or charges andany buy/sell spread) of 0.01% p.a., and implicittransaction costs (that is, the amount by which theacquisition price of an asset exceeds the disposal priceof that asset) of 0.13% p.a. of the net asset value of theFund.

Transactional and operational costs are not included inthe management costs. Instead they are recovered fromthe assets of the Fund as and when they are incurredand therefore (where not otherwise recovered throughthe buy/sell spread) are an additional cost to you.

The net transactional and operational costs of the Fund(representing the total transactional and operational costsminus the total amount recovered through the buy/sellspread of +0.35%/-0.35%) incurred for the last financialyear were 0.00% p.a. of the net asset value of the Fund,including the Responsible Entity's reasonable estimateswhere information was unavailable at the date of thisPDS.

Total fees and costs

Based on the estimated costs outlined in this section,the estimated total of the amounts for management costsand net transactional and operational costs is estimatedas 0.77% p.a. of the net asset value of the Fund. Thedollar figure of these estimated total management costsand net transactional and operational costs based on aninvestment balance of $50,000 is $385.

Buy/sell spreadsThe buy/sell spread is a type of transactional andoperational cost that may include brokerage, stamp duty,underlying security buy/sell spreads and other

government taxes or charges. The purpose of the buy/sellspread is to ensure that only those investors transactingin the Fund’s units at a particular time bear the Fund’scosts of buying and selling the Fund’s assets as aconsequence of their transaction.

The buy/sell spread for the Fund is stated as apercentage of the net asset value of the Fund and is thedifference between the investment unit price and thewithdrawal unit price. It reflects an estimate of thetransactional and operational costs expected to beincurred in buying and selling the Fund’s assets as aresult of investments and withdrawals made by investors.

This estimate may take into account factors such as (butnot limited to) historical transaction costs and anticipatedlevels of investments and withdrawals. It is expected thatbrokerage will make up the vast majority of transactioncosts.

The current buy/sell spread of the Fund is+0.35%/-0.35%; however a different buy/sell spread mayapply if the estimate changes.

We have discretion to waive or reduce the transactionaland operational costs on investments or withdrawalswhere no or reduced costs are incurred. We will providenotification to unitholders of any changes to buy/sellspread transaction costs on our website.

Please note that while the buy/sell spread is an additionalcost to you, it is not a fee paid to us or Bentham. It ispaid to the Fund and is reflected in the Fund’s unit price.

Buy/sell spread exampleThe current buy spread on an investment in the Fundis +0.35%. Therefore, the cost of an investment of$50,000 into the Fund would be $175.The current sell spread on a withdrawal from the Fundis -0.35%. Therefore, the cost on a withdrawal of$50,000 from the Fund would be $175.

Please note that this is just an example. In practice,actual transaction costs will depend on the amount youinvest or withdraw.

Can fees be different for different investors?Yes; we may negotiate, rebate, or waive fees forwholesale clients (as defined in the Corporations Act2001 (Cth)). We do not negotiate fees with retailinvestors.

Borrowing costsBorrowing costs are the costs associated with borrowingmoney or securities. The Fund may enter into borrowingfacilities and, if so, the costs of a borrowing facility wouldbe deducted from the Fund and not paid for by us fromthe fees we receive. They would therefore increase themanagement costs of the Fund.

Bentham Global Income Fund 17

Government charges and GSTGovernment taxes such as stamp duty and Goods andServices Tax (GST) may apply to the Fund or yourinvestment. Unless otherwise stated, all fees and costsare quoted inclusive of any GST and net of any input taxcredits (ITCs) or reduced input tax credits (RITCs) thatare expected to be available to the Fund.

Where RITCs are available, the prescribed rate iscurrently 55% or 75%, depending on the nature of thefee or cost incurred. Please refer to 'How managedinvestment schemes are taxed' for additional informationon GST.

Other paymentsWe may pay fees from our resources to some IDPSoperators because they offer the Fund on theirinvestment menus. These fees may be rebated to theIndirect Investor investing in the Fund through the IDPSoperator or retained by the IDPS operator and include:

for each IDPS operator, product access payments ofup to $8,250 p.a.; and/orwhere permitted by law, fund manager payments ofup to 0.55% p.a. of the amount invested by the IDPSoperator in the Fund.

If we do pay fees, we will pay them from our ownresources so that they are not an additional cost to theFund or its unitholders. These amounts are current atthe date of this document.

We may pay additional fees from our resources to someapproved participants because they offer the Fund ontheir investment menus. You should refer to the relevantapproved participants’ Financial Services Guide beforeinvesting.

Adviser remunerationAdviser service feesYou and your financial adviser may agree that you willpay an adviser service fee for the provision of ongoingservices by your financial adviser in relation to yourinvestment. This fee will be paid to the Australianfinancial services licensee responsible for your adviser(or your adviser directly if they are the licensee). You donot have to agree to these fees if you choose not to.

Where it has been agreed, the adviser service fee maybe an amount of up to 1.1% p.a. of your account balance,negotiated with your financial adviser and to becalculated and paid on a monthly basis. You and yourfinancial adviser may agree to this fee being deductedfrom your Fund account. Where you agree to pay anadviser service fee, you also authorise us to withdraw

units you hold in the Fund to pay this fee on your behalf.There may be capital gain or capital loss consequenceson the withdrawal.

We will not deduct the adviser service fee if your balancein your Fund account is less than $1,000.

Adviser service fee exampleIf your account balance in the Fund is $50,000, and youagree to pay a maximum adviser service fee of 1.1%p.a., this will equate to $45.83 per month. You or yourfinancial adviser may cancel the adviser service fee atany time.

Maximum allowable feesThe Fund’s constitution allows for expenses of the Fund(whether normal or abnormal expenses), such as registry,audit, taxation, advice, investment management andoffer document costs to be paid directly from the Fund.

Maximum amountFee

6.00% p.a. of the contributionamount

Contribution fee(currently not charged)

2.00% p.a. of the net asset valueof the Fund

Management fee(currently charged at0.72% p.a.)

6.00% p.a. of the withdrawalamount

Withdrawal fee(currently not charged)

The constitution for the Fund permits us to charge atrustee fee of 0.04% p.a. of the value of the Fund that isinvested in any of the other fundsmanaged by Bentham,plus 0.10% p.a. of the value of the balance of that fund,or, in certain circumstances specified in the constitution,an amount no greater than an amount based on $15,000adjusted for inflation since 1992.

