We understand that privacy is important. Our Privacy Policy sets out how we will collect and manage your personal information according to the Privacy Act 1988 (Cth) and the Australian Privacy Principles, as applicable.

Your access to (or use of) this website and the provision of information to us (by whatever means) indicates your acceptance of our Privacy Policy and your consent for us to collect and use your personal information according to this policy. We may modify these policies from time to time without notice by publication on our website.

A reference in this Privacy Policy to “we” and/or “us” is a reference to Contrarius Investment Advisory Pty Ltd (“Contrarius Australia” or “CIAPL”), a company incorporated in Australia with ACN 618 145 449 and AFSL No. 506315. A reference to “you” or “your” is a reference to any person who views this Privacy Policy, any person who views or visits the www.contrarius.com.au website or any person who is resident in Australia and has provided information to us.

What personal information do we collect?

Personal information means any information that can identify you or is reasonably identifiable. We obtain personal information in order to provide you with our services or manage our relationship with you. This may include details such as your name, contact information, date of birth, nationality, tax file number, occupation, employer, bank details, financial information regarding the products you invest in and data required for AML/CTF purposes. We will collect personal information directly from you where it is reasonable and practicable to do so. Where we collect personal information from a third-party service provider, we will still take reasonable steps to ensure that an individual is made aware of the same key matters as set out above.

We may also collect personal information from individuals who are not our customers or clients, for example, business contact details of a company representative or authorised signatories whom we normally deal with.

Generally, we will not collect sensitive information about you (e.g. your ethnic background, political or religious beliefs or health information) unless such information is required for providing our services to you and we have received your explicit consent, or where required by law.

How is personal information collected and stored?

In most cases, we will collect personal information about you from the forms you complete (which may be electronic) in relation to your investment in a Contrarius fund, or instructions you provide verbally or in writing to our Investor Services team. We collect personal information about you when you decide to invest in a Contrarius fund through your financial adviser and there may be instances where we collect your information from a third-party service provider.

When you visit our website, we collect information about your visit, including through the use of 'cookies'. Cookies are pieces of information that a site sends to your computer when you access information on that site. Cookies do not identify individual users; however, our servers may record information about your usage, the time of your visit, its duration, the pages you visit and style settings. We may use this information and other related site information to measure your interest in the contents provided and as such to continuously respond to your needs and improve our service. For further information, please refer to the Cookie Policy.

When accessing our website, you may be redirected to other sites of interest including those of our related entities. Once you access another site, you will be subject to that site’s approach to data protection and privacy.

Security of your personal information is important, so in storing such information we will take all reasonable steps to protect your personal information from loss, unauthorised access, destruction, use, modification or disclosure. This includes using a variety of physical and electronic measures, such as restricting physical access to our offices, and secure servers.

How is personal information used?

We use your personal information for the purposes for which it was collected, such as to assist you from an investor management perspective or to facilitate the processing of your application, transaction or other requests. If you do not provide us with such information, we may be unable to provide you with the assistance or service you require. Once we no longer require your personal information, we will take reasonable steps to either destroy or permanently de-identify this information.

We will not disclose your personal information except to:

• Companies within the Contrarius Group, some of which are located overseas in Bermuda, Jersey, South Africa and the United Kingdom. Personal information shared within the Contrarius Group will be strictly used for the purposes for which it was collected and will be dealt with according to the Contrarius Group Privacy Policy which can be viewed at www.contrarius.com.
• Third parties that perform processing or servicing functions or assist in client relationship management, including each Contrarius fund’s unit registrar or responsible entity, or your external adviser. Certain of these, such as our electronic mail service, are located or store data overseas.
• External legal or other professional advisors retained to advise Contrarius with respect to the services provided by Contrarius. Any personal information provided to external advisors will be provided on a confidential basis.

Unless we have your consent or an exception under the APPs applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information.

Can personal information be given to anyone else?

