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Important information

The information and material contained in this website are designed to provide information on Martin Currie and is only directed at Institutional Investors and Consultants.

By accepting where indicated, you hereby acknowledge, agree and represent to Martin Currie that you are eligible by confirming that you are based in the UK, you are an authorised to conduct regulated activities in the UK and that you have read and understood the "Legal & Regulatory Information", which applies to any investment in our products referred to in this website.

The information contained within this website does not constitute an offer of or an invitation to apply for securities:

In any jurisdiction where such offer or invitation is unlawful or
In which the person making such offer is not qualified to do so or
To whom it is unlawful to make such offer or solicitation.

Martin Currie Investment Management Limited is authorised and regulated in the UK by the Financial Conduct Authority.

The distribution of this information in written format is restricted to the UK. The information contained in this site has been compiled with considerable care to ensure its accuracy at the date of publication. But no representation or warranty, express or implied, is made to its accuracy or completeness. Any research or analysis contained in this website has been procured by Martin Currie for its own use. It is provided to you only incidentally, and any opinions expressed are subject to change without notice.
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For advisors, professional wealth managers and wholesale investors

Important information

The information and material contained in this website are designed to provide information on Martin Currie and is only directed at Institutional Investors and Consultants.

By accepting where indicated, you hereby acknowledge, agree and represent to Martin Currie that you are eligible by confirming that you are based in the UK, you are an authorised to conduct regulated activities in the UK and that you have read and understood the "Legal & Regulatory Information", which applies to any investment in our products referred to in this website.

The information contained within this website does not constitute an offer of or an invitation to apply for securities:

In any jurisdiction where such offer or invitation is unlawful or
In which the person making such offer is not qualified to do so or
To whom it is unlawful to make such offer or solicitation.

Martin Currie Investment Management Limited is authorised and regulated in the UK by the Financial Conduct Authority.

The distribution of this information in written format is restricted to the UK. The information contained in this site has been compiled with considerable care to ensure its accuracy at the date of publication. But no representation or warranty, express or implied, is made to its accuracy or completeness. Any research or analysis contained in this website has been procured by Martin Currie for its own use. It is provided to you only incidentally, and any opinions expressed are subject to change without notice.
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For consultants, pension schemes, insurers and professional investors

Please read this important information

Please read this important information. If you cannot make the representations below, please do not enter the website.

By clicking on this link, you agree and represent to Martin Currie that you are a resident of or incorporated in the United Kingdom have read and understood the "Important Information and Risk Factors", which apply to any investment in our products referred to in this website, and that you are categorised as a per se or elective Professional Client for the purposes of COBS 3 of the FCA Handbook or rules and guidance. The information on this section of the website is not intended for use by any other person, including members of the public.

Martin Currie Investment Management Limited, registered in Scotland (no SC066107) is authorised and regulated by the UK Financial Conduct Authority. Martin Currie Fund Management Limited, registered in Scotland (no SC104896) is authorised and regulated by the UK Financial Conduct Authority as a full-scope UK AIFM.

For the avoidance of doubt, nothing excludes, limits or restricts our obligations to you under the UK Financial Services and Market Act 2000 or any other applicable law or regulation.

The opinions and views in this website do not take into account your individual circumstances, objectives, or needs and are not intended to be recommendations of particular financial instruments or strategies to you. This website does not identify all the risks (direct or indirect) or other considerations which might be material to you when entering any financial transaction. You should consult with your professional advisers before undertaking any investment activity. The information provided on this website should not be treated as advice or a recommendation to buy or sell any particular security or other investment. The information on this website has not been reviewed by any competent regulatory authority.

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For advisors, professional wealth managers and wholesale investors

Please read this important information

Please read this important information. If you cannot make the representations below, please do not enter the website.

By clicking on this link, you agree and represent to Martin Currie that you are a resident of or incorporated in the United Kingdom have read and understood the "Important Information and Risk Factors", which apply to any investment in our products referred to in this website, and that you are categorised as a per se or elective Professional Client for the purposes of COBS 3 of the FCA Handbook or rules and guidance. The information on this section of the website is not intended for use by any other person, including members of the public.

