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IMPORTANT INFORMATION

You are about to enter a website for professional/institutional investors and the information contained herein is not suitable for retail investors. Private/retail investors should not proceed any further.

By clicking “Accept” you expressly acknowledge and confirm that you are accessing this site for the purposes of acquiring information as a professional/institutional investor and accept the Terms of Use.

  • TERMS OF USE

    Your access to and use of the web sites (“Services”) of Wellington Management are conditioned on your acceptance of and compliance with these Terms of Use (“Terms”). By accessing or using the Services, you agree to be bound by these Terms. If you are accepting these Terms and using the Services on behalf of a company, organization, government, or other legal entity, you represent and warrant that you are authorized to do so. You may use the Services only in compliance with these Terms and all applicable local, state, national, and international laws, rules, and regulations.

    Ownership
    All materials on this web site are owned or licensed by Wellington Management and/or its third-party providers and are protected by US and international intellectual property laws.  Unless otherwise indicated, all service marks, trademarks, and logos appearing on this web site are the exclusive property of Wellington Management. The information, materials, and other content of this web site may not be copied, displayed, distributed, downloaded, licensed, modified, published, reposted, reproduced, reused, sold, transmitted, used to create a derivative work, or otherwise used for public or commercial purposes without the express written consent of Wellington Management.

    Products and services
    The information, materials, products, and services on this web site are current at the time of writing and are subject to change. Not all products and services are available in all geographic areas. Your eligibility for particular products or services is subject to determination by and the approval of Wellington Management. No solicitation is made by Wellington Management to any person to use any information, materials, products, or services in any jurisdiction where the provision of such information, materials, products, and services is prohibited by law.

    The information on this web site or in any communication containing a link to this web site is not intended to constitute investment advice or an offer to sell, or the solicitation of an offer to purchase shares or other securities.

    Investment products and services are available through Wellington Management. Investment products and services are not FDIC-insured, are not deposits or obligations of, or guaranteed by, any bank, and involve investment risks, including the possible loss of the principal amount invested. Investors should always obtain and read an up-to-date investment services description or prospectus before deciding whether to appoint an investment manager or invest in a fund.

    International use
    Wellington Management makes no warranties that materials on this web site are appropriate for use in countries other than the US. Because the web site may be accessed internationally, you agree to comply with all local laws, rules, and regulations including, without limitation, all laws, rules and regulations in effect in the country in which you reside and the country from which you access the web site. The information on this web site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or which would subject Wellington Management or its affiliates to any registration requirement within such jurisdiction or country.

    No warranty
    Wellington Management does not warrant the accuracy, adequacy, completeness, or timeliness of the information, materials, products, and services on this web site or the error-free use of this web site. All information, materials, products, and services are “as is” and “as available.” No warranty of any kind, express or implied, including but not limited to the warranties of non-infringement of third-party rights, title, merchantability, fitness for a particular purpose, and freedom from computer virus is given in conjunction with the information, materials, products, and services. Any views expressed herein are those of the author(s), are based on available information, and are subject to change without notice. Individual portfolio management teams may hold different views and may make different investment decisions for different clients. Wellington Management does not warrant that the web site will meet your needs. You agree to assume the entire risk as to your use of the web site.

    Limitation of liability
    In no event shall Wellington Management be liable for any damages, losses, or liabilities including without limitation, direct or indirect, special incidental, consequential damages, losses, or liabilities, in connection with your use of this web site or your reliance on or use or inability to use the information, materials, products, and services on this web site, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus, or line or system failure, even if Wellington Management is advised of the possibility of such damages, losses, or expenses.

    YOU UNDERSTAND AND AGREE THAT YOUR USE OF THIS WEB SITE IS PREDICATED UPON YOUR WAIVER OF ANY RIGHT TO SUE WELLINGTON MANAGEMENT OR ITS AFFILIATES DIRECTLY OR TO PARTICIPATE IN A SUIT FOR ANY LOSSES OR DAMAGES RESULTING FROM YOUR USE OF THIS WEB SITE.

    Indemnification
    As a condition of your use of the Services, you agree to indemnify and hold Wellington Management, its affiliates, and its and their respective partners, directors, employees, and agents harmless from and against any and all claims, losses, liability, costs, and expenses (including but not limited to attorneys’ fees) arising from your use of the web site or from your violation of these Terms.

    Hyperlinks
    Your use of the hyperlinks on this web site to other Internet web sites is at your own risk. Wellington Management is not responsible for the content or accuracy of third-party web sites hyperlinked from this web site, nor does it guarantee the products or services offered on third-party web sites. You should review the privacy statements of a web site before you provide any personal or confidential information.

    Web site security and restrictions on use
    As a condition to your use of Services, you agree that you will not, and you will not take any action intended to:  (i) access data that is not intended for you; (ii) invade the privacy of, obtain the identity of, or obtain any personal information about any other user of this web site; (iii) probe, scan, or test the vulnerability of this web site or Wellington Management’s network or breach security or authentication measures without proper authorization; (iv) attempt to interfere with service to any user, host, or network or otherwise attempt to disrupt our business; or (v) send unsolicited mail, including promotions and/or advertising of products and services. Unauthorized use of the web site or Services, including but not limited to unauthorized entry into Wellington Management’s systems, misuse of passwords, or misuse of any information posted to a web site, is strictly prohibited. Portions of the web site are designated for password access only as indicated by a lock icon. In these instances, if you do not have an authorized password, no access is permitted.

    Confidentiality and password security
    Certain parts of this web site may be protected by passwords or require a login. You are responsible for maintaining the confidentiality of any user names, passwords, security questions, and answers. All information available through the privileged area of the site is confidential and proprietary to us. This includes all investment information and results, offering materials, financial statements, and other information provided through this part of the site.

    You will use your best efforts to keep all this information strictly confidential. You will not disclose any of this information to any person or use it for any purpose other than those strictly permitted by us, in writing.

    Severability
    If any provision of these Terms is deemed unlawful, void, or for any reason unenforceable, then that provision will be reformed only to the extent necessary to make it enforceable, and it will be deemed severable from these Terms and will not affect the validity and enforceability of the remaining provisions.

    Applicable law
    These Terms and any action related thereto are governed by Massachusetts law and applicable US federal law. Any dispute relating to the above shall be resolved solely in the state or federal courts located in Massachusetts.

    Privacy statement
    Wellington Management respects the privacy of its clients and the confidentiality of information pertaining to its clients.

    Information we collect
    We may collect non-public personal information about you on RFPs, questionnaires, and other forms we receive from you, as well as from personal contacts such as correspondence, e-mail, telephone calls, or meetings. We may also receive information about you from third parties, such as your accountants, lawyers, financial consultants, and/or other service providers.

    It also is possible to receive information from web browsers and apps regarding certain of your online activities using cookies, or other common tracking technologies.  Some web browsers and other applications may provide a Do Not Track (DNT) preference setting.  When a user turns on a tracking preference, the browser or application may send a message to web sites requesting that they do or do not track the user. At this time, we take no actions in response to any DNT settings or messages.

    Information sharing
    Wellington Management seeks to provide seamless service to all clients. To facilitate that process, information regarding client accounts is shared broadly between affiliates within the Wellington Management group of companies. For example, an affiliate may share information with other affiliates in order to facilitate portfolio management or provide client liaison services to a particular client. Client information may be used by Wellington Management in order to identify potential client needs for additional investment management services.

    Wellington Management generally does not share non-public client information with unaffiliated third parties, except as necessary to perform the investment management services it has been hired to provide. For example, Wellington Management may share non-public client information with brokers and custodian banks in order to buy and sell securities and record those purchases and sales accurately. As a general rule, Wellington Management does not engage in joint marketing arrangements with unaffiliated third parties that involve the sharing of non-public information regarding Wellington Management’s clients. Wellington Management does not provide client information to unaffiliated third parties for their own marketing purposes.

    Wellington Management does not disclose your information except as required or permitted by law. In the event that Wellington Management is involved in a merger, acquisition, reorganization or sale of assets, or bankruptcy, your information may be transferred or sold as part of that transaction.

    Security policies
    We use technical, administrative, and procedural measures in an attempt to safeguard your personal and other information from unauthorized access or use. No such measure is ever 100% effective though, so we do not guarantee that your personal and other information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such information. Users are responsible for maintaining the secrecy of their own passwords. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us by contacting your relationship team member.

    Transfer of data to other countries
    Any information you provide to Wellington Management through use of the Site may be stored and processed, transferred between, and accessed from the US and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, Wellington Management will handle your personal information in accordance with this Privacy Statement regardless of where your personal information is stored/accessed.

    Changes to Terms of use

    We may revise these Terms from time to time; the most current version will always be at https://www.wellington.com/terms-use. By continuing to access or use the Services after those revisions become effective, you agree to be bound by the revised Terms.

    Effective as of  17 January 2014

I ACCEPT I DO NOT ACCEPT
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Website Terms of use:

You are about to enter a website for professional investors (as defined in the Markets and Financial Instruments Directive 2014/65/EU as amended or updated (“MiFID”)) including financial advisers and/or intermediaries and the information contained herein is not suitable for retail clients. Any person unable to accept these terms and conditions should not proceed any further. Before making any investment decision, you shall read carefully the offering documents of each Fund.

The use of Wellingtonfunds.com (this “Website”) is subject to the following terms and conditions (the “Terms”). After you have read and understood these Terms, you may click “Accept” to confirm that you agree to the Terms.

By clicking “Accept” you:

(i) expressly acknowledge that you have read and understood the Terms and agree to abide by them;

(ii) represent and warrant that the jurisdiction you have selected is the applicable jurisdiction for the intended investment activities, and that you are not resident in the United States of America and are not a U.S. Person;

(iii) confirm that you are accessing this Website in compliance with the laws and regulations of the jurisdiction you have selected, and all other applicable laws, rules and regulations;

(iv) represent and warrant, if applicable, that you are authorised to accept these Terms and use or access (or attempt to use or access) this Website on behalf of your employer, your client, or both, and that in doing so you are acting within the scope of your duties and, at all times, on behalf of your employer, your client or both; and

(v) hereby represent and warrant that you are not a private investor or retail client as categorised under MiFID) and that you shall not in any circumstances use or rely on any information displayed on this Website for your own personal investment use.