We are also entitled to be reimbursed for certain feesand expenses of a custodian or sub-custodian up to amaximum of 1% of the net asset value of the Fund. It isnot our current intention to charge any of these fees.However, should we propose to change this we will giveunitholders 30 days’ written notice of the change. Wealso reserve the right to waive or reduce any of the feesand costs described in this PDS without prior notice.

Can fees change?All fees can change. Reasons for this might includechanging economic conditions and changes in regulation.We will give unitholders 30 days’ written notice of anyproposed increase in fees. We cannot charge more thanthe Fund’s constitution allows. If we wish to raise feesabove the amount allowed for in the Fund’s constitution,

18 Bentham Global Income Fund

we would first need to obtain the approval of unitholders.We also reserve the right to waive or reduce any of thefees and costs described in this PDS without prior notice.

Indirect (or alternative form) remunerationWe may provide benefits to other financial servicesintermediaries where the law permits. If we do, we willprovide these benefits from our own resources so thatthey are not an additional cost to the Fund or itsunitholders.

We maintain a register (in compliance with the relevantregulatory requirements) summarising alternative formsof remuneration that are paid or provided to AustralianFinancial Services Licensees and/or theirrepresentatives. Registers are publicly available and ifyou would like to review our register, please contact us.

Bentham Global Income Fund 19

The information in the table below applies to direct Investors only. If you are an indirect investor, you will need tocomply with any requirements set by your IDPS operator. Please refer to ‘Indirect investors’ for further information.

More informationHow to lodge your requestMinimum amounts1

’Additionalinformation about

making aninvestment’

and‘CustomerIdentificationProgram’

complete and sign the relevant Application Form availableon our website;complete the relevant identity verification requirements(depending on what investor type you are) and include allrequired customer identity verification documents;if making your investment via direct debit, you will need tocomplete the direct debit request section of the relevantApplication Form. All direct debits are subject to the DirectDebit Request Service Agreement available on our website;if making your investment via Electronic Funds Transfer,please transfer funds with your investor name as a referenceat the same time as posting your application. Payment detailsare outlined on the relevant Application Form;if making your investment via cheque, make the chequepayable to ‘Fidante Partners Services Limited ApplicationAccount <name of investor(s)>’ and attach it to yourapplication form.

$10,000 or $1,000with a RegularSavings Plan

Initialinvestment

’Additionalinformation about

making aninvestment’

complete and sign the ‘Additional Investment Form’ availableon our website;if making your investment via direct debit, you will need tocomplete the direct debit request section of the relevantApplication Form. All direct debits are subject to the DirectDebit Request Service Agreement available on our website;if making your investment via Electronic Funds Transfer,please transfer funds with your investor name as a referenceat the same time as posting your application. Payment detailsare outlined on the relevant Application Form;if making your investment via cheque, make the chequepayable to ‘Fidante Partners Services Limited ApplicationAccount <name of investor(s)>’ and attach it to yourapplication form.

$1,000One-offadditionalinvestment

‘‘Regular SavingsPlan’

complete and sign the Regular Savings Plan sections fromthe relevant Application Form available on our website.

$100 per month (withan initial investment of$1,000).

RegularSavings Plan

‘Additionalinformation aboutwithdrawing your

investment’and‘Telephone

and faxinstructions’

complete and sign the ‘Withdrawal Request Form’ availableon our website; orwrite a letter, including:- your account number;- the full name(s) in which your investment account is held;- the amount (dollars or units) you wish to withdraw;- how and to whom you would like us to make the payment;and- a daytime contact telephone number; orvia telephone or fax (subject to certain restrictions; pleaserefer to ‘Telephone and fax instructions’).

$1,000 per withdrawal,subject to maintainingthe minimum balancein the Fund

Withdrawals

‘Transferringownership’

Subject to conditions as required by law and that we, from timeto time, prescribe. Please contact our Investor Services teamfor information about transferring.

$10,000Transferringownership

1. We may accept lower minimum transaction amounts at our discretion.

20 Bentham Global Income Fund

Making, withdrawing, and monitoring yourinvestment

Additional information about makingan investmentInitial InvestmentsYou can access the Fund:

As a Direct Investor – by completing the relevantApplication Form

As an Indirect Investor – through your IDPS operator

Direct InvestorsDetails of how to make your initial investment are outlinedin the 'Making, withdrawing, and monitoring yourinvestment' table. Once you have made your initialinvestment in the Fund, you can make additional one-offinvestments and/or regular monthly investments via theRegular Savings Plan.

Indirect InvestorsYou should contact your IDPS operator for moreinformation regarding your investment in the Fund.

Additional one-off investmentsIf you wish to make additional investments in the Fund,please download a copy of the current PDS and theadditional important information and any disclosureupdates. A paper copy of the current PDS, the additionalimportant information and any updates are available freeof charge by visiting our website or by calling us.

Direct InvestorsIf you wish to make additional investments in the Fund,complete the relevant sections of the relevant ApplicationForm or complete the Additional Investment Form, bothavailable from www.fidante.com.au.

For direct investors, additional investments can be madevia direct debit, electronic funds transfer, or cheque. Ifyou are sending your investment from outside Australia,please note you are only able to make additionalpayments via an electronic funds transfer. If making youradditional investment via direct debit, you will need tocomplete the relevant direct debit facility section on theAdditional Investment Form.

All direct debits are subject to the Direct Debit RequestAgreement which is available on our website andcontains details of how to make payments via electronicfunds transfer.

Alternatively, if you are making your additional investmentvia cheque, you can send us written instructions. Pleaseattach your cheque to the instructions and ensure theinstructions include:

your account number;

the full name(s) in which your investment account isheld;the amount you wish to invest; anda daytime telephone number.

Indirect InvestorsYou must complete the documentation which your IDPSoperator requires.

Regular Savings PlanThe Regular Savings Plan (RSP) enables you to investin the Fund each month via direct debit from a nominatedaccount.

Direct InvestorsTo start an RSP, simply complete the relevant sectionsof the relevant Application Form or complete theAdditional Investment Form, both available fromwww.fidante.com.au.

Your nominated account will be debited on or around thenext business day after the 14th day of each month forthe specified amount. Your application to commence anRSP must be received at least three business daysbefore the 14th day of the month in which you wish yourinstructions to take effect. Participation in the RSP willbe renewed annually by continuing tomake contributions.

Units will be issued on the basis of information containedin the PDS and this document current at the time thecontributions are made. Should a replacement PDS oradditional important information be issued, we will notifyyou and inform you of any changes or updates if youcontinue to participate in the RSP. You can amend,suspend, or cancel your RSP at any time. You shouldensure that we receive your instructions to amend,suspend or cancel your RSP at least three business daysbefore the 14th day of the month in which you wish yourinstructions to take effect. Any request received after thismay result in the change not being effective until thefollowing month.