Martin Currie Investment Management Limited, registered in Scotland (no SC066107) is authorised and regulated by the UK Financial Conduct Authority. Martin Currie Fund Management Limited, registered in Scotland (no SC104896) is authorised and regulated by the UK Financial Conduct Authority as a full-scope UK AIFM.

For the avoidance of doubt, nothing excludes, limits or restricts our obligations to you under the UK Financial Services and Market Act 2000 or any other applicable law or regulation.

The opinions and views in this website do not take into account your individual circumstances, objectives, or needs and are not intended to be recommendations of particular financial instruments or strategies to you. This website does not identify all the risks (direct or indirect) or other considerations which might be material to you when entering any financial transaction. You should consult with your professional advisers before undertaking any investment activity. The information provided on this website should not be treated as advice or a recommendation to buy or sell any particular security or other investment. The information on this website has not been reviewed by any competent regulatory authority.

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This website is intended for, and is relevant to, UK residents only and should not be relied upon by persons of any other jurisdiction.

By accepting where indicated, you hereby acknowledge, agree and represent to Martin Currie that you are eligible by confirming that you are based in the UK and that you have read and understood the "Legal Regulatory Information" which applies to any investment in our products referred to in this website.

Important Information:

We do not give investment advice so you need to decide if an investment is suitable for you. If you are unsure whether to invest, you should contact a financial adviser.

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By clicking on this link, you agree and represent to Martin Currie that you have read and understood the "Important information and risk factors", which apply to any investment in our products referred to in this website, and that you are incorporated in a country listed below and that you are either an institutional investor, a corporate professional investor or a consultant business. The information on this section of the website is not intended for use by any other person in any other jurisdiction, including members of the public. If you cannot make these representations, please do not enter the website.

All residents of Hong Kong: Neither Martin Currie Investment Management Limited nor Martin Currie Inc. carries on a business in a regulated activity in Hong Kong or is licensed by the Securities and Futures Commission. The content of this section of the website is intended for Professional Investors only.

All residents of Singapore: The information in this section of the website is intended for institutional investors (as defined in the Securities and Futures Act, Chapter 289 of Singapore, as amended) and consultants in Singapore only.

All residents of China: Neither Martin Currie Investment Management Limited nor Martin Currie Inc. is authorised by the China Securities Regulatory Commission to market its strategies in China. By clicking on this link, you warrant and represent that you are entering this website on your own initiative and without being influenced or induced by any third party to do so.

All residents of South Korea: The information in this section of the website is intended only for qualified professional investors and consultants based in South Korea.

Martin Currie Investment Management Limited, registered in Scotland (no SC066107). Martin Currie Inc, incorporated in New York and having a UK branch registered in Scotland (no SF000300), Saltire Court, 20 Castle Terrace, Edinburgh EH1 2ES Tel: (44) 131 229 5252 Fax: (44) 131 222 2532 www.martincurrie.com. Both companies are authorised and regulated by the UK Financial Conduct Authority. Martin Currie Inc, 620 Eighth Avenue, 49th Floor New York, NY 10018 is also registered with the Securities Exchange Commission as an investment adviser for the purposes of the Investment Advisers Act 1940.

For the avoidance of doubt, nothing excludes, limits or restricts our obligations to you under the UK Financial Services and Market Act 2000, the Investment Advisers Act 1940 or any other applicable law or regulation.

The opinions and views in this website do not take into account your individual circumstances, objectives, or needs and are not intended to be recommendations of particular financial instruments or strategies to you. This website does not identify all the risks (direct or indirect) or other considerations which might be material to you when entering any financial transaction. You should consult with your professional advisers before undertaking any investment activity. The information provided on this website should not be treated as advice or a recommendation to buy or sell any particular security or other investment. The information on this website has not been reviewed by any competent regulatory authority.

