FRM (AUSTRALIA) PTY LIMITED PRIVACY POLICY AND DISCLOSURE STATEMENT

FRM (Australia) Pty Limited is subject to the National Privacy Principles in the Privacy Act 1988 (Cth). This Privacy Policy and Disclosure Statement explains in general terms how FRM (Australia) Pty Limited protects the privacy of your personal information under the National Privacy Principles. It also sets out the matters which we are required to disclose to individuals under National Privacy Principles 1.3 and 1.5. The principles set out in this Privacy Policy and Disclosure Statement will apply to any personal information you provide to FRM (Australia) Pty Limited via our web site or under any other agreement or arrangement and to information which we collect about you from other sources.

This Privacy Policy and Disclosure Statement does not apply to acts and practices of FRM (Australia) Pty Limited which relate directly to the employee records of our current and former employees and to our employment relationships with employees.

How we collect your personal information

We generally collect your personal information directly from you. For example, we may collect personal information about you when you deal with us over the telephone, send us your application or other correspondence (whether by letter, fax or e-mail), visit our web site or when you have contact with us in person.

Generally, the type of personal information we collect about you includes your name, mailing address, telephone number and e-mail address. We may collect information about your membership in any professional or trade associations. In relation to our employees and contractors, we may also collect information about your previous employment and sensitive information such as information relating to criminal records (if any) and the nature of that record.

There may be occasions when we source personal information about you from a third party. For example, we may collect personal information from magazines, the telephone and other commercial directories, conference organisers, our related bodies corporate, specialist investment websites, generally available publications, or collect contact details such as your email address from your company or your company's website and other generally publicly available sources.

Our disclosure statement

FRM (Australia) Pty Limited collects personal information for the following purposes:

• to ascertain the suitability of potential employees and contractors;
• to develop and manage its relationships with clients, custodians, advisors and investment industry organisations;
• to provide you with information about our products and services;
• to obtain contact details of clients, employees, professional advisors and contractors;
• to decide whether to supply investment products and services to potential customers;
• to supply investment products and services;
• to comply with laws which apply to us, such as anti-money laundering laws.

If you do not provide us with information then, depending on the circumstances, we may not be able to provide products and services to your or engage you as a supplier or pursue a business relationship with you.

In some circumstances, we collect personal information about you from a third party source. If we collect personal information about you in this way, we will take reasonable steps to ensure that you are aware of certain matters such as the purposes for which we are collecting your personal information and the organisations to which we might disclose your personal information.

We may disclose your personal information on a confidential basis to:

• our suppliers for the purpose of providing services to us so that we can supply you;
• our related bodies corporate;
• suppliers of information technology services, so that they may provide those services;
• government agencies and courts as and when required by law;
• credit reporting agencies;
• professional advisors (lawyers, accountants and auditors) for the purpose of obtaining advice and professional services.

How we use and disclose your personal information

We will use and disclose personal information for the primary purpose for which it was collected. We may also use and disclose personal information for purposes related or ancillary to the main reason we collect it. We do not disclose personal information we collect to third parties for the purposes of allowing them to direct market their products and services to you.

We engage third party contractors to perform services for us which involves the contractor handling personal information we hold. For example, we engage third party contractors to provide part time services on an ad hoc basis, for example client services and office management. We also engage third party information technology and information management contractors and investment administrators. In these situations, we prohibit the third party contractor from using personal information about you except for the specific purpose for which we supply it.

Sharing information within FRM group

We share with our related bodies corporate all information held on our information technology systems.

Each FRM entity may disclose personal information to other FRM entities which will use and disclose the information only for the purpose for which it was originally collected or other purposes permitted under the Privacy Act.

Gaining access to information we hold about you

FRM (Australia) Pty Limited will, on request, provide you with access to the personal information we hold about you, unless there is an exception which applies under the Privacy Act 1988 (Cth).

Your request to obtain access will be dealt with in a reasonable time. FRM (Australia) Pty Limited may recover from you its reasonable cost of providing you with access.

If FRM (Australia) Pty Limited refuses to provide you with access to the information, FRM (Australia) Pty Limited will provide you with reasons for the refusal and inform you of any exceptions relied upon under the Privacy Act 1988 (Cth).

Keeping your personal information up-to-date

We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it.

If you find that the personal information we hold about you is inaccurate, incomplete or out-of-date, please contact us immediately and we will take reasonable steps to correct this information, or if necessary, we will discuss alternative action with you.

Security of your personal information

We protect any personal information that we hold from misuse and loss. We also protect it from unauthorised access, modification and disclosure.

Your personal information may be stored either in hardcopy documents, as electronic data, or in FRM (Australia) Pty Limited's software or systems.

We maintain physical security over our paper and electronic data stores and premises, such as locks and security systems. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to computer system.

Transfer of information to foreign countries

We may transfer your personal information to our related bodies corporate in foreign countries. Our related bodies corporate have privacy policies, where applicable, in place. Where our related bodies corporate in foreign countries do not have a privacy policy in place, we will obtain your consent prior to transfer of any of your personal information to that related body corporate. We will only transfer your personal information to other people outside Australia with your express or implied consent or where we are otherwise permitted to do so under the Privacy Act.

How to contact us

If you wish to gain access to your personal information or make a complaint about a breach of your privacy or if you have a query on how your personal information is collected or used, or any other query relating to FRM (Australia) Pty Limited's Privacy Policy and Disclosure Statement, please contact our Privacy Officer:

Craig Miladinovic
Telephone: (02) 9256 4900
Facsimile: (02) 9252 1005

We will respond to your query or complaint as soon as possible and will try to resolve any complaint within 5 working days. If this is not possible, we will contact you within that time to let you know how long we estimate that it will take to resolve your complaint.

Our contact details

FRM (Australia) Pty Limited's offices are located at:

Suite 2, Aurora Place
Level 33
88 Phillip Street
SYDNEY NSW 2000
Australia