HUB24 Invest Voting Policy

Voting Policy

This is the Voting Policy (Policy) of HUB24 Custodial Services Ltd, ABN 94 073 633 664, AFSL 239 122 (HUB24). In this Policy, ‘HUB24’, ‘we’, ‘our’ and ‘us’ have the same meaning. 

This Voting Policy applies to the HUB24 Investor Directed Portfolio Service (IDPS). 

Purpose

This Policy sets out HUB24’s approach to voting in relation to listed securities and other investment products available for investment under the HUB24 IDPS (the Service). This policy only applies to the securities and investment products accessible on the Approved Investment Menu for the Service. These are referred to as Accessible Investments in this document. 

Voting

Clients investing in Accessible Investments offered under the Service are not in principle entitled to vote in meetings or resolutions concerning these investments given they are not the registered owners of the investment. HUB24, as the legal owner, holds these voting rights. Refer to the relevant disclosure documentation for further information. 

HUB24’s approach to proxy voting in respect of Accessible Investments is that we do not vote. This is essentially consistent with the nature of the Service, where the client (normally under the guidance of a licensed financial adviser) has the responsibility for selection of investments. HUB24, as the provider of services, is not in a position to ascertain what the best voting decision would be for individual investors. 

HUB24 does not offer voting rights as a matter of course, and we do not proactively make information about impending meetings or resolutions in relation to Accessible Investments available to our clients. However, there are limited circumstances in which we may vote: 

1. Where voting is required in respect of an event concerning an Accessible Investment that forms part of a managed portfolio offered under the Service. In this case, and if the manager of the managed portfolio provides detailed and clear written instructions as to when and how to vote, and these instructions are provided to us on or before a time not less than three Business Days⁽¹⁾ before the closing time to submit the votes, we will endeavour to follow those instructions. 

2. Where voting is required in respect of an event concerning an Accessible Investment that does not form part of a managed portfolio, and a client (through his or her adviser in the case of a client not classified as a wholesale client) has requested, in writing, the ability to submit his or her votes in respect of the event. In this case, and if the client (or adviser, as the case may be) provides detailed and clear written instructions as to when and how to vote, and these instructions are provided to us on or before a time not less than three Business Days⁽¹⁾ before the closing time to submit the votes, we will endeavour to follow those instructions. 

^{(1) Business Days is defined in the most recent copy of the HUB24 Invest IDPS Guide (including any branded versions of the HUB24 Invest IDPS Guide) which is available to you, free of charge, via InvestorHUB, from your adviser or by contacting the HUB24 Client Services Team on 1300 854 994.}

Limitations

Notwithstanding Clause 2 of this Policy, further limitations to these rights of voting apply. 

1. HUB24 does not permit a client, a client’s adviser, or a manager of a managed portfolio to act as a corporate representative for HUB24. We simply accept voting instructions from them, as described in Clause 2, and we will attempt to lodge them via proxy voting if received in the manner and in the timeframes described in that clause. 

2. HUB24 does not accept any liability for acting on client’s, adviser’s or manager’s instructions in relation to this voting, including in cases when such instructions contravene the relevant law and/or regulations, or for failing to lodge proxy voting instructions due to circumstances beyond our control (for example, limitations in our own voting rights imposed by the Service custodians, or application of more restrictive constraints for lodgement of instructions imposed on us such as a shorter time needed to lodge the instruction than that specified in this document). 

3. HUB24 does not accept standing instructions in relation to future meetings, resolutions or any other event that requires voting. Instructions, in order to be executed, will need to be supplied for each voting event as it arises. 

4. HUB24’s Accessible Investments include pooled vehicles with their own trustee and/or responsible entity which acts in relation to interests held by the vehicle. In this case HUB24 cannot issue instructions regarding voting for investments made by the pooled vehicle. 

5. HUB24 does not vote, nor does it permit voting, under any circumstances, in relation to holdings in HUB24 Limited. 

Further information regarding this policy is available on request. Please direct your request for information to admin@hub24.com.au. 

Dated: 31 May 2014