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Intermediary investor

For advisors, professional wealth managers and wholesale investors

Please read this important information

By clicking on this link, you agree and represent to Martin Currie that you have read and understood the "Important information and risk factors", which apply to any investment in our products referred to in this website, and that you are incorporated in a country listed below and that you are either an institutional investor, a corporate professional investor or a consultant business. The information on this section of the website is not intended for use by any other person in any other jurisdiction, including members of the public. If you cannot make these representations, please do not enter the website.

All residents of Hong Kong: Neither Martin Currie Investment Management Limited nor Martin Currie Inc. carries on a business in a regulated activity in Hong Kong or is licensed by the Securities and Futures Commission. The content of this section of the website is intended for Professional Investors only.

All residents of Singapore: The information in this section of the website is intended for institutional investors (as defined in the Securities and Futures Act, Chapter 289 of Singapore, as amended) and consultants in Singapore only.

All residents of China: Neither Martin Currie Investment Management Limited nor Martin Currie Inc. is authorised by the China Securities Regulatory Commission to market its strategies in China. By clicking on this link, you warrant and represent that you are entering this website on your own initiative and without being influenced or induced by any third party to do so.

All residents of South Korea: The information in this section of the website is intended only for qualified professional investors and consultants based in South Korea.

Martin Currie Investment Management Limited, registered in Scotland (no SC066107). Martin Currie Inc, incorporated in New York and having a UK branch registered in Scotland (no SF000300), Saltire Court, 20 Castle Terrace, Edinburgh EH1 2ES Tel: (44) 131 229 5252 Fax: (44) 131 222 2532 www.martincurrie.com. Both companies are authorised and regulated by the UK Financial Conduct Authority. Martin Currie Inc, 620 Eighth Avenue, 49th Floor New York, NY 10018 is also registered with the Securities Exchange Commission as an investment adviser for the purposes of the Investment Advisers Act 1940.

For the avoidance of doubt, nothing excludes, limits or restricts our obligations to you under the UK Financial Services and Market Act 2000, the Investment Advisers Act 1940 or any other applicable law or regulation.

The opinions and views in this website do not take into account your individual circumstances, objectives, or needs and are not intended to be recommendations of particular financial instruments or strategies to you. This website does not identify all the risks (direct or indirect) or other considerations which might be material to you when entering any financial transaction. You should consult with your professional advisers before undertaking any investment activity. The information provided on this website should not be treated as advice or a recommendation to buy or sell any particular security or other investment. The information on this website has not been reviewed by any competent regulatory authority.

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Institutional investor

For consultants, Superannuation, insurers and professional investors

Please read this important information

By clicking on this link, you agree and represent to Martin Currie that you are an Australian wholesale client for the purposes of section 761G of the Corporations Act 2001 (Cth) and have read and understood the "Legal and Regulatory Information”", which apply to any investment in our products referred to in this website. The information on this section of the website is not intended for use by any other person, including members of the public. If you cannot make these representations, please do not enter the website.

Important Information:

Martin Currie Australia is a division of Legg Mason Asset Management Australia Limited (ABN 76 004 835 849). Legg Mason Asset Management Australia Limited is a wholly owned subsidiary of Franklin Resources, Inc., and holds an Australian Financial Services Licence (AFSL No. 240827) issued pursuant to the Corporations Act 2001.

Martin Currie Investment Management Limited, registered in Scotland (no SC066107) is authorised and regulated by the UK Financial Conduct Authority.

The FCA's regulatory regime differs from the Australian regulatory regime.
This material is provided on the basis that you are a wholesale client within the definition of ASIC Class Order 03/1099. Martin Currie is registered as a foreign company under the Corporations Act 2001 (ARBN 131 134 613). It is exempt from the requirement to hold an Australian Financial Services Licence under the Corporations Act 2001 in respect of financial services provided to Australian wholesale clients by virtue of the application of ASIC Class Order 03/1099.