If you do not agree with these Terms you must refrain from using this Website.

In these Terms, references to “you” and “your” are references to any person using or accessing (or attempting to use or access) this Website or, as the context requires, the legal entity on whose behalf a user uses or accesses (or attempts to use or access) this Website. References to “Wellington Management”, “we” and “us” are references to Wellington Management International Limited.

By entering this Website, you acknowledge and agree to be bound by each of the Terms, together with any additional terms and conditions that apply to individual webpages, documents or other attachments contained within this Website (together, the “Conditions of Use”). If there are any Conditions of Use that you do not understand or agree with, you must leave this Website or the webpage in question (as applicable) immediately and delete immediately from the memory of your computer all documents from this Website.

  1. About this Website: The information on this Website is issued and communicated by Wellington Management International Limited (“Wellington Management,” “we” and “us”), which is authorised and regulated by the Financial Conduct Authority of the United Kingdom. This Website contains information about various umbrella funds (each an “Umbrella Fund” and together the “Umbrella Funds”) and their sub-funds (the “Funds”) which have been registered, or otherwise notified, for public distribution and marketing in the jurisdiction you have selected.

    Please note that the fact of such registration or notification does not mean that any regulator (including the Commission de Surveillance de Secteur Financier (CSSF) or any national regulator of your jurisdiction) has determined that the Funds are suitable for all or any investors. The Funds referred to on this Website may not be suitable investments for you and you should therefore seek professional investment advice before making a decision to invest in any of the Funds.

    Before making any investment decision read carefully the offering documents of each Fund.

  2. Access to this Website: In order to access this Website, you have been asked to select the jurisdiction which is applicable for the intended investment activities. Your selection will be used to determine the information that you will be able to access on this Website. You hereby represent and warrant to Wellington Management that the information that you have provided is true, accurate and complete and you undertake to notify us of any change to such information. Failure to provide us with accurate information will be treated as a material breach of these Terms. Certain Funds may not be available in all geographical locations and so information about certain Funds may not be available to all users of this Website. You must not attempt to gain access to areas of this Website other than those made available to users in the jurisdiction you selected. If the jurisdiction you should select changes, you must access this Website selecting your new jurisdiction. You should be aware that this may result in you not being able to access (i) information in relation to the same Funds as previously, or (ii) any information at all. Please note that the fact of selecting a jurisdiction does not mean that all or any of the Funds in relation to which information is made available, have been deemed suitable for you.

    When using this Website you must comply with all applicable local, national and international laws and regulations including those related to data privacy, international communications and exportation of technical or personal data. It may be unlawful to access or download the information contained on this Website in certain countries and the Umbrella Funds, Wellington Management and its affiliates disclaim all responsibility if you access or download any information from this Website in breach of any law or regulation of the United Kingdom, the jurisdiction in which you are residing or domiciled or the jurisdiction from which you access the Website.

    If you are acting as a financial adviser or intermediary, you agree to access this Website only for the purposes for which you are permitted to do so under applicable law. If you are acting as a financial adviser or intermediary and provide services to clients categorised as retail clients under MiFID, you agree that you will not share with or provide to your retail clients any information available on this Website that has not been approved for retail use and is not otherwise suitable for your retail clients.

    Wellington Management reserves the right to suspend or withdraw access to any page(s) included on this Website without notice at any time and accepts no liability if, for any reason, these pages are unavailable at any time or for any period.

  3. No Market Timing: You agree not to engage in any “market timing” practices with respect to your investment in any Fund and shall take all reasonable steps to ensure that no user authorised to access this Website on your behalf engages in any such market timing practices. For these purposes, “market timing” shall include engaging in any trading strategy with the intention of taking advantage of short term changes in market prices including (without limitation) by engaging in: (i) excessive trading, (ii) late trading or (iii) market abuse.

  4. U.S. Persons: Interests in the Funds are not being offered, and will not be sold, within the United States or to, or for the account or benefit of, any U.S. Person. The term U.S. Person shall have the meaning given to it in Regulation S under the United States Securities Act of 1933, as amended, and includes, among other things, U.S. residents and U.S. corporations and partnerships.

  5. Selling Restrictions: The distribution of the information and documentation on this Website may be restricted by law in certain countries. This Website, and the information and documentation on it, are not addressed to any person resident in the territory of any jurisdiction where such distribution would be contrary to local law or regulation. Not all the Funds in relation to which information is available on this Website are available in all geographical locations and so not all areas of this Website will be accessible to all users. The Funds are not available, and offering materials relating to them will not be distributed, to any person resident in any jurisdiction where such distribution would be contrary to local law or regulation.

  6. No Investment Advice: The information on this Website is provided for information only and on the basis that you will make your own investment decisions.

    Nothing contained on this Website constitutes, and nothing on this Website should be construed as, investment advice or a recommendation to buy, sell, hold or otherwise transact in any investment including interests in the Funds. It is strongly recommended that you seek professional investment advice before making any investment decision.

    Unless agreed separately in writing with a client, Wellington Management and its affiliates neither provide investment advice to nor receive and transmit orders from investors in the Funds nor do they carry on any other activities with or for such investors that constitute “investment services” or “ancillary services” for the purposes of MiFID.

    You should consider whether an investment fits your investment objectives, particular needs and financial situation before making any investment decision. You should also inform yourself as to (a) the possible tax consequences, (b) the legal requirements and (c) any foreign exchange restrictions or exchange control requirements which you might encounter under the laws of the countries of your citizenship, residence or domicile and which might be relevant to the subscription, holding, transfer or disposal of interests in the Funds.

  7. Past Performance; Forecast; Simulation: To the extent that this Website contains any information regarding the past performance and/or forecast of the Funds, such information is not a reliable indicator of future performance of these Funds and should not be relied upon as a basis for an investment decision.

    To the extent that this Website contains any information regarding simulated past performance, such information is not a reliable indicator of future performance and should not be relied on as the basis for an investment decision. Investment results for each Fund may vary.

    The value of investments and the income from them can go down as well as up and investors may not get back the amount originally invested and may lose all of their investment. The value of investments in the Funds may be affected by the price of underlying investments. Exchange rate changes may cause the value of overseas investments to rise or fall.

  8. Price Information: All prices or values may not reflect actual prices or values that would be available in the market at the time provided or at the time you may decide to purchase or sell an interest in a particular Fund.

  9. Risk Warnings: There are significant risks associated with an investment in any of the Funds. Investment in the Funds is intended only for those investors who can accept the risks associated with such an investment (including the risk of a complete loss of investment).You should ensure that you have fully understood such risks before taking any decision to invest.

    Investments in the Funds are neither insured nor guaranteed by any investor compensation scheme and are not deposits or obligations of, or guaranteed by, any entity within the Wellington Management group.

    These Terms do not represent a complete statement of the risk factors associated with an investment in the Funds. The offering documents for each Fund contain risk warnings which are specific to the relevant Fund. You should consider these risk warnings carefully and take appropriate investment advice before taking any decision to invest.

  10. Offering Documents: The terms of any investment in a Fund are governed by the documents establishing such terms. An application for interests in any of the Funds should only be made having fully and carefully read the offering documents, which are the relevant offering memorandum, the latest financial reports and any other offering documents for the relevant Fund which are available on this Website and upon request from the fund representative in your jurisdiction and specified in the offering memorandum for the relevant Fund.

    It is your responsibility to use the offering documents and by making an application to invest in a Fund you will represent that you have read the offering memorandum for the relevant Fund, the appropriate key investor information document for the Fund and any other applicable offering document and will agree to be bound by its contents.

  11. Information on this Website: This Website, and the information on it, are provided for information purposes only and do not constitute an invitation, offer or solicitation to engage in any investment activity including to buy, hold or sell any investment including any interests in the Funds.

    The information on this Website is provided in good faith and reasonable care has been taken to ensure that such information is accurate, current and fit for its intended purpose. To the extent that any information on this Website relates to a third party, this information has been provided by that third party and is the sole responsibility of such third party and, as such, Wellington Management and its affiliates accept no liability for such information.[ No representation or warranty of any kind regarding the accuracy, adequacy, validity, completeness or timeliness of the information on this Website or the error-free use of this Website is given and, to the extent permitted by applicable laws, no liability is accepted for the accuracy or completeness of such information. No warranty of any kind, express or implied, including but not limited to the warranties of non-infringement of third-party rights, title, merchantability, fitness for a particular purpose, and freedom from computer virus is given in conjunction with the information, materials, products, and services on the Website. Any views expressed herein are those of the author(s), are based on available information, and are subject to change without notice. Individual portfolio management teams may hold different views and may make different investment decisions for different clients. Wellington Management does not warrant that the Website will meet your needs. You agree to assume the entire risk as to your use of the Website. Any person who acts upon, or changes his investment position in reliance on information contained on this Website, does so entirely at his own risk. In the event of any inconsistency between the information on this Website and the terms of the relevant offering documents, the terms of the offering document shall prevail.

    All content on the Website is subject to modification from time to time without notice save for any mandatory disclosure requirements. Please contact Wellington Management (using the details in the “Contact Us” section below) for further information regarding the validity of any information contained on this Website. This Website and most of the documentation contained within it is provided in the English language and you represent and warrant that you understand the English language.

    The Website is limited to funds and sub-funds (and related information and documents) which have been authorised for sale.

  12. Conflicts of Interest: Wellington Management, its affiliates and their directors, officers, employees or clients may have or have had interests or long or short positions in any investment product or other financial instruments underlying any investment product referred to on this Website and may at any time make purchases and/or sales in them as principal or agent. In addition, Wellington Management and/or its affiliates may act or have acted as market maker in any investment product, or financial instruments underlying such investment product or entered into an arrangement to hedge the market risk associated with the investment products. The Wellington Management group has conflicts of interest policies in place which specify the procedures that they follow and the measures that they have adopted in order to avoid such conflicts or to manage such conflicts in a way that ensures fair treatment for clients.