If two consecutive debits are dishonoured due toinsufficient funds, we will suspend your RSP.

Indirect InvestorsYou must complete the documentation which your IDPSoperator requires.

Incomplete or rejected application formsUnder the Fund’s constitution, we can accept or rejectany application for units and are not required to give anyreason or grounds for such a refusal.

Bentham Global Income Fund 21

Monies from incomplete applications will generally beheld on trust for a maximum period of 30 days in anon-interest bearing account commencing on the daywe receive the monies. After this period, your funds willbe returned to the source of payment.

Once we receive your completed application form, themonies held will be divided by the next determined unitprice to calculate the number of units allocated to you.

Customer Identification ProgramDirect InvestorsTo address money laundering and terrorism risks,verification of each customer’s identity is a prerequisitefor all new customers starting an investment. Therequirements to verify each customer’s identity willdepend on what type of investor you are, e.g. individualor company etc.

You will be required to provide certified copies of youridentity verification documents directly to us (refer to‘Who can certify’ for a list of who can certify thesedocuments). If the Application Form is signed underPower of Attorney we will also require a certified copy ofthe Power of Attorney document and a specimensignature of the attorney.

Under relevant laws, we may be required to ask you foradditional identity verification documents and/orinformation about you, anyone acting on your behalf, orany related persons that are beneficial owners in relationto your investment, either when we are processing yourinvestment request or at some stage after we haveissued units in the Fund. We may pass any informationwe collect and hold about you or your investment to therelevant government authority.

Identity verification documents

You will be required to provide valid identity verificationdocumentation when you invest. The actualdocumentation required will depend on whether you arean individual investor or a non-individual investor suchas a superannuation fund, a trust or a company.

We have outlined the specific documentation requiredin the relevant Application Form. If any documentationyou provide is not in English, it must be accompanied byan original copy of an English translation prepared byan accredited translator. If we do not receive all requiredvalid customer identity verification documents with yourapplication, or we are unable to verify your identity atany time, we will not be able to commence yourinvestment until we receive the required documents. Wewill contact you as soon as possible if we require moreinformation.

Who can certify

You must ensure that each page of the relevant identityverification document(s) is certified. The person certifyingmust state in writing:

their capacity (from the list provided); andon each page of the document ‘this document is atrue and correct copy of the original’ or words to thateffect.

An identity verification document may be certified as atrue and correct copy of an original document by one ofthe following persons:

an officer with, or authorised representative of, aholder of an Australian Financial Services Licence,having two or more continuous years of service withone or more licensees, i.e. a financial adviser;a Justice of the Peace;a person who is enrolled on the roll of the SupremeCourt of a State or Territory, or the High Court ofAustralia, as a legal practitioner (however described),i.e. an Australian lawyer;a member of the Institute of Chartered Accountantsin Australia, CPA Australia or the National Institute ofAccountants, i.e. an accountant;an agent of the Australian Postal Corporation who isin charge of an office supplying postal services to thepublic;a permanent employee of the Australian PostalCorporation with two or more years of continuousservice who is employed in an office supplying postalservices to the public;a police officer;Australian consular officer or Australian diplomaticofficer; ora person authorised as a notary public in a foreigncountry.

Other personsmay also be qualified to certify documents.For a full list of eligible persons, please contact us.

Indirect InvestorsIndirect Investors should refer to their IDPS operator fordetails of their customer identification program.

22 Bentham Global Income Fund

Additional information aboutwithdrawingHow to make a withdrawalDirect InvestorsDirect Investors can request a withdrawal by telephoneor fax (refer to ‘Telephone and fax instructions’ in thisdocument) or in writing. A withdrawal request, either inwhole or in part, once received by us may not bewithdrawn without our agreement. If you make yourwithdrawal request by telephone or fax, we can makeyour withdrawal payment to a previously nominated bankaccount we have on file.

If you provide us with an appropriately signed, originalwritten request, then in addition to the payment methodsset out above, we can also make payments by directcredit to other bank accounts not on file with us.

We will require the following information when you makeyour withdrawal request:

your account number;the full name(s) in which your investment account isheld;the amount (dollar or units) you wish to withdraw;how and to whom you would like us to make thepayment; anda daytime telephone number.

Please ensure that the appropriate signatories sign allwritten withdrawal instructions, including those forwardedby fax.

If you originally invested via direct debit and you makea withdrawal within the first three months of making yourinvestment, we will only pay the withdrawal proceeds tothe account that was debited when making your initialinvestment.

Indirect InvestorsYou must complete the withdrawal documentationrequired by their IDPS operator.

Processing your withdrawalWhile withdrawals are normally processed and paidwithin five business days of receiving your validwithdrawal request, wemay take significantly longer thanthis (please refer to ‘Delay of withdrawal payments’). Ifyour request for withdrawal would cause your balanceto fall below the current minimum balance amount of$10,000, this may be treated as a request for fullwithdrawal.

For Direct Investors, we can make withdrawal paymentsby direct credit to your nominated account. You agreethat if the type of payment you request results in bank

fees being charged, we may deduct those fees from yourwithdrawal proceeds before remitting the net amount toyou.

Generally, if the payment for your withdrawal is returnedto us and remains outstanding for 6 months, we mayreinvest the proceeds in the Fund. Any reinvestment ofa withdrawal amount will be processed using theinvestment unit price current at the time of thereinvestment transaction. For more information on unitprices, refer to ‘How unit prices are calculated’ below.

We may determine that some or all of the withdrawalamount consists of income (whichmay include net capitalgains), rather than capital of the Fund.

We will advise you when this is the case as soon aspracticable after the end of the financial year in whichthe withdrawal occurred.

We have the discretion to transfer assets of the Fund toyou (instead of cash) in payment (partly or fully) for theproceeds of your withdrawal request less any costsinvolved in the transfer.

Delay of withdrawal paymentsWithdrawals are normally processed within five businessdays of receiving a valid withdrawal request; however,we do not guarantee this timeframe and we may takesignificantly longer to pay withdrawals.

Withdrawals may be delayed in the followingcircumstances:

under the Fund’s constitution, we have 30 days to paywithdrawals

if the Fund becomes illiquid, we are not required topay withdrawals unless we offer to do so (refer to ‘Ifthe Fund becomes illiquid’ below)

Where multiple delays are applicable, timeframes mayapply cumulatively.

Additionally, if we did not receive all required identityverification documents (as outlined in the relevantapplication form) at the time of investment or yourwithdrawal request is incomplete, we may not processyour withdrawal request until these documents arereceived or further requirements are met.