The opinions and views in this website do not take into account your individual circumstances, objectives, or needs and are not intended to be recommendations of particular financial instruments or strategies to you. This website does not identify all the risks (direct or indirect) or other considerations which might be material to you when entering any financial transaction. You should consult with your professional advisers before undertaking any investment activity. The information provided on this website should not be treated as advice or a recommendation to buy or sell any particular security or other investment. The information on this website has not been reviewed by any competent regulatory authority.

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Intermediary investor

For advisors, professional wealth managers and wholesale investors

Please read this important information

By clicking on this link, you agree and represent to Martin Currie that you are an Australian wholesale client for the purposes of section 761G of the Corporations Act 2001 (Cth) and have read and understood the "Legal and Regulatory Information”", which apply to any investment in our products referred to in this website. The information on this section of the website is not intended for use by any other person, including members of the public. If you cannot make these representations, please do not enter the website.

Important Information:

Martin Currie Australia is a division of Legg Mason Asset Management Australia Limited (ABN 76 004 835 849). Legg Mason Asset Management Australia Limited is a wholly owned subsidiary of Franklin Resources, Inc., and holds an Australian Financial Services Licence (AFSL No. 240827) issued pursuant to the Corporations Act 2001.

Martin Currie Investment Management Limited, registered in Scotland (no SC066107) is authorised and regulated by the UK Financial Conduct Authority.

The FCA's regulatory regime differs from the Australian regulatory regime.
This material is provided on the basis that you are a wholesale client within the definition of ASIC Class Order 03/1099. Martin Currie is registered as a foreign company under the Corporations Act 2001 (ARBN 131 134 613). It is exempt from the requirement to hold an Australian Financial Services Licence under the Corporations Act 2001 in respect of financial services provided to Australian wholesale clients by virtue of the application of ASIC Class Order 03/1099.

The opinions and views in this website do not take into account your individual circumstances, objectives, or needs and are not intended to be recommendations of particular financial instruments or strategies to you. This website does not identify all the risks (direct or indirect) or other considerations which might be material to you when entering any financial transaction. You should consult with your professional advisers before undertaking any investment activity. The information provided on this website should not be treated as advice or a recommendation to buy or sell any particular security or other investment. The information on this website has not been reviewed by any competent regulatory authority.

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Institutional investor

For consultants, pension schemes, insurers and professional investors

Please read this important information

Please read this important information. The information on this section of the website is not intended for use by any other person in any other jurisdiction, including members of the public. If you cannot make the following representations, please do not enter the website.

All residents of Luxembourg, Republic of Ireland, Netherlands, Germany, Sweden, Finland, Norway, Denmark, Italy, Belgium and France: By clicking on this link, you agree and represent to Martin Currie that you have read and understood the "Important information and risk factors", which apply to any investment in our products referred to in this website, and that you are categorised as a per se or elective Professional Client for the purposes of Directive 2014/65/EU (“MiFID II”). The information on this section of the website is not intended for use by any other person, including members of the public.

All residents of Switzerland: By clicking on this link, you agree and represent to Martin Currie that you have read and understood the "Important information and risk factors", which apply to any investment in our products referred to in this website, and that that you are resident in or incorporated in Switzerland and that you are a Qualified Investor for the purposes of Article 10 of the Collective Investment Schemes Act. The information on this section of the website is not intended for use by any other person, including members of the public.

Martin Currie Investment Management Limited, registered in Scotland (no SC066107) is authorised and regulated by the UK Financial Conduct Authority. Martin Currie Investment Management Limited has a MiFID II passport to provide investment services to Professional Clients in the European Union.

For the avoidance of doubt, nothing excludes, limits or restricts our obligations to you under the UK Financial Services and Market Act 2000 or any other applicable law or regulation.

The opinions and views in this website do not take into account your individual circumstances, objectives, or needs and are not intended to be recommendations of particular financial instruments or strategies to you. This website does not identify all the risks (direct or indirect) or other considerations which might be material to you when entering any financial transaction. You should consult with your professional advisers before undertaking any investment activity. The information provided on this website should not be treated as advice or a recommendation to buy or sell any particular security or other investment. The information on this website has not been reviewed by any competent regulatory authority.