We do not sell, rent or trade personal information to, or with, third parties. In some circumstances personal information may be disclosed without obtaining your consent or prior notification to you. This includes where disclosure is required by law enforcement agencies, government agencies or regulatory bodies such as AUSTRAC, ASIC or ATO, courts, or in compliance with applicable laws.

Accessing and correcting your personal information

You can access the personal information we hold about you and request changes. Your right to access your personal information is subject to certain exceptions. For example, you may be unable to access your information which would interfere with the privacy of others or which we are prevented by law from disclosing.

If you have any complaints or questions about this Privacy Policy or wish to access and/or correct your personal information, please contact us at investorservices@contrarius.com.au.

If we are not able to resolve your complaint or query with respect to this Privacy Policy and/or your personal information, please contact the Office of the Australian Information Commissioner on 1300 363 992 or at enquiries@oaic.gov.au.

Changes to Privacy Policy

From time to time, we may change this Privacy Policy. We recommend that you visit our site regularly to keep up to date with any changes.

This Privacy Policy is dated 15 February 2023.

The Privacy Notice of the Contrarius Group is available here.

Cookie Policy

The use of cookies

We use cookies and similar tools on our website to improve its performance and enhance user experience. Cookies are small text files which a website may put on your computer when you first visit a site or page. The cookie will help our website to recognise your device the next time you visit, thus improving your experience of our website. We use the term "cookies" in this policy to refer to all files that collect information in this way.

The Contrarius Australia website uses two types of cookies: session cookies and persistent cookies:

• Session cookies that are temporary and expire at the end of a browser session. The session cookie we use allows us to link your actions during a single browser session so you can use our website most efficiently.
• Persistent cookies that are stored on your equipment until deleted. An example is the cookie used to record if you have accepted the use of cookies on the Contrarius Australia website by continuing to browse as normal. This cookie allows you to browse the Contrarius Australia website in future without being shown our cookie notice.

This cookie policy applies to our website, mobile applications and emails and forms part of our Privacy Policy.

We reserve the right to update this Cookie Policy. Any changes will be posted within this page and become effective immediately. Continued use of our website constitutes your agreement to all such updates. If you require any further information about Contrarius Australia’s use of cookies, please contact us at investorservices@contrarius.com.au.

Third Party Analytics

From time to time, the Contrarius Australia website may use web analytics service providers, for instance Google Analytics, to help Contrarius analyse how users use the website. Third-party cookies from Google are used in these instances which allows us to recognise, measure and track users of the website. The information collected includes the number of visitors to the website, where visitors have come to the website from and the pages they have visited. This helps us improve the way the website works, for example, by determining whether visitors can find information easily or by identifying aspects of the website that are of the most interest to them.

More information on “How Google uses data” can be found here: https://policies.google.com/technologies/partner-sites

Information concerning the terms and conditions of use and data privacy can be found here: https://marketingplatform.google.com/about/analytics/terms/gb/

Blocking Cookies

You can choose to accept or decline the usage of cookies by adjusting your browser settings. Cookie settings typically are found in the ‘Options’ or ‘Preferences’ menu of your browser. You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available here: https://tools.google.com/dlpage/gaoptout?hl=en-GB

However, if you decline the use or prevent the usage of cookies on your browser, you may encounter problems browsing our website.

For more information about cookies and how cookie regulation affects you, please visit: http://ico.org.uk/for_the_public/topic_specific_guides/online/cookies.

Contrarius Investment Advisory Pty Ltd

ABN 48 618 145 449 AFSL No. 506315

Who is Contrarius Australia?

Contrarius Australia is an Australian incorporated company with its main office in Sydney. Contrarius Australia is a member of the Contrarius Group, a global fund manager which was established in 2008. The Contrarius Group has offices in Australia, Bermuda, Jersey (Channel Islands), South Africa and the United Kingdom. Additional information about the Contrarius Group is available at www.contrarius.com.au.

How can we be contacted?