If the Fund becomes illiquid

If the Fund is not liquid (as defined in the CorporationsAct 2001 (Cth)), unitholders will only be able to withdrawfrom the Fund if we make an offer of withdrawal tounitholders. If we do make such an offer, unitholdersmay only be able to withdraw part of their investment.There is no obligation for us to make withdrawal offers.

Bentham Global Income Fund 23

Under the Corporations Act 2001 (Cth), the Fund isregarded as liquid if liquid assets account for at least80% of the value of the assets of the Fund. Liquid assetsgenerally include money in an account or on deposit witha bank, bank-accepted bills, marketable securities andproperty of the kind prescribed under the CorporationsAct 2001 (Cth).

Additional information abouttransactionsTransferring ownershipDirect InvestorsYou can generally transfer some or all of your investmentto another person in such a manner and subject to suchconditions as required by law and that we, from time totime, prescribe. We are not obliged to register a transferthat does not meet these criteria, or where there is anamount payable to us by the transferee or the transferor(as applicable) in respect of the units being transferred.We recommend that you obtain your own professionaladvice regarding your position before transferring someor all of your investment, as tax and social security lawsare complex and subject to change, and investors’individuals circumstances vary.

Please contact us for further information abouttransferring units.

Indirect InvestorsContact your IDPS operator if you wish to transfer yourunits.

Transaction cut-off timesDirect InvestorsGenerally, if your valid investment or withdrawal requestis received in our Sydney office before 3:00pm Sydneytime on a New South Wales business day (referred toas the transaction cut-off time), it will usually beprocessed using the unit price determined as at the closeof business on that day. If your valid investment orwithdrawal request is received after the transaction cut-offtime, or on a non-business day, it will usually beprocessed using the applicable unit price calculated asat the close of business on the next business day.

Indirect InvestorsYou should contact your IDPS operator for informationregarding transaction cut-off times.

Telephone and fax instructionsDirect InvestorsYou should understand that a person without yourauthority could telephone us or send us a fax and, bypretending to be you, withdraw funds from your accountfor their own benefit.

We take all care when acting on instructions. In doingso, we perform security checks and have in place internalpolicies and procedures designed to reduce the risk thatfraud is committed in relation to your account. In usingthe telephone and/or a fax facility, you agree that we arenot responsible to you for any fraudulently completedcommunications and that we will not compensate youfor any losses where we have complied with our securitychecks, internal policies and procedures and providedwe have not been negligent, fraudulent or dishonest.

We will only act on completed communications that wereceive. In the case of a fax, a transmission certificatefrom your fax machine is not sufficient evidence (unlesswe have otherwise agreed), that we received your fax.We will not be liable for any loss or delay resulting fromthe non-receipt of any transmission.

In the case of joint holdings, superannuation funds, trustsand companies additional processes may apply, and anyinvestor or director who signs the application form mayrequest a telephone withdrawal. If the details of the bankaccount quoted at the time of making a telephone or faxwithdrawal do not match the nominated bank accountwe have on file, the withdrawal will not proceed. Youmust advise us via an original, signed, written request ifyou wish to change your previously nominated bankaccount details. Should you not wish to use thesefacilities, we must receive an original, signed, writtenrequest to cancel them. Cancellation will be effectivefrom the end of the second business day after receipt ofthis request.

Wemay cancel or vary these requirements by giving younotice in writing.

Indirect InvestorsYou should contact your IDPS operator for informationregarding how to transact.

Changes to permitted transactionsWe can vary the minimum investment amounts for theFund at any time and can also change the applicationor withdrawal cut-off time. Under the Fund’s constitution,we can refuse applications or withdrawals for any reason.In particular, where we consider it to be in the interestsof unitholders (such as an inability to value the Fund),wemay suspend application or withdrawal requests. Any

24 Bentham Global Income Fund

application or withdrawal requests received during theperiod of suspension, or for which a unit price has notbeen calculated or confirmed prior to the commencementof a period of suspension, will be deemed to have beenreceived immediately after the end of the suspensionperiod.

Monitoring your investmentDirect investorsYou can access your account information 24 hours aday, seven days a week through InvestorOnline, a secureonline service which provides access to up-to-dateinformation about your investments, including the latestunit prices, your account balance and transaction history.

We will also send you regular information about yourinvestments, including:

confirmation of the acceptance of your initial andone-off additional investments; this confirmation willprovide details of the units issued;confirmation that we have processed a withdrawalrequest; this confirmation will provide details of theunit and dollar value withdrawn;a quarterly statement; anda consolidated annual taxation statement.

At any time, you may request a transaction statementthat shows either all transactions since your last regularstatement or all transactions for a specific period. Werecommend that you check all statements and transactionconfirmations carefully. If there are any discrepancies,please contact your financial adviser or our InvestorServices team.

As the Fund is a ‘disclosing entity’ under the CorporationsAct 2001 (Cth), it is subject to regular reporting anddisclosure obligations.

As Responsible Entity of the Fund, we are also subjectto continuous disclosure obligations that require us tomake material information available to investors. Youcan obtain a copy of the Fund’s continuous disclosureinformation by visiting our website.

You can obtain copies of the Fund’s most recent annualfinancial report by visiting our website.

Copies of documents lodged with ASIC in relation to theFund may be obtained from, or inspected at, an ASICoffice.

Indirect InvestorsPlease contact your IDPS operator for informationregarding your investment in the Fund.

Keeping us informedDirect InvestorsOur records about you are important.

Please inform us in writing of any change to the personaldetails that you have given us. This may be a new postaladdress, a change of name or new bank account details.We will send you written confirmation of any changesthat you request us to make to your personal details.

Indirect InvestorsAs an Indirect Investor, you should notify your IDPSoperator of any changes to your personal details.

What happens if you choose not to disclosecertain information?If you choose not to disclose certain information, thefollowing may apply:

Account details: we will not be able to pay withdrawalproceeds or income distributions to you.Tax residency information: we may not be able toprocess your request, or we may be required to notifythe ATO.Incomplete application form: unless otherwise agreed,we will not be able to process your investment request.If you do not provide all relevant identity verificationdocuments, we will not be able to process yourinvestment request.

For Australian resident investors, if you choose not todisclose your TFN, TFN exemption or ABN, we have todeduct tax at the highest marginal tax rate plus Medicarelevy (and any other levies we are required to deduct,from time to time) from any amounts attributed ordistributed to you (refer to ‘Tax File Number’ in 'Howmanaged investment schemes are taxed').

Up-to-date information about the FundYou can obtain up-to-date Fund performance, actualasset allocations and Fund size information by contactingyour financial adviser, visiting our website, or calling us.