  13. Monetary Benefits: You agree that we may, to the extent permitted by applicable laws and regulations, share charges or commission with affiliates of Wellington Management or other third parties, or receive remuneration from them, in respect of transactions you carry out in relation to the Funds described on this Website. Where relevant, we may disclose such arrangements to you. Details of any such arrangements are available on request.

  14. Liability: No warranty is given that the contents of this Website are compatible with all computer systems or browsers or that this Website shall be available on an uninterrupted basis.

    The internet is not a completely reliable transmission medium and none of the Umbrella Funds, Wellington Management or any of its affiliates accept any liability for any data transmission errors such as data loss or damage or alteration of any kind or for the security or confidentiality of information transmitted across the internet to or from the Umbrella Funds, Wellington Management or any of its affiliates. Any such transmission of information is entirely at your own risk and any material downloaded from this Website is downloaded at your own risk.

    The information on this Website is provided “as is” and “as available”. To the extent permitted by law, no guarantee or representation, express or implied, is made as to the accuracy, validity, timeliness, completeness or continued availability of any information made available on the Website The Umbrella Funds, Wellington Management, its affiliates and each of their directors, officers, employees and/or agents expressly exclude all conditions, warranties, representations, and other terms which might otherwise be implied by statute, common law or the law of equity to the fullest extent permitted by applicable law or regulation.

    In no event will the Umbrella Funds, Wellington Management, or any of its affiliates be liable to any person for any direct, indirect, special or consequential damages, losses or liabilities arising out of any use of, or inability to use, this Website or the information contained on it including, without limitation, lost profits, business interruption, any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus, line or system failure, loss of programs or data on your equipment or otherwise, even if the Umbrella Funds, Wellington Management or its affiliates is expressly advised of the possibility or likelihood of such damages, losses or liabilities, unless such damages, losses or liabilities are due to the Umbrella Funds’, Wellington Management’s or its affiliates’ negligence, willful default, fraud or material breach of the Umbrella Funds’, Wellington Management’s or its affiliates’ obligations under applicable law or regulation.

    This does not affect the liability of the Umbrella Funds, Wellington Management, or its affiliates for any loss or damage which cannot be excluded or limited under applicable law.

  15. Indemnification: As a condition of your use of the Website, you agree to indemnify and hold the Umbrella Funds, Wellington Management, and its affiliates, and their respective partners, directors, employees, and agents harmless from and against any and all claims, losses, liability, costs, and expenses (including but not limited to legal fees) arising from your use of the Website or from your violation of these Terms unless such claims, losses, liability, costs or expenses are due to the Umbrella Funds’, Wellington Management’s or its affiliates’ negligence, willful default, fraud or material breach of the Umbrella Funds’, Wellington Management’s or its affiliates’ obligations under applicable law or regulation.

  16. Intellectual Property: The entire content of this Website is subject to copyright with all rights reserved. All materials on this Website are owned or licensed by the Umbrella Funds, Wellington Management, its affiliates and/or its third-party providers and are protected by UK and international intellectual property laws. Unless otherwise indicated, all service marks, trademarks, and logos appearing on this Website are the exclusive property of the Wellington Management group. You may not copy, display, distribute, download, license, modify, publish, repost, reproduce, sell, transmit, and use to create a derivative work, or otherwise use for public or commercial purposes the content of this Website without the prior written permission of Wellington Management.

  17. Privacy: Please see our privacy policy which is contained on this Website for information about how the Wellington Management group protects your personal data, including personal data collected through this Website. You will be asked to agree to the terms of our privacy policy when selecting your relevant jurisdiction.

  18. Cookies: When you visit this Website, a Wellington Management group company server will record your IP address together with the date, time, page visited and duration of your visit. Please note that the Wellington Management group uses cookies on this section of the Website. Cookies are small pieces of software that are issued to your computer or device and that store and sometimes track information about your use of the site. Cookies on this Website may collect a unique identifier, user preferences and profile information and membership information from which it is possible to identify individual users. The Wellington Management group also uses cookies to collect general usage and volume statistical information that does not include personally identifiable information. Some cookies may remain on the user’s computer after they leave this Website (these are known as persistent cookies). For more information about cookies including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org or http://youronlinechoices.eu.

    By using this Website, you agree that the Wellington Management group can place cookies on your device which collect the data and for the purposes described above and as further detailed in the Cookie Policy. If you delete cookies relating to this Website, we will not remember things about you, you will be treated as a first-time visitor the next time you visit this Website and we will not be able to tailor your experience of this Website.

    The Wellington Management group has engaged one or more third party service providers to track and analyze usage and volume statistical information from visitors to this Website. The service provider(s) set cookies on behalf of the Wellington Management group. The Wellington Management group may re-associate the information provided by the technologies directly above with other personal information we hold about you. By using this Website, you agree that third parties can place cookies on your device as described above.

  19. Your use of this Website: You must not use this Website (or permit or procure others to use it) as follows:

    • for any unlawful, improper or illegal purpose or activity;
    • to communicate or receive information that is obscene, indecent, pornographic, sadistic, cruel, or racist in content, of a sexually explicit or graphic nature, which promotes or incites discrimination, hatred or racism or which might be legally actionable for any reason;
    • in a manner intended to threaten, harass, or intimidate;
    • to violate Wellington Management’s or any third party’s copyright, trademark, proprietary or other intellectual property rights;
    • to damage Wellington Management’s name or reputation or that of Wellington Management’s affiliated companies or any third parties;
    • to impersonate any of Wellington Management’s employees or other person or use a false name while using this Website or implying an association with Wellington Management;
    • to penetrate Wellington Management’s security measures or other entities’ systems (“hacking”);
    • to transmit unsolicited voluminous emails (for example, spamming) or to intercept, interfere with or redirect email intended for others using this Website;
    • to generate excessive amounts of internet traffic, to interfere with Wellington Management’s network or other’s use of this Website or to engage in activities designed to, or having the effect of, degrading or denying service to other users of this Website or others;
    • to introduce viruses, worms, harmful code and/or Trojan horses onto the internet or into this Website or any other entity’s systems and it is your responsibility to ensure that whatever you download or select for your use from this Website is free from such items;
    • to post or transmit information that is defamatory, fraudulent or deceptive including, but not limited to, scams such as “make-money-fast” schemes or “pyramid/chain” letters; and/or
    • to transmit confidential or proprietary information, except solely at your own risk.
  20. Linked Websites: Links to websites operated by third parties are provided for information only and do not constitute any form of advice, endorsement or recommendation of such websites or the material on them. Wellington Management accepts no responsibility for information contained on any other sites which can be accessed by hypertext link from this Website or for these sites not being available at all times. Any use that you make of such websites and information is at your own risk. Please note that when you click on any external site hypertext link you will leave this Website. You should review the privacy statements of such websites before you provide any personal or confidential information.

  21. Website Security and Restrictions on Use: As a condition to your use of this Website, you agree that you will not, and you will not take any action intended to: (i) access data that is not intended for you; (ii) invade the privacy of, obtain the identity of, or obtain any personal information about any other user of this Website; (iii) probe, scan, or test the vulnerability of this Website or Wellington Management’s network or breach security or authentication measures without proper authorisation; (iv) attempt to interfere with service to any user, host, or network or otherwise attempt to disrupt our business; or (v) send unsolicited mail, including promotions and/or advertising of products and services. Unauthorised use of the Website, including but not limited to unauthorised entry into Wellington Management’s systems or misuse of any information posted to a web site, is strictly prohibited.

  22. Website Security and Restrictions on Use: As a condition to your use of this Website, you agree that you will not, and you will not take any action intended to: (i) access data that is not intended for you; (ii) invade the privacy of, obtain the identity of, or obtain any personal information about any other user of this Website; (iii) probe, scan, or test the vulnerability of this Website or Wellington Management’s network or breach security or authentication measures without proper authorisation; (iv) attempt to interfere with service to any user, host, or network or otherwise attempt to disrupt our business; or (v) send unsolicited mail, including promotions and/or advertising of products and services. Unauthorised use of the Website, including but not limited to unauthorised entry into Wellington Management’s systems or misuse of any information posted to a web site, is strictly prohibited.

  23. Third Parties: The Umbrella Funds, Wellington Management, and its affiliates shall have the benefit of the rights conferred on them by these Terms but otherwise no person who is not a party to these Terms may enforce its terms under the Contracts (Rights of Third Parties) Act 1999.

  24. Applicable Law: These Terms and any non-contractual obligations arising from or connected with them shall be governed by, and these Terms shall be construed in accordance with, the laws of England and Wales.

  25. Jurisdiction: You agree that the English courts shall have exclusive jurisdiction in relation to any legal action or proceedings arising out of or in connection with these Terms (whether arising out of or in connection with contractual or non-contractual obligations) (“Proceedings”) and waive any objection to Proceedings in such courts on the grounds of venue or on the grounds that Proceedings have been brought in an inappropriate forum. You further agree that this paragraph operates for the benefit of the Umbrella Funds, or Wellington Management and accordingly the Umbrella Funds, or Wellington Management shall be entitled to take Proceedings in any other court or courts having jurisdiction.

  26. Specific information for Spanish investors: Wellington Management International Limited is registered in the Spanish Securities Market Commission – Comision Nacional del Mercado de Valores (“CNMV”) with number 874, to provide investment services on a cross border basis. The Funds are registered in the CNMV for sale to professional investors and registration numbers may be found on the Website. The distributors in Spain of Funds registered in the corresponding CNMV Registry must provide to each unit-holder or shareholder, prior to subscribing units or shares in the Funds, a copy of the simplified prospectus or the document substituting it ( when applicable) and a copy of the latest published annual report and accounts. Delivery of these documents is mandatory and cannot be waived by the unit-holder or the shareholder. In addition, an updated copy of other official documentation of the Funds must be provided upon request. In any event at least one of the distributors will make available by electronic means all the documents, as well as the net asset values corresponding to the share or units marketed in Spain.

  27. About Wellington Management International Limited and the Umbrella Funds. Wellington Management International Limited is authorised and regulated by the Financial Conduct Authority of the United Kingdom and is entered on the register maintained by the Financial Conduct Authority and the Prudential Regulation Authority(Reference number: 208573). Its registered office is at Cardinal Place, 80 Victoria Street, London SW1E 5JL, United Kingdom and its VAT number is GB420309205. Wellington Management International Limited is an appointed distributor to the Funds.