Contrarius Australia can be contacted by:

Financial services provided by Contrarius Australia

When providing financial services under its AFSL, Contrarius Australia acts on its own behalf as a financial services licensee. Contrarius Australia is in the business of asset management and is authorised under its AFSL to (i) provide general financial product advice for; and (ii) deal in a financial product by applying for, acquiring, varying or disposing of a financial product on behalf of another person, in respect of the following classes of products:

• deposit and payment products;
• derivatives (restricted to the management of financial risk);
• foreign exchange contracts (restricted to the management of financial risk);
• debentures, stocks or bonds issued or proposed to be issued by a government;
• interests in managed investment schemes, excluding investor directed portfolio services; and
• securities.

These financial services may be provided to retail and wholesale clients.

Note: The advice that we provide is general advice only and will not take into account your personal financial objectives, situation or needs. Accordingly, before acting on any advice that we provide to you, please consider the appropriateness of the advice having regard to your personal financial objectives, situation and needs and, if applicable, obtain and consider any PDS issued in connection with the financial products and services that we offer before making a decision to acquire a financial product. If you are seeking financial product advice that takes into account your personal financial situation, you should contact an appropriately licensed financial adviser.

Contrarius Australia is:

• The investment manager for Contrarius Australia Equity Fund (ARSN 664 226 331), and Contrarius Australia Balanced Fund (ARSN 664 224 604) (together the ”Australia Funds”). The Australia Funds are Australian registered managed investment schemes and are open to both retail and wholesale investors. Units in the Australia Funds are issued by the funds’ responsible entity, EQT.
• The distributor of Contrarius Global Equity Fund (Australia Registered) (ARSN 625 826 075) and Contrarius Global Balanced Fund (Australia Registered) (ARSN 664 222 646) (together the “Global Funds”). The Global Funds are Australian registered managed investment schemes managed by Contrarius Investment Management Limited, a member of the Contrarius Group. The Global Funds are open to both retail and wholesale investors. Units in the Global Funds are issued by the funds’ responsible entity, EQT.

The Australia Funds and Global Funds will be referred to together as the Contrarius Australia Funds.

Providing instructions

Instructions on how to invest in, and redeem from, the Contrarius Australia Funds are set out in the relevant Product Disclosure Statement or other disclosure document (“PDS”). Investors who wish to invest in the Contrarius Australia Funds will receive, and should read and understand, the relevant PDS, Target Market Determination (“TMD”) and Reference Guide. The PDS contains important information regarding the relevant terms and conditions, significant risks and the fees and charges that may be payable.

You should consider seeking independent professional financial advice before making a decision to invest in any of the Contrarius Australia Funds

If you appoint your financial adviser as your authorised and/or nominated representative for the relevant Contrarius Australia Fund, then they can make certain transactions and provide instructions to us on your behalf. Please read the relevant PDS for further information.

How Contrarius Australia is remunerated

There are no fees or charges associated with any general financial product advice Contrarius Australia may give you. However, you will incur fees and charges if you decide to invest in the Contrarius Australia Funds, as detailed in each Fund’s PDS.

Investors in the Contrarius Australia Funds may pay a fixed (base fee) and a performance-related fee (performance fee). In acting as the investment manager of the Australia Funds, Contrarius Australia is entitled to receive the base fee and performance fee, as applicable.

In acting as distributor of the Global Funds in Australia, Contrarius Australia is entitled to receive a distribution fee from the Global Funds’ investment manager for the services it provides which will be calculated with indirect reference to the net asset value of the Global Funds at certain intervals.

If you are a client of Contrarius Australia, you may request further particulars of the remuneration Contrarius Australia is entitled to receive within a reasonable time after you have been provided with this FSG and before any financial service identified in this FSG is provided to you.

Benefits for those who refer customers to Contrarius Australia

Our employees, directors and other staff are paid a salary but do not receive any commissions. However, they may be eligible for bonus payments based on their performance in meeting or exceeding performance objectives.

Contrarius Australia does not pay any fees or commissions to any financial adviser that refers clients to Contrarius Australia. If you have invested in the Contrarius Australia Funds through a financial adviser, your financial adviser may separately charge a fee and/or commission.