A paper copy of any updated information will be givento you, without charge, on request by contacting us.

A paper copy of the Fund’s annual financial reports, anycontinuous disclosure notices, and any half yearlyfinancial report will also be given to you, without charge,on request.

Bentham Global Income Fund 25

How to exercise cooling-off rightsThe repayment of your investment under the cooling-offright is subject to an adjustment for market movements(both positive or negative) during the period in which theinvestment has been held. We may also deduct areasonable charge for our administration costs.

Direct InvestorsIf you are a Direct Investor and you wish to exercise thecooling off rights, we must receive your writteninstructions in our office before the expiry of thecooling-off period. This cooling-off right must beexercised within 14 days from the earlier of:

when you receive confirmation of your investment; orthe end of the fifth business day after the day on whichyour units were issued or sold to you.

Indirect InvestorsIf you are an indirect investor, you should seek advicefrom your financial adviser or IDPS operator about thecooling-off rights (if any) that might apply to yourinvestment in or through your IDPS.

Wholesale clientsThese cooling-off rights do not apply to wholesale clients(as defined in the Corporations Act 2001 (Cth)). Pleasenote that as an investor in the Fund you will notnecessarily be a wholesale client for the purposes of theCorporations Act 2001 (Cth).

Additional information about makinga complaintAs part of our commitment to providing quality serviceto our investors, we endeavour to resolve all complaintsquickly and fairly. Our policy is to acknowledge anycomplaint promptly after receiving it and investigate,properly consider, and decide what action (if any) to takeand to provide a final response to you within 45 days (30days in relation to privacy complaints).

If you have a particular complaint regarding yourinvestment, please do not hesitate to contact us by callingour Investor Services team on 13 51 53 or +61 2 99947000 from outside Australia (during Sydney businesshours) or by writing to:

Complaints Resolution OfficerFidante PartnersReply Paid 86049Sydney NSW 2001

If you are not happy with our response or how thecomplaint has been handled (or if we have not respondedwithin 45 days, or 30 days in relation to privacycomplaints), you may contact the following externaldispute resolution scheme.

Financial Ombudsman ServiceGPO Box 3Melbourne VIC 3001Tel: 1300 780 808www.fos.org.au

Its service is generally only available to retail clients.

New Zealand investors must send all complaints inwriting to the Financial Markets Authority, New Zealand.

Indirect Investors may either contact their IDPS operatoror us with complaints relating to the Fund. Complaintsregarding the operation of an IDPS should be directedto the IDPS operator. If a complaint is first raised withan IDPS operator and an Indirect Investor is not happywith how the complaint has been handled, they shouldraise that with the IDPS operator or the IDPS operator’sexternal dispute resolution service.

26 Bentham Global Income Fund

Any investment can have a substantial impact on yourtax position from year to year. The following informationis of a general nature and is based on our understandingof the Australian tax laws, as at the date of thisdocument, as they relate to Australian resident individualtaxpayers who hold their investment on capital account.It does not take into the account the Australian or NewZealand tax treatment of New Zealand residenttaxpayers. Fidante Partners is not a registered tax(financial) adviser and is not licensed or authorised toprovide tax advice. We recommend that you obtain yourown professional advice regarding your position, as taxand social security laws are complex and subject tochange, and investors’ individual circumstances vary.

Taxation of the FundThe Attribution Managed Investment Trust (AMIT)legislation applies to qualifying Managed InvestmentTrusts (MITs) that make an irrevocable election tobecome an AMIT. The Responsible Entity hasdetermined that the Fund will elect to become an AMITcommencing from the 2018 financial year.

An AMIT must attribute its taxable income to investorson a fair and reasonable basis, and investors are advisedof their share of the taxable income via an AMIT MemberAnnual Statement (AMMA Statement). The Fund willgenerally not be liable to pay income tax on its taxableincome on the basis that it will attribute all determinedtrust components (i.e. assessable income, exemptincome and non-assessable non-exempt income) tomembers each year. If the Fund were to cease being anAMIT, it should also generally not be liable to pay incometax on the basis that unitholders are presently entitled tothe Fund’s distributable income.

Other key features of the AMIT regime include incomecharacter retention, deemed fixed trust status, an abilityfor adjustments and errors at the trust level to be carriedforward and dealt with in the year in which they arediscovered, adjustments (upwards and downwards)madeto investors’ cost bases for CGT purposes, and theircosts for revenue purposes, where there are differencesbetween the amount distributed and the amountattributed on an AMMA statement, and clarification ofthe treatment of tax deferred distributions.

The MIT capital account election regime permits eligibleMITs to make an irrevocable election to adopt capitalaccount treatment for certain types of assets (broadlyshares, units and real property) for income years to whichthe election applies. An irrevocable election has beenmade in respect of the Fund and accordingly deemedcapital treatment will apply in respect of the qualifyingassets for the income years to which the electionapplies.

The Foreign Investment Fund (FIF) provisions wererepealed with effect from the 2010/2011 income year.The FIF provisions may be replaced by a specificanti-avoidance roll-up rule for Foreign AccumulationFunds (FAF), which seek to ensure that Australianresidents cannot defer or avoid a tax liability on incomeearned in a FAF. As at the date of this document, theGovernment has not released the final FAF legislation.

The Australian Government recently introduced arm’slength income legislation that applies to MITs. Under thislegislation, excess income generated by a MIT fromnon-arm’s length arrangements may be determined tobe subject to tax at 30%. It is not expected that the arm'slength income provisions will impact the Fund.

Tax position of Australian resident investorsYou will generally be required to include in yourassessable income your attributed income of the Fund.Where investors disagree with the allocation of taxableincome in an AMMAStatement, theymay give a 'memberchoice' to the Commissioner of Taxation. In the eventinvestors make a member choice, the constitutionprovides that the investors will indemnify us for all costsand liabilities incurred as a result of the member choice.

Tax losses incurred by the Fund will remain in the Fundand can be applied to reduce the Fund’s income in futureyears (subject to the Fund satisfying the specificprovisions of the trust loss carry forward legislation).

CGT cost base reductions or uplifts may occur wheretaxable income attributed is either less than or greaterthan, respectively, the total of both cash distributed andtax offsets attributed for an income year. Where costbase reductions occur, this will affect the CGT positionof the investment. For those investors who have a zerocost base in their units, or where the total cost basereduction amount exceeds the cost base of their units,a capital gain may arise to these investors for that year.Investors should maintain records of their cost baseadjustments. You may also be entitled to tax offsets(franking credits and/or foreign tax offsets) attributed bythe Fund. Provided investors satisfy certain provisionsof the Tax Act, investors may be able to utilise theseoffsets against their tax liability on the taxablecomponents of the distributions. In order to claim theamount of tax offsets, investors must include the amountof the offsets in their assessable income.