    Wellington Management Funds (Luxembourg) II is an open-ended unincorporated mutual investment fund (fonds commun de placement) and is governed by the Luxembourg Law of 13th February 2007 on specialised investment funds, as amended from time to time, and qualifies as an AIF.

    Wellington Management Funds (Luxembourg) II SICAV is an open-ended investment company with variable capital (societe d’investestissement a capital variable) and is governed by Luxembourg Law of 13th February 2007 on specialised investment funds, as amended from time to time, and qualifies as an AIF.

    Wellington Luxembourg S.à r.l. is the appointed management company of Wellington Management Funds (Luxembourg) and alternative investment fund manager of Wellington Management Funds (Luxembourg) II and Wellington Management Funds (Luxembourg) II SICAV. Wellington Luxembourg S.à r.l. is a société à responsabilité limitée registered in Luxembourg and authorised by the Commission de Surveillance du Secteur Financier (the CSSF) as a management company authorised under chapter 15 of the Luxembourg law of 17 December 2010 on undertakings for collective investment, as amended. Wellington Luxembourg S.à r.l.’s registered address is at 33, Avenue de la Liberté, L-1931 Luxembourg.

  28. Contact Us: If you have any enquiries in relation to this Website or the information on it, please contact Wellington at infofunds@wellington.com.

Effective as of 21 August 2019

You are about to enter a website for qualified and professional investors including financial advisors / intermediaries and the information contained herein is not suitable for retail investors. Any person unable to accept these terms and conditions should not proceed any further.

 The use of Wellingtonfunds.com (this “Website”) is subject to the following terms and conditions (the “Terms”). After you have read and understood these Terms, you may click “Accept” to confirm that you agree to the Terms.

 By clicking “Accept” you:

(i) expressly acknowledge that you have read and understood the Terms and agree to abide by them;

(ii) represent and warrant that the jurisdiction you have selected is the applicable jurisdiction for the intended investment activities, and that you are not resident in the United States of America and are not a U.S. Person;

(iii) confirm that you are accessing this Website in compliance with the laws and regulations of the jurisdiction you have selected, and all other applicable laws, rules and regulations;

(iv) represent and warrant, if applicable, that you are authorised to accept these Terms and use or access (or attempt to use or access) this Website on behalf of your employer, your client, or both, and that in doing so you are acting within the scope of your duties and, at all times, on behalf of your employer, your client or both; and

(v) hereby represent and warrant that you are not a private investor or retail client (as defined in the Markets and Financial Instruments Directive 2014/65/EC as amended or updated (“MiFID”)) and that you shall not in any circumstances use or rely on any information displayed on this Website for your own personal investment use. 

If you do not agree with these Terms you must refrain from using this Website.

In these Terms, references to “you” and “your” are references to any person using or accessing (or attempting to use or access) this Website or, as the context requires, the legal entity on whose behalf a user uses or accesses (or attempts to use or access) this Website. References to “Wellington Management”, “we” and “us” are references to Wellington Management Switzerland GmbH. 

By entering this Website, you acknowledge and agree to be bound by each of the following terms and conditions, together with any additional terms and conditions that apply to individual webpages, documents or other attachments contained within this Website (together, the “Conditions of Use”). If there are any Conditions of Use that you do not understand or agree with, you must leave this Website or the webpage in question (as applicable) immediately and delete immediately from the memory of your computer all documents from this Website.

  1. About this Website: The information on this Website is issued and communicated by Wellington Management Switzerland GmbH (“Wellington Management,” we” and “us”), which is registered at the commercial register of the canton of Zurich with number CH-020.4.050.857-7 and which holds a distribution license from the Swiss Financial Market Supervisory Authority (“FINMA”), as a fund distributor. This Website contains information about various umbrella funds (each an “Umbrella Fund” and together the “Umbrella Funds”) and their sub-funds (the “Funds”) which have been registered, or otherwise notified, for public distribution and marketing in the jurisdiction you have selected. 

    Please note that the fact of such registration or notification does not mean that any regulator (including the Swiss Financial Market Supervisory Authority, the Commission de Surveillance de Secteur Financier (CSSF) or any national regulator of your jurisdiction) has determined that the Funds are suitable for all or any investors. The Funds referred to on this Website may not be suitable investments for you and you should therefore seek professional investment advice before making a decision to invest in any of the Funds.

    Before making any investment decision read carefully the offering documents of each Fund.

  2. Access to this Website: In order to access this Website, you have been asked to select the jurisdiction which is applicable for the intended investment activities. Your selection will be used to determine the information that you will be able to access on this Website. You hereby represent and warrant to Wellington Management that the information that you have provided is true, accurate and complete and you undertake to notify us of any change to such information. Failure to provide us with accurate information will be treated as a material breach of these Terms. Certain Funds may not be available in all geographical locations and so information about certain Funds may not be available to all users of this Website. You must not attempt to gain access to areas of this Website other than those made available to users in the jurisdiction you selected. If the jurisdiction you should select changes, you must access this Website selecting your new jurisdiction. You should be aware that this may result in you not being able to access (i) information in relation to the same Funds as previously, or (ii) any information at all. Please note that the fact of selecting a jurisdiction does not mean that all or any of the Funds in relation to which information is made available, have been deemed suitable for you. 

    When using this Website you must comply with all applicable local, national and international laws and regulations including those related to data privacy, international communications and exportation of technical or personal data. It may be unlawful to access or download the information contained on this Website in certain countries and the Umbrella Funds, Wellington Management and its affiliates disclaim all responsibility if you access or download any information from this Website in breach of any law or regulation of the United Kingdom, the jurisdiction in which you are residing or domiciled or the jurisdiction from which you access the Website. 

    If you are acting as a financial adviser or intermediary, you agree to access this Website only for the purposes for which you are permitted to do so under applicable law. If you are acting as a financial adviser or intermediary and provide services to clients categorised as retail clients under the MiFID, you agree that you will not share with or provide to your retail clients any information available on this Website that has not been approved for retail use and is not otherwise suitable for your retail clients. 

    Wellington Management reserves the right to suspend or withdraw access to any page(s) included on this Website without notice at any time and accepts no liability if, for any reason, these pages are unavailable at any time or for any period.

  3. No Market Timing: You agree not to engage in any “market timing” practices with respect to your investment in any Fund and shall take all reasonable steps to ensure that no user authorised to access this Website on your behalf engages in any such market timing practices. For these purposes, “market timing” shall include engaging in any trading strategy with the intention of taking advantage of short term changes in market prices including (without limitation) by engaging in: (i) excessive trading, (ii) late trading or (iii) market abuse.

  4. U.S. Persons: Interests in the Funds are not being offered, and will not be sold, within the United States or to, or for the account or benefit of, any U.S. Person. The term U.S. Person shall have the meaning given to it in Regulation S under the United States Securities Act of 1933, as amended, and includes, among other things, U.S. residents and U.S. corporations and partnerships.

  5. Selling Restrictions: The distribution of the information and documentation on this Website may be restricted by law in certain countries. This Website, and the information and documentation on it, are not addressed to any person resident in the territory of any jurisdiction where such distribution would be contrary to local law or regulation. Not all the Funds in relation to which information is available on this Website are available in all geographical locations and so not all areas of this Website will be accessible to all users. The Funds are not available, and offering materials relating to them will not be distributed, to any person resident in any jurisdiction where such distribution would be contrary to local law or regulation. 

    Certain information and documentation available on the Website relate to Funds, which have not been registered with the FINMA for distribution in or from Switzerland to non-qualified investors in accordance with Articles 119 etseq of the Federal Act on Collective Investment Schemes of 23 June 2006, as amended (“CISA”). Such information and documentation are exclusively directed at qualified investors within the meaning of Article 10 CISA located in Switzerland (“Qualified Investors”). By entering into this website you certify that you are a Qualified Investor and that you have read, understood and accepted the legal terms and conditions summarized hereinafter. Qualified Investors pursuant to Article 10 para 3, 3bis and 3ter CISA are in particular: 1) regulated financial intermediaries, such as banks, securities dealers, fund management companies, asset managers of collective investment schemes as well as central banks, 2) regulated insurance companies, 3) public entities and retirement benefits institutions with professional treasury facilities, 4) companies with professional treasury facilities, and 5) high-net worth individuals, which meet the requirements of Articles 6 and 6a of the Ordinance on Collective Investment Schemes of 22 November 2006, as amended (“CISO”). If you are a high-net worth individual resident in Switzerland, you hereby declare that you meet the requirements provided for by Article 6 CISO and that you have submitted an appropriate written opting-in declaration according to Article 6a CISO to Wellington Management. The Swiss representative and Swiss paying agent of the Funds is BNP Paribas Securities Services, Selnaustrasse 16, 8002 Zurich, Switzerland. The offering memorandum and the latest annual report of the Funds can be obtained free of charge from the Swiss representative of the Funds. In respect of the interests of the Funds distributed in and from Switzerland, the place of performance and jurisdiction is the registered office of the Swiss representative of the Funds.

  6. No Investment Advice: The information on this Website is provided for information only and on the basis that you will make your own investment decisions. 

    Nothing contained on this Website constitutes, and nothing on this Website should be construed as, investment advice or a recommendation to buy, sell, hold or otherwise transact in any investment including interests in the Funds. It is strongly recommended that you seek professional investment advice before making any investment decision.

    The information on this Website does not take account of any investor’s investment objectives, particular needs or financial situation. Investment in the Funds may not be suitable for you. In addition, nothing on this Website shall, or is intended to, constitute financial, legal, accounting or tax advice. 

    Unless agreed separately in writing with a client, Wellington Management and its affiliates neither provide investment advice to, nor receive and transmit orders from, investors in the Funds nor do they carry on any other activities with or for such investors that constitute “investment services” or “ancillary services” for the purposes of MiFID. 

    You should consider whether an investment fits your investment objectives, particular needs and financial situation before making any investment decision. You should also inform yourself as to (a) the possible tax consequences, (b) the legal requirements and (c) any foreign exchange restrictions or exchange control requirements which you might encounter under the laws of the countries of your citizenship, residence or domicile and which might be relevant to the subscription, holding, transfer or disposal of interests in the Funds. 