From time to time, the Contrarius Australia Funds may be made available on fund platforms. To be on such fund platforms, the responsible entity or Contrarius Australia may pay these fund platforms a fee and/or some form of commission as permitted by law.

Other than the above, Contrarius Australia does not pay any fees or commissions to any person or organisation that refers clients to Contrarius Australia.

Related party transactions

We may appoint related parties on an arm’s length basis, having regard to our obligation to manage conflicts of interest under the Corporations Act 2001. Contrarius Group companies receive fees on normal commercial terms for the services they provide in connection with any of the products where we are the investment manager or distributor.

We may also provide services to other Contrarius Group companies and receive fees on normal commercial terms for these services.

Respecting your privacy

In order to administer its customer relationships and provide its customers with appropriate services, Contrarius Australia needs to collect personal information. Contrarius Australia respects your privacy and has systems and processes in place to protect your personal information.

For details on how we handle your personal information, please read our Privacy Policy that can be obtained from our website, www.contrarius.com.au, or by contacting us.

Conflicts of interest

Potential and actual material conflicts of interest may arise during activities carried out. We have policies and processes in place to manage conflicts of interest.

From time to time, Contrarius Australia directors may hold interests in shares or invest in financial products.

Professional indemnity insurance

Contrarius Australia has professional indemnity insurance arrangements that satisfies the requirements of section 912B of the Corporations Act 2001 (Cth) in regard to compensation arrangements. Subject to its terms and conditions, the policy provides cover for civil liability resulting from third party claims concerning the financial services provided by Contrarius Australia. The policy covers the conduct of current and former Contrarius Australia staff (where such staff were working under Contrarius Australia’s direct control and supervision).

Resolving your complaints

Contrarius Australia endeavours to resolve all complaints in a satisfactory and timely manner. If you have an enquiry or wish to make a complaint, please contact us on:

Contrarius Australia will seek to acknowledge your complaint within 24 hours (or one business day) of receiving it. Contrarius Australia will consider and seek to resolve your complaint as soon as possible. Should the complaint be expected to take longer than 30 days, you will be kept informed of its progress. You can either decide to wait for our internal process to complete or refer your complaint to AFCA.

If you are not satisfied with our response to your complaint, you may lodge a complaint with the Australian Financial Complaints Authority (“AFCA”). Contact details are:

The external dispute resolution body is established to assist you in resolving your complaint where you have been unable to do so with us. However, it’s important that you contact us first. Contrarius Australia’s AFCA membership number is 41037.

This Financial Services Guide is dated 31 January 2023.

This statement has been prepared by Contrarius Investment Advisory Pty Limited (ABN 48 618 145 449, AFSL No. 506315) (“Contrarius Australia”, “we”, “us”, “our”). At Contrarius Australia our objective is to create long-term wealth for our investors through superior long-term investment performance. We believe that long-term performance is driven by the consistent application of a sound investment philosophy. The key characteristics of our investment philosophy are that it is contrarian, valuation based, long-term and based on proprietary fundamental research.

When investing on behalf of the members of the funds for which we are the investment manager, our overriding objective is to act in the best interest of the Funds. A prerequisite for a sound investment philosophy is that it is sustainable. Our research efforts are directed to uncover companies that are trading below their underlying intrinsic value. The focus is on the long-term value of a business rather than short-term sentiment and earnings outlook. As part of our bottom-up research process, we consider a range of factors that might affect a company’s intrinsic value. These factors include environmental, social and governance (”ESG”) issues.

As long-term investors, it is critical for us to understand the full range of factors that might affect a company’s business and share price performance. While there is scope for investors to have diverse views about ESG matters, we believe there is a broad consensus that a company that acts in a way that damages the environment or is morally or socially irresponsible will eventually undermine its own profitability. We believe that by performing rigorous, fact-based research that carefully seeks to consider risks, including relevant ESG related risks, we are able to maximise the chances that we can successfully implement our contrarian, valuation-based and long-term investment philosophy in a sustainable manner.