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Intermediary investor

For advisors, professional wealth managers and wholesale investors

Please read this important information

Please read this important information.

All residents of Luxembourg, Republic of Ireland, Netherlands, Germany, Sweden, Finland, Norway, Denmark, Italy, Belgium and France: By clicking on this link, you agree and represent to Martin Currie that you have read and understood the "Important information and risk factors", which apply to any investment in our products referred to in this website, and that you are categorised as a per se or elective Professional Client for the purposes of Directive 2014/65/EU (“MiFID II”). The information on this section of the website is not intended for use by any other person, including members of the public.

All residents of Switzerland: By clicking on this link, you agree and represent to Martin Currie that you have read and understood the "Important information and risk factors", which apply to any investment in our products referred to in this website, and that that you are resident in or incorporated in Switzerland and that you are a Qualified Investor for the purposes of Article 10 of the Collective Investment Schemes Act. The information on this section of the website is not intended for use by any other person, including members of the public.

Martin Currie Investment Management Limited, registered in Scotland (no SC066107) is authorised and regulated by the UK Financial Conduct Authority. Martin Currie Investment Management Limited has a MiFID II passport to provide investment services to Professional Clients in the European Union.

For the avoidance of doubt, nothing excludes, limits or restricts our obligations to you under the UK Financial Services and Market Act 2000 or any other applicable law or regulation.

The opinions and views in this website do not take into account your individual circumstances, objectives, or needs and are not intended to be recommendations of particular financial instruments or strategies to you. This website does not identify all the risks (direct or indirect) or other considerations which might be material to you when entering any financial transaction. You should consult with your professional advisers before undertaking any investment activity. The information provided on this website should not be treated as advice or a recommendation to buy or sell any particular security or other investment. The information on this website has not been reviewed by any competent regulatory authority.

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Institutional investor

For consultants, pension schemes, insurers and professional investors

Please read this important information. If you cannot make either of the representations below, please do not enter the website.

Investors resident in the Canada: By clicking on this link, you agree and represent to Martin Currie that you have read and understood the "Important information and risk factors", which apply to any investment in our products referred to in this website, and that you are resident in, or incorporated in, Canada and are a Permitted Client for the purposes of NI 31-103. The information on this section of the website is not intended for use by any other person, including members of the public.

Investors resident in the United States of America: By clicking on this link, you agree and represent to Martin Currie that you have read and understood the "Important information and risk factors", which apply to any investment in our products referred to in this website, and that you are either incorporated in, or a resident of, the United States of America and that you meet the definition of an Accredited Investor as defined in Rule 501 of the United States Securities Act of 1933, as amended (‘The 1933 Act’). The information on this section of the website is not intended for use by any other person in any other jurisdiction, including members of the public.

Martin Currie Inc, incorporated in New York with its registered office at 620 Eighth Avenue, 49th Floor New York, NY 10018 and having a UK branch registered in Scotland (no SF000300), Saltire Court, 20 Castle Terrace, Edinburgh EH1 2ES Tel: (44) 131 229 5252 Fax: (44) 131 222 2532 www.martincurrie.com, is registered with the Securities Exchange Commission as an investment adviser for the purposes of the Investment Advisers Act 1940 and is also authorised and regulated by the UK Financial Conduct Authority. Martin Currie Inc. operates under the International Adviser Exemption with the Ontario Securities Commission (‘OSC’) and is therefore currently not required to be registered as a portfolio manager for the purposes of MI 31-103.

For the avoidance of doubt, nothing excludes, limits or restricts our obligations to you under the UK Financial Services and Market Act 2000, the Investment Advisers Act 1940, National Instruments or any other applicable law or regulation.

The opinions and views in this website do not take into account your individual circumstances, objectives, or needs and are not intended to be recommendations of particular financial instruments or strategies to you. This website does not identify all the risks (direct or indirect) or other considerations which might be material to you when entering any financial transaction. You should consult with your professional advisers before undertaking any investment activity. The information provided on this website should not be treated as advice or a recommendation to buy or sell any particular security or other investment. The information on this website has not been reviewed by any competent regulatory authority.