We will advise each investor of their share of tax offsetsin the AMMA statement.

The disposal of units (for instance by withdrawal ortransfer) may give rise to a capital gains tax liability or acapital loss. Investors who have held their units on capitalaccount for more than 12 months may be entitled to acapital gains tax discount.

Bentham Global Income Fund 27

Howmanaged investment schemes are taxed

The Taxation of Financial Arrangement (TOFA)provisions apply on a mandatory basis to qualifyingtaxpayers in respect of certain financial arrangements.Broadly, the TOFA provisions recognise certain gainsand losses on financial arrangements on an accrualsbasis, which may result in a taxing point prior to therealisation of the investment. Due to the implementationof the TOFA regime, there may be some instances whereyour attributed share of the taxable income of the Fundexceeds the cash distribution you receive from the Fund.As at the date of this document, we, as ResponsibleEntity of the Fund, have not made an election to applyone of the elective methods under TOFA.

Any investors who are non-residents should seekprofessional advice in respect of the Australian andforeign tax implications of their investment.

Non-resident account holder reportingrequirementsAs a result of an increased international focus on accountholder data exchange, a number of countries havelegislated that financial institutions (which includes us)identify and report certain information about the financialaccounts of investors. The regimes include the UnitedStates Foreign Account Tax Compliance Act (FATCA)and the OECD's Common Reporting Standard (CRS).To comply with our obligations under various reportinglegislation we will provide to the ATO such data asrequired in respect of your investment with us. This willbe required if you are a US citizen or a foreign taxresident of any jurisdiction outside of Australia. If we haveattempted to confirm your tax status with you but havebeen unable to do so, we may still be required to notifythe ATO.

Goods and Services Tax (GST)GST is not payable on the issue, withdrawal or transferof units in the Fund, as these are input-taxed financialsupplies for GST purposes. However, GST will generallybe incurred on various acquisitions made by the Fund,including the acquisition of investment managementservices. In certain specified circumstances, the Fundmay be entitled to input tax credits (ITCs), or reducedinput tax credits (RITCs) at the prescribed percentageof 55% or 75% depending on the acquisition. Anyavailable ITCs or RITCs effectively reduce thenon-recoverable GST cost incurred.

Tax File NumberOn your application form you may provide us with yourTax File Number (TFN), or TFN exemption. Alternatively,if you are investing in the Fund in the course of an

enterprise, you may quote an Australian BusinessNumber (ABN). It is not compulsory for you to quote aTFN, exemption or ABN, but if you do not, then we arerequired to deduct tax from your attributed or distributedamounts at the highest marginal tax rate plus theMedicare levy (and any other levies we are required todeduct, from time to time). The collection of TFNs isauthorised, and their use is strictly regulated by tax andprivacy laws. Non-residents are generally exempt fromproviding a TFN, however may be required to provideother information.

28 Bentham Global Income Fund

How unit prices are calculatedUnit prices are determined in accordance with the Fund’sconstitution and are usually calculated each NSWbusiness day. The calculation of both the investment unitprice and the withdrawal unit price is based on the netasset value (NAV) adjusted by the buy/sell spread. Forinformation on buy/sell spreads, refer to ‘Buy/sellspreads’ in 'Additional explanation of fees and costs'.

For investment and withdrawal unit prices, the NAV isthe value of all the Fund’s assets attributed to the Fundless the value of the Fund’s liabilities at the valuationtime. When calculating the NAV, we must use the mostrecent valuations of the Fund’s assets and the mostrecent determination of the liabilities.

The Fund’s assets and liabilities are usually valued eachNSW business day. Generally, for unit pricing purposes,listed securities are valued using the last available marketclose price quoted on the relevant exchange. Otherassets are generally valued at recoverable value. Anyincome entitlements, cash at bank, and any amount ofGoods and Services Tax (GST) recoverable by the Fundfrom the Australian Taxation Office are also included inasset values used to calculate the investment andwithdrawal unit price.

Generally, for unit pricing purposes, liabilities are valuedat cost. Liabilities also include an accrual formanagement costs (which includes management feesup to and including the calculation date) and for costs (ifany) that an investor would ordinarily incur wheninvesting in the Fund’s underlying assets.

Where we receive a valid transaction request before thetransaction cut-off time of 3:00pm (Sydney time) on aNSW business day, the unit price will generally bedetermined at the next valuation time after thattransaction cut-off time. This is typically referred to as‘forward pricing’.

In rare circumstances, we may suspend unit pricingwhere, acting in accordance with our Responsible Entityobligations to unitholders, we consider it impracticableto calculate a NAV.

We have a Unit Pricing Permitted Discretions Policy. Thepolicy sets out how we will exercise any discretions inrelation to unit pricing (such as, for example, how oftenwe determine unit prices and valuation methodology). Ifwe depart from our policy, we are also required to recorddetails of this departure. You can obtain a copy of thispolicy or any recorded departures free of charge bycalling us.

Additional information aboutdistributionsIf we pay a distribution, as a Direct Investor you maychoose to have your distribution reinvested in additionalunits in the Fund, or paid directly to your nominatedaccount with an Australian financial institution. Unlessyou have indicated otherwise, we will reinvest yourdistributions.

As an Indirect Investor you should contact your IDPSoperator for distribution payment or reinvestmentoptions.

The price of units issued on reinvestment of distributionsis the investment price for units next determined afterthe close of business on the last day of the distributionperiod. There is no buy/sell spread reflected in thisinvestment price. The amount of each distribution mayvary. Your share of any distribution depends on howmany units you hold at the end of the relevant period asa proportion of the total number of units in the relevantclass on issue at that time and the amount of distributableincome referable to those units and that class.

As distributable amounts are a component of the unitprice, unit prices normally fall by the distribution amountfollowing a distribution.

The amount of income distributed each year will generallybe the distributable income received by the Fund, unlesswe decide to distribute a different amount. Any net capitalgains derived by the Fund during the financial year aregenerally distributed in the June distribution period.

If you invest just prior to a distribution payment, you mayreceive some of your investment back immediately asincome. Conversely, if you withdraw from the Fund justbefore a distribution, you might turn income into a capitalgain or reduce your capital losses.

Generally, if any distribution payments are returned tous and remain outstanding for a period of 6 months, wemay reinvest those distributions and amend your futuredistribution method to reinvest.