We select investments following detailed proprietary research. We have a designated ESG analyst (with the necessary back-up resources) who prepares and presents ESG reports for companies to be discussed at investment policy group meetings. Investment policy group meetings are where a fundamental investment policy group report is presented by the investment analyst for a company. The investment policy group report also addresses various risks considered relevant to the investment case (including ESG related risks). The investment policy group meeting discusses the investment merits of individual companies and then votes on the companies’ attractiveness versus the market and assigns an overall risk rating to the company. The separate ESG report is presented and discussed prior to voting on a share. ESG considerations are taken into account to the extent that they may have a material impact on the long-term financial value of an investment. Shares may not typically be automatically excluded from our investable universe purely as a result of ESG factors and the Funds may invest in shares with a potentially higher exposure to ESG risks where it is believed the potential return outweighs the risks identified. The portfolio of any fund may therefore contain shares of companies that are not considered to have strong ESG characteristics.

The incorporation of responsible investing in our research effort extends to our voting at shareholder meetings. We use our own research and make voting decisions without the use of external service providers. Our overriding objective is to act in the best interest of the Funds by voting in support of proposals that will further the long-term value of the companies that the Funds are invested in. When voting at shareholding meetings, we consider all the aspects of a proposal being put to the vote – including relevant ESG issues. We are mindful to not follow a prescriptive set of rules for proxy voting as this could restrict our ability to act in the Funds’ best interest. Our historical proxy voting records are made available quarterly on our website.

Other than as referred to below, our fundamental research process does not typically include engagement with management or other representatives of our investee companies. We generally believe that managements’ actions speak louder than words when assessing the merits of an investment and the quality of management. Shareholder engagement may, on occasion, also place the Fund in a position where it would not be able to trade in a share, sometimes for lengthy periods. Furthermore, given the publicly available information on companies today (including transcripts and recordings of results, conferences, presentations, investor Q&A’s and detailed filings and company reports), engaging with investee companies does not typically add particular value to the investment decision. However, as part of our approach to responsible investing, there are occasions where we engage with companies that the Funds are invested in with regards to ESG related matters. Such engagements may be for various reasons, including influencing corporate practice on ESG issues, encouraging improved ESG disclosure or gaining a better understanding of ESG strategy. Our engagement is based on a consideration of what is in the best interests of the Funds for which we are the investment manager and subject to applicable laws and regulations in the relevant jurisdiction.

Contrarius is a signatory to the United Nations-supported Principles for Responsible Investment.

What to do if you are unhappy with our service

Contrarius Investment Advisory Pty Limited (ABN 48 618 145 449, AFSL 506315) (“Contrarius Australia”, ”we”, “us” or “our”) endeavours to resolve all complaints in a satisfactory and timely manner. If you have an enquiry or wish to make a complaint, please contact us on:

To help us investigate and resolve your complaint effectively, please provide us with the following information:

• your full name, address and contact phone number(s);
• a description of your complaint;
• any additional documentation or information that may support your complaint and assist us to resolve it; and
• how you would like your complaint to be resolved.

If you need assistance to make a complaint, we will accept complaints made by someone on your behalf, such as your financial or legal adviser, a member of your family or a friend.

How will your complaint be addressed?

We will seek to resolve your complaint at the first point of contact. If this is not reasonably possible, we will acknowledge your complaint within 24 hours (or one business day) of receiving it, and you will receive the name of the responsible individual who will work to resolve your complaint.

Investigating and resolving your complaint

We are committed to investigating your complaint in a satisfactory and timely manner. If we require further information, we will contact you. Once we have collected all required information about the complaint, we will conduct our investigation. When we have completed our investigation, we will write you to explain our findings and the steps we propose to take.

We aim to resolve your complaint as soon as possible, generally where possible within 14 business days. If we are not in a position to resolve it within this timeframe, we will provide a response to your complaint no later than 30 calendar days after receiving it.

Closing complaints

Generally, if we close your complaint within 5 business days after receipt, we will not provide a formal written response to you. This may be the case if we have resolved the complaint to your satisfaction, or if we have given you an explanation and consider that no further action can reasonably be taken by us to address the complaint.