    Any opinion, article, comment, financial analysis, market forecast, market commentary or other such information which is published on the Website is not binding on Wellington Management or its affiliates nor are they deemed responsible for the opinions or information offered.

  7. Past Performance; Forecast; Simulation: To the extent that this Website contains any information regarding the past performance and/or forecast of the Funds, such information is not a reliable indicator of future performance of these Funds and should not be relied upon as a basis for an investment decision. To the extent that this Website contains any information regarding simulated past performance, such information is not a reliable indicator of future performance and should not be relied on as the basis for an investment decision. Investment results  for each Fund may vary.

    The value of investments and the income from them can go down as well as up and investors may not get back the amount originally invested and may lose all of their investment. The value of investments in the Funds may be affected by the price of underlying investments. Exchange rate changes may cause the value of overseas investments to rise or fall. 

  8. Price Information: All prices or values may not reflect actual prices or values that would be available in the market at the time provided or at the time you may decide to purchase or sell an interest in a particular Fund.

  9. Risk Warnings: There are significant risks associated with an investment in any of the Funds. Investment in the Funds is intended only for those investors who can accept the risks associated with such an investment (including the risk of a complete loss of investment).You should ensure that you have fully understood such risks before taking any decision to invest.

    Investments in the Funds are neither insured nor guaranteed by any investor compensation scheme and are not deposits or obligations of, or guaranteed by, any entity within the Wellington Management group.

  10.  Offering Documents: The terms of any investment in a Fund are governed by the documents establishing such terms. An application for interests in any of the Funds should only be made having fully and carefully read the offering documents, which are the relevant offering memorandum, the latest financial reports and any other offering documents for the relevant Fund which are available on this Website and upon request from the fund representative in your jurisdiction and specified in the prospectus for the relevant Fund.

    It is your responsibility to use the offering documents and by making an application to invest in a Fund you will represent that you have read the offering memorandum for the relevant Fund and any other applicable offering document and will agree to be bound by its contents.

  11. Information on this Website: This Website, and the information on it, are provided for information purposes only and do not constitute an invitation, offer or solicitation to engage in any investment activity including to buy, hold or sell any investment including any interests in the Funds.

    The information on this Website is provided in good faith and reasonable care has been taken to ensure that such information is accurate, current and fit for its intended purpose. To the extent that any information on this Website relates to a third party, this information has been provided by that third party and is the sole responsibility of such third party and, as such, Wellington Management and its affiliates accept no liability for such information. No representation or warranty of any kind regarding the accuracy, adequacy, validity, completeness or timeliness of the information on this Website or the error-free use of this Website is given and, to the extent permitted by applicable laws, no liability is accepted for the accuracy or completeness of such information. No warranty of any kind, express or implied, including but not limited to the warranties of non-infringement of third-party rights, title, merchantability, fitness for a particular purpose, and freedom from computer virus is given in conjunction with the information, materials, products, and services on the Website. Any views expressed herein are those of the author(s), are based on available information, and are subject to change without notice. Individual portfolio management teams may hold different views and may make different investment decisions for different clients. Wellington Management does not warrant that the Website will meet your needs. You agree to assume the entire risk as to your use of the Website. Any person who acts upon, or changes his investment position in reliance on information contained on this Website, does so entirely at his own risk. In the event of any inconsistency between the information on this Website and the terms of the relevant offering documents, the terms of the offering document shall prevail.

    All content on the Website is subject to modification from time to time without notice save for any mandatory disclosure requirements. Please contact Wellington Management (using the details in the “Contact Us” section below) for further information regarding the validity of any information contained on this Website. 

    This Website and most of the documentation contained within it is provided in the English language and you represent and warrant that you understand the English language.

    The Website is limited to funds and sub-funds (and related information and documents) which have been authorised for sale.

  12. Conflicts of Interest: Wellington Management, its affiliates and their directors, officers, employees or clients may have or have had interests or long or short positions in any investment product or other financial instruments underlying any investment product referred to on this Website and may at any time make purchases and/or sales in them as principal or agent. In addition, Wellington Management and/or its affiliates may act or have acted as market maker in any investment product, or financial instruments underlying such investment product or entered into an arrangement to hedge the market risk associated with the investment products. The Wellington Management group has conflicts of interest policies in place which specify the procedures that they follow and the measures that they have adopted in order to avoid such conflicts or to manage such conflicts in a way that ensures fair treatment for clients. 

  13. Monetary Benefits: You agree that we may, to the extent permitted by applicable laws and regulations, share charges or commission with affiliates of Wellington Management or other third parties, or receive remuneration from them, in respect of transactions you carry out in relation to the Funds described on this Website. Where relevant, we may disclose such arrangements to you. Details of any such arrangements are available on request.

  14. Liability: No warranty is given that the contents of this Website are compatible with all computer systems or browsers or that this Website shall be available on an uninterrupted basis.

    The internet is not a completely reliable transmission medium and none of the Umbrella Funds, Wellington Management or any of its affiliates accept any liability for any data transmission errors such as data loss or damage or alteration of any kind or for the security or confidentiality of information transmitted across the internet to or from the Umbrella Funds, Wellington Management or any of its affiliates. Any such transmission of information is entirely at your own risk and any material downloaded from this Website is downloaded at your own risk. The information on this Website is provided “as is” and “as available”. To the extent permitted by law, no guarantee or representation, express or implied, is made as to the accuracy, validity, timeliness, completeness or continued availability of any information made available on the Website. The Umbrella Funds, Wellington Management, its affiliates and each of their directors, officers, employees and/or agents expressly exclude all conditions, warranties, representations, and other terms which might otherwise be implied by statute, common law or the law of equity to the fullest extent permitted by applicable law or regulation.

    In no event will the Umbrella Funds, Wellington Management, or any of its affiliates be liable to any person for any direct, indirect, special or consequential damages, losses or liabilities arising out of any use of, or inability to use, this Website or the information contained on it including, without limitation, lost profits, business interruption, any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus, line or system failure, loss of programs or data on your equipment or otherwise, even if the Umbrella Funds, Wellington Management or its affiliates is expressly advised of the possibility or likelihood of such damages, losses or liabilities, unless such damages, losses or liabilities are due to the Umbrella Funds’, Wellington Management’s or its affiliates’ negligence, wilful default, fraud or material breach of the Umbrella Funds’, Wellington Management’s or its affiliates’ obligations under applicable law or regulation.

    This does not affect the liability of the Umbrella Funds, Wellington Management or its affiliates for any loss or damage which cannot be excluded or limited under applicable law.

  15. Indemnification: As a condition of your use of the Website, you agree to indemnify and hold the Umbrella Funds, Wellington Management, and its affiliates, and their respective partners, directors, employees, and agents harmless from and against any and all claims, losses, liability, costs, and expenses (including but not limited to legal fees) arising from your use of the Website or from your violation of these Terms, unless such claims, losses, liability, costs or expenses are due to the Umbrella Funds’, Wellington Management’s or its affiliates’ negligence, willful default, fraud or material breach of the Umbrella Funds’, Wellington Management’s or its affiliates’ obligations under applicable law or regulation.

  16. Intellectual Property: The entire content of this Website is subject to copyright with all rights reserved. All materials on this Website are owned or licensed by the Umbrella Funds, Wellington Management, its affiliates and/or its third-party providers and are protected by UK and international intellectual property laws. Unless otherwise indicated, all service marks, trademarks, and logos appearing on this Website are the exclusive property of the Wellington Management group. You may not copy, display, distribute, download, license, modify, publish, repost, reproduce, sell, transmit, use to create a derivative work, or otherwise use for public or commercial purposes the content of this Website without the prior written permission of Wellington Management.

  17. Privacy: Please see our privacy policy which is contained on this Website for information about how the Wellington Management group protects your personal data, including personal data collected through this Website. You will be asked to agree to the terms of our privacy policy when selecting your relevant jurisdiction. 

    For users in Switzerland: the data that Wellington Management collects from you may be transferred to, processed by, or stored by Wellington Management or its affiliates which may be based outside Switzerland. You acknowledge that such foreign jurisdictions do not necessarily have equivalent data protection laws compared to Switzerland. By submitting your personal data, you agree to this transfer, processing or storing.

  18. Cookies: When you visit this Website, a Wellington Management group company server will record your IP address together with the date, time, page visited and duration of your visit. Please note that the Wellington Management group uses cookies on this section of the Website. Cookies are small pieces of software that are issued to your computer or device and that store and sometimes track information about your use of the site. Cookies on this Website may collect a unique identifier, user preferences and profile information and membership information from which it is possible to identify individual users. The Wellington Management group also uses cookies to collect general usage and volume statistical information that does not include personally identifiable information. Some cookies may remain on the user’s computer after they leave this Website (these are known as persistent cookies). For more information about cookies including how to set your internet browser to reject cookies, please go to http://www.allaboutcookies.org or http://youronlinechoices.eu.

  19. The Wellington Management group has engaged one or more third party service providers to track and analyze usage and volume statistical information from visitors to this Website. The service provider(s) set cookies on behalf of the Wellington Management group. The Wellington Management group may re-associate the information provided by the technologies directly above with other personal information we hold about you. By using this Website, you agree that third parties can place cookies on your device as described above.