Any reinvestment of an unclaimed or returned distributionwill be processed using the investment unit price currentat the time of the reinvestment transaction.

If you wish to change your distribution paymentinstructions, please follow the process outlined below.

Direct InvestorsPlease mail us an original, signed, written request.

Indirect InvestorsPlease contact your IDPS operator for the documentationrequired.

Bentham Global Income Fund 29

Additional information

How the Fund is governedThe Fund’s constitution, together with the CorporationsAct 2001 (Cth) and other laws, governs the way in whichthe Fund operates, including the rights, responsibilitiesand duties of the Responsible Entity and unitholders.

The constitutionThe constitution contains the rules relating to a numberof issues including:

unitholder rights;the process by which units are issued and redeemed;the calculation and distribution of income;the investment powers of the Responsible Entity;the Responsible Entity’s right to claim indemnity fromthe Fund and charge fees and expenses to the Fund;the creation of other classes of units; andthe termination of the Fund.

It is generally thought that unitholders’ liabilities arelimited to the value of their holding in the Fund. It is notexpected that a unitholder would be under any obligationif a deficiency in the value of the Fund was to occur.However, this view has not been fully tested at law.

Unitholders can inspect a copy of the constitution at ourhead office or we will provide them with a copy free ofcharge, on request.

We may alter the constitution if we reasonably considerthe amendments will not adversely affect unitholders’rights. Otherwise (subject to any exemption under thelaw), we must obtain unitholder approval at a meeting ofunitholders. We may retire or be required to retire asResponsible Entity if unitholders vote for our removal.

Termination

The constitution, together with the Corporations Act 2001(Cth), governs how and when the Fund may beterminated. We may terminate the Fund at any time bywritten notice to unitholders. On termination, a unitholderis entitled to a share of the net proceeds of our realisationof the assets in proportion to the number of units theyhold in the Fund.

Unitholder meetings

The conduct of unitholder meetings and unitholders’rights to requisition, attend and vote at those meetingsare subject to the Corporations Act 2001 (Cth) and (tothe extent applicable) the Fund’s constitution.

Compliance plan and compliance committeeWe have lodged the Fund’s compliance plan with theAustralian Securities and Investments Commission(ASIC) and established a compliance committee for theFund with a majority of external members. Thecompliance plan sets out how we will ensure compliancewith both the Corporations Act 2001 (Cth) and the Fund’sconstitution.

The compliance committee’s role is to monitorcompliance with the compliance plan. It must alsoregularly assess the adequacy of the compliance planand report any breaches of the Corporations Act 2001(Cth) or the Fund’s constitution to us. If we do not takeappropriate action to deal with the breach, thecompliance committee must report the breach to ASIC.

The Fund and the compliance plan are required to beaudited annually.

Other partiesWe have engaged a custodian to hold the assets of theFund. The custodian has no independent discretion withrespect to the holding of assets and is subject toperformance standards.

The Fund has a registered company auditor. Theauditor’s role is to provide an audit of the financialstatements of the Fund each year, as well as performinga half-yearly review (if required), and to provide anopinion on the financial statements.

Other important informationIndirect InvestorsInvestors accessing the Fund through an investordirected portfolio service (IDPS) or IDPS-like scheme(known commonly as a master trust or wrap account)may use, or be given, this PDS when deciding to investin the Fund. These investors are referred to as IndirectInvestors.

Indirect Investors do not become unitholders in the Fund,nor do they acquire the rights of a unitholder. Theoperator of the IDPS (IDPS operator) acquires thoserights and can exercise or decline to exercise them onbehalf of Indirect Investors. Indirect Investors do notreceive distributions or reports directly from us, nor dothey directly participate in investor meetings or thewinding up of the Fund if this were to occur. Indirectinvestors should direct all enquiries or complaints aboutthe operation of their IDPS to the IDPS operator. In

30 Bentham Global Income Fund

relation to complaints about the Fund, Indirect Investorsmay contact either their financial adviser, their IDPSoperator, or us.

In addition to reading this PDS, Indirect Investors shouldcarefully read the IDPS operator’s offer document, whichexplains the service and the fees payable by the IndirectInvestor to the IDPS operator. To invest, IndirectInvestors need to complete the documentation whichtheir IDPS operator requires.

New Zealand InvestorsThis offer to New Zealand investors is a regulated offermade under Australian and New Zealand law. InAustralia, this is Chapter 8 of the Corporations Act 2001(Cth) (Aust) and regulations made under that Act. In NewZealand, this is subpart 6 of Part 9 of the FinancialMarkets Conduct Act 2013 and Part 9 of the FinancialMarkets Conduct Regulations 2014. Please refer to‘Important Information for New Zealand Investors’

PrivacyWe collect, use and disclose personal information to:

process your application;provide and administer your investment and send youinformation;improve and personalise our products and services;conduct product and market research;inform you about other products and services that maybe useful to you; andcomply with our obligations under the law, includingwith respect of anti-money laundering, financialservices and taxation laws.

We collect personal information from you and, if relevant,from your financial adviser. We may take steps to verifythe information collected. Where you provide us withpersonal information about someone else (for example,your power of attorney, or related persons including thebeneficial owners connected with your investment) youmust have their consent to provide their personalinformation to us.

If you decide not to provide certain information, we maynot be able to process your investment or futurewithdrawal requests, or will have to deduct tax from anyamounts attributed or distributed to you at the highestmarginal tax rate plus the Medicare levy (and any otherlevies we are required to deduct, from time to time).

Disclosing your information

We disclose your information to your financial adviser.In addition, we may disclose information we hold aboutyou:

if you consent to the disclosure;if the disclosure is required or authorised by law;to organisations acting on our behalf (for example,sending your statements);to professional service firms that provide services tous such as legal and audit services, or data orinformation services;to related companies and/or the investment managerthat may also provide you with a financial product orfinancial service;to electronic identity verification service providers, inorder for identity information (about you or relatedpersons connected with your investment) to be verifiedagainst relevant government and other databases, forthe purpose of complying with anti-money launderinglaws; orotherwise in accordance with our privacy policy.

We do not disclose personal information to recipients inforeign jurisdictions.

From time to time we or our related companies maycontact you to tell you about other products and servicesthat might be useful to you, including financial,superannuation, investment, insurance and fundsmanagement products and services. Please contact us(our details are noted in this PDS) if you do not want toreceive any of this kind of marketing material.

For how you can correct or update the personalinformation we hold about you refer to ‘Keeping usinformed’. Our privacy policy also contains thisinformation as well as further details about our handlingof personal information and about how you can requestaccess to it or lodge a complaint if you believe yourpersonal information has been misused, and how wedeal with complaints.