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Intermediary investor

For advisors, professional wealth managers and wholesale investors

Please read this important information

Investors resident in the Canada: By clicking on this link, you agree and represent to Martin Currie that you have read and understood the "Important information and risk factors", which apply to any investment in our products referred to in this website, and that you are resident in, or incorporated in, Canada and are a Permitted Client for the purposes of NI 31-103. The information on this section of the website is not intended for use by any other person, including members of the public.

Investors resident in the United States of America: By clicking on this link, you agree and represent to Martin Currie that you have read and understood the "Important information and risk factors", which apply to any investment in our products referred to in this website, and that you are either incorporated in, or a resident of, the United States of America and that you meet the definition of an Accredited Investor as defined in Rule 501 of the United States Securities Act of 1933, as amended (‘The 1933 Act’). The information on this section of the website is not intended for use by any other person in any other jurisdiction, including members of the public.

Martin Currie Inc, incorporated in New York with its registered office at 620 Eighth Avenue, 49th Floor New York, NY 10018 and having a UK branch registered in Scotland (no SF000300), Saltire Court, 20 Castle Terrace, Edinburgh EH1 2ES Tel: (44) 131 229 5252 Fax: (44) 131 222 2532 www.martincurrie.com, is registered with the Securities Exchange Commission as an investment adviser for the purposes of the Investment Advisers Act 1940 and is also authorised and regulated by the UK Financial Conduct Authority. Martin Currie Inc. operates under the International Adviser Exemption with the Ontario Securities Commission (‘OSC’) and is therefore currently not required to be registered as a portfolio manager for the purposes of MI 31-103.

For the avoidance of doubt, nothing excludes, limits or restricts our obligations to you under the UK Financial Services and Market Act 2000, the Investment Advisers Act 1940, National Instruments or any other applicable law or regulation.

The opinions and views in this website do not take into account your individual circumstances, objectives, or needs and are not intended to be recommendations of particular financial instruments or strategies to you. This website does not identify all the risks (direct or indirect) or other considerations which might be material to you when entering any financial transaction. You should consult with your professional advisers before undertaking any investment activity. The information provided on this website should not be treated as advice or a recommendation to buy or sell any particular security or other investment. The information on this website has not been reviewed by any competent regulatory authority.

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Select your investor type

Institutional investor

For consultants, pension schemes, insurers and professional investors

Please read this important information

Please read this important information. If you cannot make the representations below, please do not enter the website.

By clicking on this link, you agree and represent to Martin Currie that you have read and understood the "Important information and risk factors", which apply to any investment in our products referred to in this website, and that: (i) you are an institutional investor, an intermediary investor a consultant or other professional investor; and (ii) you are entering this website on your own initiative and without being influenced or induced by any third party to do so. The information on this section of the website is not intended for use by any other person, including members of the public.

Martin Currie Investment Management Limited, registered in Scotland (no SC066107). Martin Currie Inc, incorporated in New York and having a UK branch registered in Scotland (no SF000300), Saltire Court, 20 Castle Terrace, Edinburgh EH1 2ES Tel: (44) 131 229 5252 Fax: (44) 131 222 2532 www.martincurrie.com. Both companies are authorised and regulated by the UK Financial Conduct Authority. Martin Currie Inc, 620 Eighth Avenue, 49th Floor New York, NY 10018 is also registered with the Securities Exchange Commission as an investment adviser for the purposes of the Investment Advisers Act 1940.

For the avoidance of doubt, nothing excludes, limits or restricts our obligations to you under the UK Financial Services and Market Act 2000, the Investment Advisers Act 1940 or any other applicable law or regulation. The information on this website has not been reviewed by any competent regulatory authority in any jurisdiction.