    • to communicate or receive information that is obscene, indecent, pornographic, sadistic, cruel, or racist in content, of a sexually explicit or graphic nature, which promotes or incites discrimination, hatred or racism or which might be legally actionable for any reason;
    • in a manner intended to threaten, harass, or intimidate;
    • to violate Wellington Management’s or any third party’s copyright, trademark, proprietary or other intellectual property rights;
    • to damage Wellington Management’s name or reputation or that of Wellington Management’s affiliated companies or any third parties;
    • to impersonate any of Wellington Management’s employees or other person or use a false name while using this Website or implying an association with Wellington Management;
    • to penetrate Wellington Management’s security measures or other entities’ systems (“hacking”);
    • to transmit unsolicited voluminous emails (for example, spamming) or to intercept, interfere with or redirect email intended for others using this Website;
    • to generate excessive amounts of internet traffic, to interfere with Wellington Management’s network or other’s use of this Website or to engage in activities designed to, or having the effect of, degrading or denying service to other users of this Website or others;
    • to introduce viruses, worms, harmful code and/or Trojan horses onto the internet or into this Website or any other entity’s systems and it is your responsibility to ensure that whatever you download or select for your use from this Website is free from such items;
    • to post or transmit information that is defamatory, fraudulent or deceptive including, but not limited to, scams such as “make-money-fast” schemes or “pyramid/chain” letters; and/or
    • to transmit confidential or proprietary information, except solely at your own risk.
  20. Linked Websites: Links to websites operated by third parties are provided for information only and do not constitute any form of advice, endorsement or recommendation of such websites or the material on them. Wellington Management accepts no responsibility for information contained on any other sites which can be accessed by hypertext link from this Website or for these sites not being available at all times. Wellington Management has not reviewed, and will not review or update, such websites or information and any use that you make of such websites and information is at your own risk. Please note that when you click on any external site hypertext link you will leave this Website. You should review the privacy statements of such websites before you provide any personal or confidential information.

  21. Website Security and Restrictions on Use: As a condition to your use of this Website, you agree that you will not, and you will not take any action intended to: (i) access data that is not intended for you; (ii) invade the privacy of, obtain the identity of, or obtain any personal information about any other user of this Website; (iii) probe, scan, or test the vulnerability of this Website or Wellington Management’s network or breach security or authentication measures without proper authorisation; (iv) attempt to interfere with service to any user, host, or network or otherwise attempt to disrupt our business; or (v) send unsolicited mail, including promotions and/or advertising of products and services. Unauthorised use of the Website, including but not limited to unauthorised entry into Wellington Management’s systems or misuse of any information posted to a web site, is strictly prohibited.

  22. Amendment: Wellington Management may delete or make changes to these Terms and to the information contained on this Website at any time. Where such amendments are made, you will be required to accept any such changes in order and prior to continue to use the Website. If you do not accept such revised Terms, you may no longer be able to access this Website. 

    If any provision of these Terms is found by any court or authority of competent jurisdiction to be illegal, void or invalid under the laws of any jurisdiction, the legality, validity or enforceability of the remainder of these Terms in that jurisdiction shall not be affected and the legality, validity and enforceability of the whole of these Terms in any other jurisdiction shall not be affected.

  23. Third Parties: The Umbrella Funds, Wellington Management, and its affiliates shall have the benefit of the rights conferred on them by these Terms but otherwise no person who is not a party to these Terms may enforce its terms under the United Kingdom Contracts (Rights of Third Parties) Act 1999.

  24. Applicable Law: These Terms and any non-contractual obligations arising from or connected with them shall be governed by, and these Terms shall be construed in accordance with, the laws of England and Wales.

  25. Jurisdiction: You agree that the English courts shall have exclusive jurisdiction in relation to any legal action or proceedings arising out of or in connection with these Terms (whether arising out of or in connection with contractual or non-contractual obligations) (“Proceedings”) and waive any objection to Proceedings in such courts on the grounds of venue or on the grounds that Proceedings have been brought in an inappropriate forum. You further agree that this paragraph operates for the benefit of the Umbrella Funds, or Wellington Management and accordingly the Umbrella Funds, or Wellington Management shall be entitled to take Proceedings in any other court or courts having jurisdiction.

  26. About Wellington Management Switzerland GmbH and the Umbrella Funds:

    Wellington Management Switzerland GmbH is registered at the commercial register of the canton of Zurich with number CH-020.4.050.857-7 and its registered office is at Limmatquai 92, 8001 Zurich. It holds a distribution license from FINMA. Its VAT number is CHE-229.706.429 MWST. Wellington Management Switzerland GmbH is an appointed distributor to the Funds.

    Wellington Luxembourg S.à r.l. is the appointed management company of Wellington Management Funds (Luxembourg). Wellington Luxembourg S.à r.l. is a société à responsabilité limitée registered in Luxembourg and authorised by the Commission de Surveillance du Secteur Financier (the CSSF) as a management company authorised under chapter 15 of the Luxembourg law of 17 December 2010 on undertakings for collective investment, as amended. Wellington Luxembourg S.à r.l.’s registered address is at 33, Avenue de la Liberté, L-1931 Luxembourg.

  27. Contact Us: If you have any enquiries in relation to this Website or the information on it, please contact Wellington Management at infofunds@wellington.com. Registered office: Limmatquai 92, CH-8001 Zurich, Switzerland.

Effective as of 21st August 2019

I ACCEPT I DECLINE

FSC Standard 23: Principles of Internal Governance and Asset Stewardship

Wellington Management1 manages our business in Australia and New Zealand through Wellington Management Australia Pty Ltd (WM Australia). WM Australia is an Australian proprietary limited company. WM Australia is an indirect subsidiary of Wellington Management Group LLP and is authorized to provide investment management services in Australia under an Australian Financial Services Licence.

Organisational and Investment Approach

1. A description of the distinguishing features of the Asset Manager and how these features are directed towards achieving client objectives

Wellington Management offers comprehensive investment management capabilities that span nearly all segments of the global capital markets. Our only business is investment management, and our mission is to exceed the investment objectives and service expectations of our clients worldwide.

Wellington Management combines the resources of a large, global, diversified multi-asset manager with the small-company feel of an independent, privately held partnership. We believe this combination serves our clients well. First, our scale and broad capabilities allow us to address a wide range of investment needs and foster innovative solutions. Second, our ownership model aligns our interests with those of our clients and enables a longer-term perspective on our business.

Most importantly, the glue that holds all of this together is our culture. We believe our collaborative culture is the sustainable competitive advantage of our firm, helping us to attract, retain, develop, and motivate talented, dedicated people. Our shared values include integrity, collegiality, learning, humility, respect for diversity of thought, and an unyielding focus on our clients. We are guided by the mantra, “client, firm, self,” and the result is a firmwide mandate to put forth our best efforts on behalf of our clients every day.

2. An explanation of how the Asset Manager aligns its purpose and values with its duty to clients

Clients are the reason that our firm exists, and are at the heart of everything we do. This is evident in the clarity of our mission — to exceed the investment objectives and service expectations of our clients worldwide — and in the strengths we bring to bear in pursuing that mission:

LONG-TERM PERSPECTIVE OF A PARTNERSHIP STRUCTURE
Our private ownership model provides stability, allows us to focus on long-term results, aligns our interests with those of our clients, and helps us to recruit and retain outstanding talent.

SINGULAR FOCUS ON INVESTMENT MANAGEMENT
Our only business is managing money for our clients, allowing us to concentrate on our goal of exceeding their investment and service expectations.

EMPOWERED INVESTMENT TEAMS AND RIGOROUS PROPRIETARY RESEARCH
We describe our investment model as a “community of boutiques.” Each investment team has freedom of philosophy and process, while benefiting from the resources of a large, global firm.

OPEN, COLLABORATIVE CULTURE
We have built our organization to foster healthy debate, diversity of thought, and the free exchange of ideas — conditions we believe are essential for informed investment decision making.

3. An overview of the ownership, management and governance structures of the organisation

The ultimate parent of the Wellington Management group is Wellington Management Group LLP (“WMG” or the “Partnership”). WMG is an independent, private partnership that is owned by its partners, all of whom are fully active in the firm. Business oversight is the responsibility of Brendan Swords, Chairman and CEO, and the firm’s Executive Committee.

Management responsibility is carried out by the firm’s line management, under the direction of the CEO.

Wellington Management has a number of committees that are charged with various management and oversight responsibilities (including the examples below). The frequency and timing of meetings varies across committees. They fall into five major categories.

General Management
Managing Partners Committee
Executive Committee
Affiliate Boards

Talent/Resource Management
Operating Committee
Compensation Committees
Information Technology Priorities Committee

Investment Process and Oversight
Investment Stewardship Committee
Investment Review Groups
Trading Policy Review Group

Risk Management and Internal Controls
Audit Committee
Ethics Committee
Pricing Committee
Risk Management Committee

Business Oversight
Diversity Committee
Hedge Fund Oversight Committee
Product Panel

4. An overview of the key management and investment personnel within the organisation

The following diagram summarises the key management and investment personnel for Wellington Management:

Australian stewardship code

5. Explanation of how the Asset Manager ensures client assets are managed in accordance with their investment strategies and how conflicts of interest are managed

We exercise investment discretion on behalf of our client accounts only when expressly authorized to do so in writing by the client. We exercise this discretion in accordance with client guidelines and limits we place on the aggregate ownership of individual equity securities across all client accounts.

In exercising investment discretion, our portfolio managers manage client accounts in compliance with account guidelines, which are often customized to reflect a particular client’s investment objective, benchmark, risk tolerance and other requirements. Initial client account guidelines are established by agreement between us and the client and are typically included as part of the investment management agreement. From time to time, we negotiate changes to account guidelines with a client. We document changes to client guidelines and provide those changes to the account’s portfolio management team.

We employ a variety of methods to assist portfolio managers in complying with client guidelines. This support includes a dedicated team of guideline monitoring personnel, compliance systems technology, exception identification and escalation, periodic training, consultation and review.

The directors of each investment function at the firm, together with their teams, review the portfolio managers within their respective groups on an ongoing basis. In addition, we have created several formal investment review groups. These groups are intended to support our firm’s fiduciary responsibility to provide competent and professional investment management services to our clients by reviewing the investment process and performance of investment teams.

Our global relationship and client services groups provide a variety of reporting and other services to our clients. We provide detailed portfolio information on our client website on an ongoing basis. On a quarterly basis, we typically provide a written reporting package, including an update of the holdings, transactions and performance of the client’s account as well as commentary on current positioning. As part of this package, we typically share the portfolio manager’s views on the economy and markets. In addition, we periodically provide our clients with white papers on asset allocation issues, investment strategy questions and other relevant topics. Clients receive different levels of service from our firm or have varying access to our investment and other personnel, including varying opportunities to discuss current investment trends or themes. Some of our clients receive investment reports or analyses that other clients do not receive. We make decisions about the level of service offered to any client or group of clients based on a review of client needs and our business considerations.