For more information regarding the collection and useof personal information, please refer to our ‘PrivacyPolicy’ available on our website or by contacting ourInvestor Services team.

We do not normally receive any personal informationabout you when you invest in the Fund through an IDPSoperator. For details on the collection, storage and useof personal information you should contact your IDPSoperator. The information we collect and store from IDPSoperators is used to establish and administer itsinvestments. If we do receive any personal informationwe will deal with it in accordance with our privacy policy.

Bentham Global Income Fund 31

ExplanationInvestment term

Refers to a style of portfolio management where the manager actively makes specific investmentswith the goal of outperforming an investment benchmark. Portfolio investment strategies aregenerally constrained within specific investment risk limits.

active management

A debt security that is secured by assets such as loans, leases, credit card debt, etc. Refer to'Credit risk’ for more information.

asset backed security(ABS)

An investment approach where the focus of the analysis is on individual securities with lessemphasis on broad economic and market cycle themes.

bottom-up analysis

Cash and short-term securities include cash, deposits and short-term bank bills. Cash traditionallyproduces a stable investment return (through the payment of interest).

cash

A derivative contract designed to transfer the credit risk exposure of a debt security from one partyto another. A CDS contract can be used to create or reduce exposure on a particular debt security.In the event of default on an underlying debt security, the purchaser of the CDS contract is generallyentitled to receive face value in exchange for delivering the underlying debt security.

credit default swap (CDS)

A debt security or derivative that has credit risk.credit investment

Buying a CDS contract to protect, or benefit from, the deterioration in credit quality of an underlyingdebt security.

credit protection

A financial instrument that is an obligation of its issuer to make payments to the holder of theinstrument. The terms of the instrument define the interest payment terms, maturity date andinvestor protections. Debt securities can be bought and sold between different parties eitherover-the-counter or on an exchange. Examples of debt securities include government bonds,investment grade corporate bonds, non-investment grade corporate bonds (high yield bonds),syndicated loans, preferred securities and asset backed securities.

debt security

The financial ratio that relates the change in the price of a derivative to the corresponding changein the price of an underlying asset.

equity delta

A fixed interest security is a debt security that makes interest payments based on a fixed rate thatis set at the time of issuance. The market value of fixed interest securities can be affected bychanges in market interest rates.

fixed income security

A non-investment grade security issued by a corporation.high yield bond

Hybrid securities are financial securities that have aspects of both equity and debt securities. Thesecurities can include debt security terms such as defined interest payments and redemptionfeatures as well as equity terms such as the ability to convert into equity and discretionary paymentof income distributions.

hybrid security

Debt securities are generally assigned a credit rating of BBB–/Baa3 or better by the credit ratingagencies. The credit ratings assigned by rating agencies represent an assessment of the borrower’screditworthiness, that is, its ability to make interest and principal payments. Higher rated borrowerswith an investment grade rating generally allow companies to reduce the interest rates that theypay on their debt when compared with lower rated borrowers.

investment grade security

Debt securities that are generally unrated or assigned a credit rating of below BBB–/Baa3 by thecredit rating agencies. The credit ratings assigned by rating agencies represent an assessmentof the borrower’s creditworthiness, that is, its ability to make interest and principal payments.Non-investment grade borrowers generally pay higher interest rates than higher rated borrowersas their financial position is not as strong.

non-investment gradesecurity

A debt security that has not been rated by a large credit rating agency, usually because the securityis too small.

non-rated securities

32 Bentham Global Income Fund

Glossary

ExplanationInvestment term

Shares (also known as equities) represent the part ownership in a company and generally havevoting rights. Shares are the residual claim on the assets of a company after all liabilities are paid.Shareholders may be entitled to receive some of the company’s profits if the company’s boarddecides to pay a dividend. Shareholders may experience some capital growth if the share pricerises, or some capital loss may occur if the share price falls.

shares/equities

An investment approach that focuses on broader economic andmarket cycle themes in an attemptto identify investment sectors that are forecasted to outperform the market (not the individualcompany or companies).

top-down investing

Bentham Global Income Fund 33

This offer to New Zealand investors is a regulated offermade under Australian and New Zealand law. InAustralia, this is Chapter 8 of the Corporations Act 2001(Aust) and regulations made under that Act. In NewZealand, this is subpart 6 of Part 9 of the FinancialMarkets Conduct Act 2013 and Part 9 of the FinancialMarkets Conduct Regulations 2014.

This offer and the contents of the offer document areprincipally governed by Australian rather than NewZealand law. In the main, the Corporations Act 2001(Aust) and the regulations made under that Act set outhow the offer must be made.

There are differences in how financial products areregulated under Australian law. For example, thedisclosure of fees for managed investment schemes isdifferent under the Australian regime.

The rights, remedies, and compensation arrangementsavailable to New Zealand investors in Australian financialproducts may differ from the rights, remedies, andcompensation arrangements for New Zealand financialproducts.

Both the Australian and New Zealand financial marketsregulators have enforcement responsibilities in relationto this offer. If you need to make a complaint about thisoffer, please contact the Financial Markets Authority,New Zealand (http://www.fma.govt.nz). The Australianand New Zealand regulators will work together to settleyour complaint.

The taxation treatment of Australian financial productsis not the same as for New Zealand financial products.If you are uncertain about whether this investment isappropriate for you, you should seek the advice of anappropriately qualified financial adviser.

This offer may involve a currency exchange risk. Thecurrency for the financial products is not New Zealanddollars. The value of the financial products will go up ordown according to changes in the exchange rate betweenthat currency and New Zealand dollars. These changesmay be significant.

If you expect the financial products to pay any amountsin a currency that is not in New Zealand dollars, you mayincur significant fees in having the funds credited to abank account in New Zealand dollars.

The dispute resolution process described in this offerdocument is available only in Australia and is notavailable in New Zealand.

Contact details for New Zealand InvestorsInvestor Services team: +612 9994 70008.00am to 6.00pm Monday to Friday (Sydney time)Fax: +612 9994 6666Website: www.fidante.com.au

34 Bentham Global Income Fund

Important information for New Zealandinvestors

Level 12179 Elizabeth StreetSydney NSW 2000

T 02 9994 7921F 02 9994 6666

Bentham Asset Management Pty Limited (ABN 92 140 833 674, AFSL 356199) is authorised to provide financialservices to wholesale clients only. The information in this document is provided for use by such wholesale clients, isgeneral in nature and does not take into account the personal circumstances, financial needs or objectives of anyperson. You should seek independent financial advice and read any relevant Product Disclosure Statement or otheroffer document prior to acquiring a financial product.