The opinions and views in this website do not take into account your individual circumstances, objectives, or needs and are not intended to be recommendations of particular financial instruments or strategies to you. This website does not identify all the risks (direct or indirect) or other considerations which might be material to you when entering any financial transaction. You should consult with your professional advisers before undertaking any investment activity. The information provided on this website should not be treated as advice or a recommendation to buy or sell any particular security or other investment. The information on this website has not been reviewed by any competent regulatory authority.

Accept and enter

Intermediary investor

For advisors, professional wealth managers and wholesale investors

Please read this important information

Please read this important information. If you cannot make the representations below, please do not enter the website.

By clicking on this link, you agree and represent to Martin Currie that you have read and understood the "Important information and risk factors", which apply to any investment in our products referred to in this website, and that: (i) you are an institutional investor, an intermediary investor a consultant or other professional investor; and (ii) you are entering this website on your own initiative and without being influenced or induced by any third party to do so. The information on this section of the website is not intended for use by any other person, including members of the public.

Martin Currie Investment Management Limited, registered in Scotland (no SC066107). Martin Currie Inc, incorporated in New York and having a UK branch registered in Scotland (no SF000300), Saltire Court, 20 Castle Terrace, Edinburgh EH1 2ES Tel: (44) 131 229 5252 Fax: (44) 131 222 2532 www.martincurrie.com. Both companies are authorised and regulated by the UK Financial Conduct Authority. Martin Currie Inc, 620 Eighth Avenue, 49th Floor New York, NY 10018 is also registered with the Securities Exchange Commission as an investment adviser for the purposes of the Investment Advisers Act 1940.

For the avoidance of doubt, nothing excludes, limits or restricts our obligations to you under the UK Financial Services and Market Act 2000, the Investment Advisers Act 1940 or any other applicable law or regulation. The information on this website has not been reviewed by any competent regulatory authority in any jurisdiction.

The opinions and views in this website do not take into account your individual circumstances, objectives, or needs and are not intended to be recommendations of particular financial instruments or strategies to you. This website does not identify all the risks (direct or indirect) or other considerations which might be material to you when entering any financial transaction. You should consult with your professional advisers before undertaking any investment activity. The information provided on this website should not be treated as advice or a recommendation to buy or sell any particular security or other investment. The information on this website has not been reviewed by any competent regulatory authority.

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If none of the above applies to you, please go to our corporate site.

The unintended outcomes of APRA's proposed remuneration changes

Active Ownership will ultimately see better outcomes for all stakeholders than the proposed caps on financial performance metrics.

Executive remuneration is an area where we place significant importance. As active managers, it is our duty to scrutinize, and where necessary, advocate for shareholder conscious remuneration. As such, we regularly address compensation questions in the course of our ongoing engagement with Management and Boards of our portfolio companies.

ARPA is proposing to change renumeration requirements by deemphasizing the role that objective financial metrics play in determining executive compensation.

Watering down financial objectives will only diminish the focus and expectations of Boards and management

We are concerned that, while well intended, the changes will have unintended negative outcomes which impact both investors and the wider public.

As such we recently made a submission to ARPA outlining our concerns. We believe that rather than the proposed caps on financial performance metrics, Active Ownership will ultimately see better outcomes for all stakeholders.

Background to the proposed changes

On 23 July 2019, Australian Prudential Regulation Authority (APRA) released for consultation a discussion paper, “Strengthening Prudential Requirements for Remuneration”.

APRA is proposing to strengthen prudential requirements for remuneration across APRA-regulated entities in the banking, insurance and superannuation industries.

The new prudential standard on remuneration (CPS 511) will address recommendations from the Final Report of the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry.

The core elements of the changes to CPS 511 are to:

  • strengthen governance of remuneration frameworks and outcomes, in particular through an expanded Board role, where the Board needs to be active and have direct oversight;
  • set overarching remuneration objectives that inform design of all remuneration arrangements and influence remuneration outcomes;
  • limit the use of financial performance metrics (share price and profit-based); and
  • set minimum deferral periods (up to seven years) for senior executives to provide more 'skin-in-the-game' through better alignment to the time horizon of risk and performance outcomes.