What if your complaint is not resolved?

If you are not satisfied with our response to your complaint, you may lodge a complaint with the Australian Financial Complaints Authority (“AFCA”). AFCA is the external dispute resolution scheme established by the Commonwealth Government to deal with complaints about financial services providers from individuals and small businesses. AFCA’s services are provided at no cost to you.

The external dispute resolution body is established to assist you in resolving your complaint where you have been unable to do so with us. However, it’s important that you contact us first. Contrarius Australia’s AFCA membership number is 41037.

AFCA’s contact details are outlined below:

Questions

If you have any questions about our complaints process, please contact us at investorservices@contrarius.com.au.

The Contrarius Group Companies (“Contrarius”, “us” or “we”), understand that your privacy is important to you. Contrarius may process your personal data in their capacity as ‘data controllers’. We are committed to respecting your privacy and protecting your personal data. This Privacy Notice (“Privacy Notice”) describes how Contrarius collects, uses, discloses and protects your personal data, and your rights in relation to the personal data it holds.

The funds for which CIML is the appointed investment manager may have their own privacy notices, which set out how each fund and its delegates and their affiliates collect, use, disclose and protect the personal data of investors and potential investors in the fund. The relevant funds’ privacy notice can be accessed on the Contrarius website.

Contrarius will process your personal data in accordance with this Privacy Notice, unless such processing conflicts with the requirements of applicable law, in which case, applicable law will prevail. We may amend this Privacy Notice from time to time, to reflect any changes in the way that we process your personal data. This Privacy Notice supersedes any previous version of it which you may have had sight of.

By submitting your personal data to us, you acknowledge that:

• You have read and understood this Privacy Notice and agree to the use of your personal data as set out herein.
• Your personal data may be transferred and processed worldwide, including countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice.
• All of your representations made when agreeing to the terms of use of the website to establish a user profile for the website are true and correct to the best of your knowledge and belief.

What information do we collect?

You are not required to provide any personal information on the public areas of the website; however, you may choose to do so in order to register a user profile to obtain access to certain parts of the website or when contacting us.

Contrarius may collect a range of information about you. This could include:

• Contact information including first name, last name, telephone and fax numbers, e-mail address;
• Personal characteristics such as date of birth and country of birth;
• Government-issued Identification such as passports, national identity cards or tax identification numbers;
• Where you have been granted access to protected parts of our website, your log in information;
• In addition to the information you knowingly provide, we may collect certain technical information, including your Internet Protocol (IP) address used to connect your computer to our website. An IP address is an assigned number similar to a telephone number, which allows your computer to communicate over the internet.
• Data from third parties during the investment process. This may include fraud and anti-money laundering (“AML”) checks, know your customer (“KYC”) screening and checks required due to sanctions and anti-terrorism laws.

This list is not exhaustive and Contrarius may collect more personal data where it is required.

Sensitive personal data is a subset of personal data and includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, as well as other categories as prescribed by law. We do not seek to obtain such data unless permitted to do so by applicable laws.

Why does Contrarius process personal data?

We collect and use your data in order to provide our services to you, to communicate with you about them, to comply with our legal obligations or when necessary for the purposes of our legitimate interests in effectively managing our business operations.

Who has access to data?

Your personal data may be shared within the Contrarius Group or with certain third parties for the purposes set out above. We maintain processes designed to ensure that any processing of personal data by the Contrarius Group entities or third party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your personal data.

In addition, Contrarius and/or the third parties may be required to disclose your personal data to the extent required by relevant regulatory, tax or foreign exchange authorities or law enforcement officials.

We will not sell your personal information or share it with third parties for use in marketing their products and services.

We may transfer your personal data outside the European Economic Area

Contrarius maintains physical, electronic and procedural safeguards to protect your non-public personal information. Even though we have taken significant steps to ensure that your personal information is not misused, you should know that we cannot fully eliminate security risks associated with personal information. The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may be processed by individuals operating outside of the EEA who work for the Contrarius Group. This could include transfers of personal data to Jersey, Bermuda, Australia, South Africa, the UK and the USA. Certain countries may have different data protection standards to those which apply in the EEA. Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA in compliance with data protection law.