Conflicts of interest are inherent in any large global investment management business. Asset management firms have to maintain and operate effective organizational and administrative arrangements with a view to taking all reasonable steps to prevent conflicts of interest from adversely affecting the interests of their clients. To the extent that those conflicts relate to our role as a fiduciary, the management of the conflict is a core fiduciary responsibility. We have extensive policies and procedures for identifying circumstances which may give rise to, and for managing conflicts of interest.

Internal Governance

1. Ethical conduct and professional practice

Our Code of Ethics (Code) applies to all Wellington Management personnel worldwide. The Code describes the standard of conduct we require of our personnel and sets forth certain restrictions on activities, such as personal trading and gifts and entertainment. Compliance with the Code is a condition of employment for all personnel. A serious violation of the Code or related policies may result in dismissal. A copy of the entire document is available upon request.

Wellington Management seeks excellence in its personnel, the products and services we offer, the way we meet our ethical and fiduciary responsibilities, and the working environment we create. All personnel are required to put our clients’ interests above our own. Our firm’s policies and procedures reflect this principle with respect to conducting the firm’s business.

2. Personal trading

All Wellington Management, personnel are considered “access persons” under our Code. They must preclear their personal transactions in covered securities prior to execution, except as specifically exempted under the Code. Some personal securities transactions that are not subject to preclearance must nonetheless be reported, including transactions in open-end mutual funds and variable insurance products that we manage. The Code’s restrictions on personal trading apply to accounts over which an access person and/or certain immediate family members have investment discretion, or from which they enjoy economic benefits. Portfolio managers are subject to additional restrictions on their personal transactions.

The preclearance process tests proposed transactions against a number of substantive restrictions designed to prevent our personnel from taking advantage of our firm’s investment activity on behalf of our clients. We prohibit all personnel from buying or selling securities issued by broker/dealers that are approved for execution of client trades or by securities markets or exchanges on which we trade on behalf of clients. Likewise, we do not allow our personnel to engage in personal transactions involving the direct purchase of any security in an IPO. All personnel are required to provide quarterly reports and certifications regarding their securities transactions and annual reports regarding their securities holdings

3. Management of conflicts of interest to ensure client interests take priority (including gifts and entertainment)

Conflicts arise in the ordinary course of our business. Some of those conflicts are inherent in any large, global investment management business, while others are a result of our business model. We seek to avoid or minimize these conflicts where reasonably possible. However, some conflicts cannot be avoided, and although others could be, we have determined that doing so would require changes to business or investment practices that, on balance, provide a significant benefit to our firm and/or our clients. Any conflicts that we cannot or have chosen not to avoid are managed through policies and procedures that we believe are sufficient to protect the interests of our clients and fulfill our fiduciary obligations to our clients.

Our Code places restrictions on receipt of gifts, travel, and entertainment opportunities by our personnel. Our personnel occasionally participate in entertainment opportunities that are for legitimate business purposes, subject to limitations set forth in the Code.

4. Risk management and compliance

Wellington Management identifies risks at the entity or business level as well as the activity or process level. Managers of individual business units are responsible for identifying business risks associated with their functions and monitoring changes in their functions to verify that new risks are identified. Legal & Compliance monitors laws and regulations to identify new laws that emerge or changes to existing laws or regulations.

Market risk is monitored on a daily basis to evaluate the impact on our strategies and portfolios. Portfolio gearing is monitored based on relevant client guidelines. Control and monitoring of market risk utilizes specialized reporting that has been developed to provide investment personnel with information on derivative positions.

Our Compliance Program starts with two fundamental principles. First, each Wellington Management employee serves as a fiduciary to the firm’s clients. Second, each employee is subject to certain securities laws, and to the rules and regulations that implement those laws. Our approach to compliance embraces these fundamental principles and seeks to reinforce them through the engagement of Wellington Management personnel in the process of compliance, as well as through specific policies and procedures. Our overarching policy is to achieve firmwide compliance with all applicable laws and regulations on an employee-by-employee basis, through involvement of all employees and business groups in the compliance process.

5. Error correction policy

Our risk-management and compliance processes are designed to minimize the occurrence of errors in our investment process, and we believe that we have strong policies and procedures in place. However, from time to time, errors do occur. They are usually discovered early in the process, often by the trading desk before settlement has occurred or through other internal reviews. When an individual identifies an error, he or she is required to report it to the line manager and Wellington Management’s Error Resolution Council, a committee composed of senior management personnel, for immediate review and determination of the appropriate resolution. If a compensable error impacts a client account, we endeavor to promptly notify the client involved and minimize disruption to the client and to the investment process. The Error Resolution Council is responsible for overseeing the resolution process and for working with line managers to identify issues that may warrant changing procedures.

6. Brokerage and commissions

We negotiate commission rates with broker/dealers in advance of trading based on the various types of trade execution that our client accounts may need. In many cases, we also negotiate commission rates with broker/dealers to include research services that are bundled with execution services. We attempt to negotiate rates that maximize the overall benefits received by our clients for their commission expenditures. Those benefits include, but are not limited to, trade execution, the willingness and ability to commit capital and the availability of investment research provided by the broker/dealer. While some client accounts routinely make use of a range of services provided by broker/dealers, an account may make use of a particular service only rarely, if at all. As we cannot predict when orders for a client account will require a particular service, we believe that access to the full range of services provided by broker/dealers generally benefits all client accounts.

We do not own or control a broker/dealer that executes securities trades for client accounts.

7. Equitable asset valuation and pricing

We seek to maintain accurate market valuations of the holdings in our client accounts. We determine values of all securities and other instruments held in client accounts at least monthly. Where reliable third-party vendor prices are readily available, we update those values daily. In addition, we determine fair values for securities and other instruments for which market quotations are not readily available or when the price provided by a pricing source does not, in our view, represent fair value. This pricing is done primarily to assist our portfolio managers in managing client accounts, although certain clients have agreed to use these prices when calculating the market value of their accounts for purposes of calculating our management fees.

We do not act as the pricing agent of record in our capacity as advisor or subadvisor for client accounts, though we will provide assistance to the official pricing agents of those accounts, usually custodian banks or accounting agents, upon request. For example, we provide recommendations regarding the appropriate pricing methodology for fair-valued securities held in client accounts and often will act as the primary or sole pricing source for fair-valued securities held by our Sponsored Funds. In each instance, however, the official pricing agent retains responsibility for determining the value of the securities in question.

8. Best execution and trade allocation

We seek best available price and most favorable execution of the orders directed by our portfolio managers. We define best execution as a process, not a result: it is the process of executing portfolio transactions at prices and, if applicable, commissions that provide the most favorable total cost or proceeds reasonably obtainable under the circumstances (taking into account all relevant factors). Trading practices, regulatory requirements, liquidity, public availability of transaction information and commission structures vary considerably from one market to another. Best execution incorporates many such factors, as well as the portfolio manager’s investment intentions, and involves an evaluation of the trading process and execution results over extended periods. We regularly monitor our trade executions to assess our effectiveness in seeking best execution and use third-party analysis where applicable. We can never know with certainty that we have achieved best execution on any given trade, but we believe that over time we do achieve it. Wellington Management’s allocation policy is designed to allocate trades in a manner that is fair and reasonable to client accounts over time. When orders are substantially similar, Equity and Fixed Income Trading typically aggregates them and places a block order with one or more broker/dealers. After execution, the allocation to a given account may be rounded to the nearest round trading lot or adjusted due to specific market conventions. Wellington Management typically imposes a minimum allocation amount for transactions in equity securities in secondary markets. When a strict pro rata allocation places some client accounts below the minimum allocation amount, an algorithm is used to reallocate the residual shares among the affected accounts. The new allocations are approximately equal in size to the minimum allocation amount. The algorithm weights the participating accounts according to the allocations they would have received under a strict pro rata process.

All executed trade orders are allocated to client accounts on the same business unless market convention dictates otherwise. For equity IPOs, if the resulting allocation received from the underwriting syndicate is sufficient to fill each order, then each order is filled. If, however, the orders exceed the number of shares allocated to the firm, then the shares are automatically distributed pro rata among the participating accounts, based on each account’s equity assets under management. For these purposes, equity assets may include cash, fixed income securities and derivative instruments held in that portfolio. The designated trader reviews the Underwriter report upon allocation to verify that the system allocated the shares correctly.

9. Remuneration policy

Our compensation plans are designed to be fair and motivational over time in order to attract and retain the best professionals in the investment industry. We provide them with incentives to excel, and reward superior performance. Compensation arrangements for investment professionals typically include a base salary component and one or more variable components. For senior professionals, variable compensation is a substantial portion of total compensation.

The significant number of our professionals who are senior managing directors or managing directors of the firm receive additional merit-based compensation based on the overall performance of the firm and their individual and team contributions to firmwide results.

10. Whistle-blower protection policy

Wellington Management staff have the right to report violations of law or regulation to Wellington Management, the Code of Ethics team, the Chief Compliance Officer, the General Counsel or the Chair of the Ethics Committee. They also have the right to report violations of law or regulation directly to relevant governmental agencies. They do not need Wellington Management’s prior authorization to make any such report or disclosures and are not required to notify the firm if any such disclosures are made.

11. Training and development

Wellington Management endeavors to hire, develop and retain personnel with the appropriate knowledge and skills to successfully fulfill their roles. Most portfolio management and trading positions require a minimum of five years of relevant industry experience and an undergraduate degree, coupled with an advanced degree and/or Chartered Financial Analyst designation or efforts towards one. All candidates participate in a vigorous interview process, meeting with many professionals at the firm. Once hired, new employees participate in new employee orientation. In addition to standard human resources-related issues, new employees learn about Wellington Management’s culture, the Code of Ethics and general operating procedures such as client confidentiality, proprietary research and material nonpublic information.

In addition, Wellington Management firmly believes in the value of continuing education. The firm offers many diverse opportunities, both internally and externally, for personal and professional development. On-the-job training is an important responsibility of each line manager.

12. Complaints and dispute resolution

Wellington Management Australia has established formal procedures for dealing with enquiries and complaints by its clients to ensure that all complaints are responded to promptly and in a positive manner, and to provide an efficient, fair and accessible mechanism for complaint resolution.