Our concern on the changes to financial performance metrics

We welcome changes that will help improve the resilience of the financial system and alignment between the interests of financial institutions and those of stakeholders including shareholders, customers and beneficiaries, regulators and the broader community.

However, we are concerned that the proposal to limit the maximum weighting of financial performance metrics to 50%, and for this to apply to all employees, as is currently drafted under item 38, will have unintended outcomes on APRA regulated entities.

We outline our concerns in full in our submission to APRA: Martin Currie Australia submission on CPS 511.

Financial metrics are more tangible and objective than qualitative measures

Our central premise is that in relation to remuneration, we believe the majority of measures for both Short-Term Incentives (“STI”) and Long-Term Incentives (“LTI”) should be easily identifiable, measurable and relate directly to the company’s performance.

Non-financial metrics include, for example, customer outcomes such as loyalty and complaints, reputation and trust, alignment with firm values, employee engagement, team work etc.

Our concern with a prescriptive quantity of qualitative measures is that there is difficulty in ultimately devising the correct non-financial metrics for each firm, and it can create confused incentives, often leading to perverse outcomes.

By contrast, financial metrics which include relative Total Shareholder Returns (“TSR”), are very tangible and objective.

A prime example of a poor application of a non-financial metric was the CBA’s1 introduction of a ‘people & community’ metric in 2016. Absent of formal intervention by the Board in 2017, application of the ‘people & community’ metric for CEO pay would have resulted in an outcome that was outside the realm of reasonability given the AUSTRAC2 issues at the time.The unintended outcomes of APRA's proposed remuneration changes

By favouring all stakeholder, none benefit fully.

By definition, using non-financial metrics which treat the interests of all stakeholders as equivalent, decisions made will leave some stakeholders better off and some worse off.

Expert in corporate governance and Professor of Finance at NYU Stern School of Business, Aswath Damodaran, also predicts that “expanding decision making to take into account the interests of all stakeholders will create decision paralysis3.”

This begs the question; how Boards can truly be held accountable when there are multiple conflicting interests. Where to now for shareholder primacy?

Non-financial metrics do have merit for front line

We do see merit in using non-financial measures as key performance indicators, for specific employee groups, such as front line staff who interact with customers and suppliers. Our position recognises that there are significant differences in staff’s accountability and duty to customers compared to that of the CEO and Board accountability to their shareholders.

Qualitative measures can more easily be rorted

Financial metrics such as TSR are not easily manipulated. We see improved TSR is only achieved as a result of management efforts delivers benefits to shareholders and stakeholders. However, if a minimum number of intangible measures are mandated by APRA, we expect management will find ways to ensure they are met.

We also have concerns that this could divert management’s focus away from adhering to unbiassed accounting practices, hence reducing financial reporting quality.

We believe that this could lead to the exact opposite to what APRA was aiming for, and instead encourage excessive compensation and reduce the independence of Boards.

Our focus is on Active Ownership for better outcomes

Watering down financial objectives will only diminish the focus and expectations of Boards and management of listed companies and not be in the interests of the stakeholders to which the proposed changes are aiming to align.

Should law makers decide that components of STI and LTI become increasingly non-financial by nature, we as shareholders vow to continue to vote against such measures when nominated at company Annual General Meetings.

We believe that Active Ownership, through strong interaction with both Boards and management, will ultimately see better outcomes for all stakeholders. Furthermore, incentive structures are already highly focused on these outcomes.


1The information provided should not be considered a recommendation to purchase or sell any particular security. It should not be assumed that any of the security transactions discussed here were, or will prove to be, profitable.
2Australian Transaction Reports and Analysis Centre
3Source: Damodaran, A 2019, From Shareholder wealth to Stakeholder interests: CEO Capitulation or Empty Doublespeak?, Musings on Markets, accessed October 2019, http://pages.stern.nyu.edu/~adamodar/


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The information provided should not be considered a recommendation to purchase or sell any particular security. It should not be assumed that any of the security transactions discussed here were, or will prove to be, profitable.