How does Contrarius protect data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

For how long does Contrarius keep data?

The retention period will be determined by the purpose for which we are using your personal data and any laws or regulation that may set a minimum or maximum period for which we have to keep your personal data.

Your rights

As a data subject, you have a number of rights.

You can:

• access and obtain a copy of your personal data on request;
• require Contrarius to change incorrect or incomplete data;
• require Contrarius to delete of stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
• object to the processing of your data.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

You can find out more about your rights under data protection legislation at www.jerseyoic.org.

If you would like further information on how Contrarius uses your personal data, the exercise of any of the rights listed above or have a complaint, you may contact privacy@contrarius.com.

This Privacy Notice took effect on 30 May 2023.

Cookies Policy

The use of cookies

We use cookies and similar tools on our website to improve its performance and enhance user experience. Cookies are small text files which a website may put on your computer when you first visit a site or page. The cookie will help our website to recognise your device the next time you visit, thus improving your experience of our website. We use the term "cookies" in this policy to refer to all files that collect information in this way.

The Contrarius website uses two types of cookies: session cookies and persistent cookies:

• Session cookies that are temporary and expire at the end of a browser session. The session cookie we use allows us to link your actions during a single browser session so you can use our website most efficiently.
• Persistent cookies that are stored on your equipment until deleted. An example is the cookie used to record if you have accepted the use of cookies on the Contrarius website by continuing to browse as normal. This cookie allows you to browse the Contrarius website in future without being shown our cookie notice.

This Cookie Policy applies to our website, mobile applications and emails and forms part of our Privacy Notice.

We reserve the right to update this cookie policy. Any changes will be posted within this page and become effective immediately. Continued use of our website constitutes your agreement to all such updates. If you require any further information about Contrarius’ use of cookies, please contact us at clientservice@contrarius.com.

Third Party Analytics

From time to time, the Contrarius website may use web analytics service providers, for instance Google Analytics, to help Contrarius analyse how users use the website. Third party cookies from Google are used in these instances which allows us to recognise, measure and track users of the website. The information collected includes the number of visitors to the website, where visitors have come to the website from and the pages they have visited. This helps us improve the way the website works, for example, by determining whether visitors can find information easily or by identifying aspects of the website that are of the most interest to them.

More information on “How Google uses data” can be found here: https://policies.google.com/technologies/partner-sites

Information concerning the terms and conditions of use and data privacy can be found here: https://marketingplatform.google.com/about/analytics/terms/gb/

Blocking Cookies

You can choose to accept or decline the usage of cookies by adjusting your browser settings. Cookie settings typically are found in the ‘Options’ or ‘Preferences’ menu of your browser. You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available here: https://tools.google.com/dlpage/gaoptout?hl=en-GB

However, if you decline the use or prevent the usage of cookies on your browser, you may encounter problems browsing our website.

For more information about cookies and how cookie regulation affects you, please visit: http://ico.org.uk/for_the_public/topic_specific_guides/online/cookies.

1. Introduction

   At Contrarius our objective is to create long-term wealth for our investors through superior long-term investment performance. We believe that long-term performance is driven by the consistent application of a sound investment philosophy. The key characteristics of our investment philosophy are that it is contrarian, valuation based, long-term and based on proprietary fundamental research.

   When investing on behalf of our fund investors, our overriding objective is to act in the best interest of the Funds. A prerequisite for a sound investment philosophy is that it is sustainable. As long-term investors, it is critical for us to understand the full range of factors that might affect a company’s business and share price performance. While there is scope for investors to have diverse views about ESG-related matters, we believe there is a broad consensus that a company that acts in a way that damages the environment or is morally or socially irresponsible will eventually undermine its own profitability. We believe that by performing rigorous, fact-based research that carefully seeks to consider risks, including relevant ESG-related risks, we are able to maximise the chances that we can successfully implement our contrarian, valuation-based and long-term investment philosophy in a sustainable manner.