All material instances of client dissatisfaction (i.e., a complaint), whether verbal, written or electronic, must be communicated to appropriate members of the Wellington Management Australia Team and Compliance. Wellington Management Australia will investigate the client’s allegation(s) and the circumstances that resulted in the complaint and, as appropriate, a response will be prepared and issued to the client.

Asset Stewardship

1. Monitoring of company performance on financial and nonfinancial matters

Wellington Management has a long history of conducting independent fundamental research. Monitoring our investee companies and engaging directly with company management on a range of issues, including environmental, social and corporate governance (ESG) matters, has always been a core part of our investment process.

The majority of our company research is the result of direct contact with company management, both in our offices and on site, including contacts with company suppliers, customers and competitors. Every year, Wellington Management participates in more than 10,000 meetings with company management teams from around the world. Portfolio managers, industry analysts and ESG analysts all take part in our ongoing dialogue with companies and we share information from these engagements with one another using a common research platform. This internal platform allows us to share specific company ratings from our fundamental, credit, quantitative and ESG research teams, along with engagement notes from meetings with company managements. Providing this level of transparency and information sharing across the firm facilitates our ongoing monitoring of, and dialogue with, investee companies and helps us prioritise and focus our monitoring and engagement activity.

2. Engagement with company management and the board (as appropriate) and escalation of issues in instances where initial engagements have not been adequately responded to

Wellington Management engages with company management and the board as appropriate. Examples of engagement topics include business strategy, capital structure and material ESG issues relevant to the company’s long-term success such as environmental regulation, employee training and development and senior-level succession planning. During our conversations with company management, we learn about their perspectives and approaches, provide them with feedback on how they can improve and incorporate our findings into our research and ratings. We assess each company relative to its industry and home-market peers, and we pay particular attention to its adherence to regional corporate governance codes in our analysis. For example, if a company fails to comply with the FSC standards, we assess the potential impact on the company’s long-term success and may choose to employ our engagement efforts and proxy voting to address the issue with management.

We have not developed prescriptive guidelines for when and how we will escalate our activities. Rather, decisions to escalate are made on a case-by-case basis by our portfolio management and ESG Research teams. The decision to escalate depends on the materiality of the issue, the responsiveness exhibited by the company to past communications and our assessment of whether such engagement is in the best interests of our clients. Our escalation activities can include meeting with company boards, participating in stakeholder dialogues or submitting proxy votes against company management on behalf of our clients. Our Global Proxy Voting Policy and Guidelines describe our practices around voting.

3. Approach to considering Environmental, Social and Corporate Governance factors (risks and opportunities) and whether these considerations influence investment decision making and company engagement

To assist analysts and portfolio managers in fulfilling our stewardship responsibilities, we have a dedicated research team of ESG experts. Our ESG Research Team, part of the central investment research function, researches and provides company- and sector-specific ESG analysis and engages directly with company management teams on ESG topics. The team analyzes and executes proxy voting for over 5,000 company meetings annually, and performs portfolio reviews with portfolio managers to identify holdings with the greatest ESG risks and opportunities.

Examples of topics on which we engage with companies include:

1. Climate change: Global climate change poses significant long-term risks to companies in many industries, especially those most exposed to increased regulation, extreme weather and food and water disruptions. Our ESG Research Team engages with companies to gauge their exposure to climate-related events, assess management’s awareness of this topic and evaluate their risk-management approach.

2. Supply chain management: Supply chain issues can cause operational disruptions and/or brand damage, both of which can affect a company’s bottom line. Our ESG Research Team engages with company managements to better assess their supply chain risks which could include labor strikes, product quality or safety issues, data-security breaches, natural disasters and geopolitical uncertainty.

3. Executive compensation: We strongly agree with the philosophy of pay for performance and believe that company management teams should be incentivised on clear measures that directly drive the long-term performance of their business. Executive compensation is one of the most frequent topics of engagement with our investee companies, and we may meet with management teams multiple times over the course of a year as they consult with us on improving their pay plans.

Wellington Management is organised as a collection of portfolio teams — each with its own unique investment philosophy, approach and time horizon; there is no “house view”. Consistent with this structure, each of our portfolio teams develops its own investment approach whereby ESG considerations are integrated into its research and decision making processes to the extent that it believes these issues may affect the long-term success of a company and investment returns. This can manifest itself within the investment thesis or portfolio weighting for a particular security, as well as within our proxy voting and company engagement efforts. While each portfolio team acts as a fiduciary for its clients, differences in investment philosophy and process across teams means that the emphasis on incorporating ESG factors in the investment decision making process may vary across investment approaches.

4. Proxy voting

Clients often give us discretion to vote proxies on securities held in their accounts. We take the responsibility of proxy voting seriously. We have policies and procedures designed to ensure that we collect and analyse all relevant information for each meeting, apply our proxy voting guidelines accurately and execute the votes in a timely manner. Our policies and procedures are contained in our Global Proxy Policy and Procedures.

We vote proxies in the best interests of our clients as shareholders and in a manner that we believe maximises the economic value of their holdings. Importantly, we do not automatically vote proxies either with management or in accordance with the recommendations of third-party proxy providers. We vote according to our own Global Proxy Voting Guidelines, and we employ a third-party vendor to perform administrative tasks related to proxy voting. While our proxy voting guidelines set forth general guidelines for voting proxies, we evaluate each proposal on its merits. The ESG Research Team examines each proxy proposal and recommends voting against proposals that we believe would have a negative effect on shareholder rights or the current or future market value of the company’s securities.

While the ESG Research Team provides proxy voting recommendations, the portfolio manager for the client account has the authority to decide the final vote, absent a material conflict of interest. Each portfolio manager examines and votes each proposal with the goal of maximising the long-term value of securities held in their clients’ portfolios. In addition, there is no “house vote”. Our proxy voting system allows different votes to be submitted for the same security. Our firm is organised as a collection of portfolio teams — each with its own unique investment philosophy, approach and time horizon. Consistent with this structure, various portfolio managers holding the same securities may arrive at different voting conclusions for their clients’ proxies.

While Wellington Management does not rely on any external parties for recommendations or vote determinations, we do subscribe to the research products supplied by various proxy advisors and research providers, including ISS and Glass Lewis. We use an electronic voting platform provided by one of our proxy advisors to facilitate electronic receipt and execution of ballots.

Our actual votes on behalf of a given client or pool are a matter of record for that client or pool, and are disclosed to the respective party in the reports they are entitled to receive. Our record of proxy votes provided to each client includes the name of the security, meeting date, number of shares voted and how we voted on behalf of each client. Summary reporting of our proxy voting activity is included in our Global ESG Research Update, which is published quarterly and made publicly available on the Insights section of our website. We do not disclose information about specific proxy votes publicly, but do provide the relevant data to support public disclosure by those clients that are required to do so by law.

In certain instances, Wellington Management may be unable to vote or may determine not to vote a proxy on behalf of one or more clients. For example, we may be unable to vote proxies when the underlying securities have been lent out pursuant to a client’s securities lending program. In general, Wellington Management does not know when securities have been lent out and are therefore unavailable to be voted. In some circumstances, we may recommend that a client attempt to have its custodian recall the security to permit voting of related proxies. However, efforts to recall loaned securities may not always be successful. Another instance when we may refrain from voting is when the cost of voting outweighs the value of the vote. For example, we typically do not vote in share blocking markets, where countries impose trading restrictions or requirements regarding re-registration of securities held in omnibus accounts in order for shareholders to vote a proxy. The consequences of such requirements — including the potential impact on liquidity — are evaluated on a case-by-case basis when determining whether to vote such proxies.

Day-to-day administration of the proxy voting process is the responsibility of the ESG Research Team. Annually, Wellington Management engages an independent accounting firm to perform an assessment of controls surrounding our proxy voting process. This assessment is made available to clients.

5. Collaborative engagement with other investors including involvement with industry groups and associations

We have been signatories to the UN Principles for Responsible Investment (PRI) since 2012, and in 2017 we signed the PRI Statement on ESG in credit ratings and the Statement of Support for the Task Force for Climate-Related Financial Disclosures (TCFD). We are also signatories of several stewardship codes, including the UK Stewardship Code, the Hong Kong Principles of Responsible Ownership, the Japan Stewardship Code, and joined those efforts soon after their launch. In addition, we are founding members of the Investor Stewardship Group’s Governance and Stewardship Principles in the US, which launched in January 2017. We are also members of the Council for Institutional Investors, the International Corporate Governance Network, the Asian Corporate Governance Association and the Global ESG Benchmark for Real Assets (GRESB), and became members of the Global Impact Investing Network (GIIN) in 2016.

6. Principles used for policy advocacy including participation with industry groups and associations

We cultivate relationships with other asset management firms and broader industry organizations to share insights on corporate governance trends and local market considerations. Due to Wellington Management’s significant presence and long-term track record in nearly all sectors of the global securities markets, we often have direct access to company management teams. We believe this access is highly valuable, given the number of meetings we conduct, the breadth of our contacts and the quality of the dialogue. We often prefer to engage privately with our portfolio companies as we have found this encourages openness and a productive engagement dialogue. When private engagement proves ineffective, however, we are willing to collaborate with other investors when such action would be in our clients’ best interests and is permissible under applicable laws and regulations. Questions related to specific collaboration opportunities can be directed to Carolina San Martin, director, ESG Research, at ESGresearch@wellington.com.

7. The approach to client engagement, education and communication regarding asset stewardship

We provide educational opportunities to a limited number of clients. Those opportunities include roundtable forums or investment institutes where clients meet and exchange investment ideas and techniques with our personnel. We also provide educational services related to various investment topics such as asset allocation, portfolio construction and risk analysis, and integration of environmental, social and corporate governance factors. We select the clients who participate in these events or receive these services at our discretion.

Our Global ESG Research Update report, published quarterly and made available on the Insights section of our website, includes a list of company engagements conducted by our ESG team and statistics summarising proxy voting activity from the previous quarter. The report also includes engagement case studies that provide additional examples of circumstances in which we would be likely to escalate our activities with the intention of protecting and enhancing shareholder value.

1“Wellington Management” means companies conducting investment management business within the Wellington Management Group LLP group of companies.

Published June 2018

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