   Contrarius is a signatory to the United Nations-supported Principles for Responsible Investment (‘PRI’). We have employed the PRI as a guiding framework for developing our Responsible Investing Policy.

   This Policy provides an overview of our approach to responsible investing for the Contrarius Funds and covers how we deal with issues and risks relating to environmental, social, and governance (‘ESG’) matters.

2. Integration of Responsible Investing

   Investment Process

   As part of our investment philosophy and process, we select investments following detailed proprietary research. Our research efforts are directed to uncover companies that are trading below their underlying intrinsic values. The focus is on the long-term value of a business rather than short-term sentiment and earnings outlook. As part of our bottom-up research process, we consider a range of factors that might affect a company’s intrinsic value. These factors include environmental, social and governance (‘ESG’) issues.

   Investment policy group meetings are where a fundamental investment policy group report is presented by the investment analyst for a company. The investment policy group report also addresses various risks considered relevant to the investment case (including ESG related risks). The investment policy group meeting discusses the investment merits of individual companies and then votes on the companies’ attractiveness versus the market and assigns an overall risk rating to the company.

   We have a designated ESG analyst (with the necessary back-up resources) who prepares and presents an ESG report for each company discussed at investment policy group meetings. These separate ESG reports are presented and discussed prior to voting on a share. Incorporation of ESG-related risks and opportunities in both investment policy group reports by investment analysts and separate ESG reports prepared by a designated ESG analyst provides for the identification and assessment of these factors to be considered as part of the vote by the policy group meeting and, among other considerations, are incorporated into the risk rating assigned to the company and the resulting maximum position size of that share that may be purchased by the Funds.

   ESG information is held within centralised databases or tools, and accessible by all relevant staff for ongoing analysis of investments.

   Screening and Exclusions

   Negative screens and broad ESG-related exclusions do not form part of our investment philosophy or fundamental research process. Contrarius believes that screening out investments purely on the basis of ESG-related metrics are not in the best interest of the Funds’ investors.

   Contrarius’ approach to responsible investment includes the integration of ESG considerations into the investment process, and the Contrarius Funds may invest in securities with potentially higher exposure to ESG risks where it is believed the potential return outweighs the risks identified.

   Review and Monitoring

   Our investment analysts conduct ongoing monitoring of individual securities within the investable universe. This ongoing monitoring includes the consideration of relevant ESG-related matters that may impact our assessment of a security’s fair value. A designated ESG analyst collaborates closely with investment analysts and regularly monitors securities within the investable universe utilising third-party ESG data in addition to ongoing internal ESG research, providing an additional input that assists with investment decisions.

   In addition to the monitoring of individual securities, the Funds’ portfolio exposures are monitored on an ongoing basis. This portfolio review includes an assessment of exposures to material ESG-related risks and assists in informing the overall portfolio construction process.

3. Proxy Voting

   The incorporation of responsible investing in our research effort extends to our voting at shareholder meetings. Contrarius considers the exercise of proxy voting as central to its stewardship responsibilities. Our Proxy Voting Policy details how proxy voting is directed at Contrarius and sets out the process and procedures taken in relation to resolutions put forward at annual general meetings and extraordinary general meetings. This section of the Responsible Investing Policy should be read in conjunction with the Proxy Voting Policy, available on our website.

   Our overriding objective is to act in the best interests of the Funds by voting in support of proposals that will further the longterm value of the companies that the Funds are invested in. We aim to vote on all resolutions wherever possible and practical, taking into consideration local market and operational requirements. We use our own research and make voting decisions without the use of external service providers.

   When voting at shareholder meetings, we consider all the aspects of a proposal being put to the vote, including relevant ESG issues. We are mindful to not follow a prescriptive set of rules for proxy voting as this could restrict our ability to act in the Funds’ best interests.

   All voting actions are recorded in an internal register and proxy voting details are reported publicly on a quarterly basis.

4. Engagement

   Our fundamental research process does not typically include engagement with management or other representatives of our investee companies. We generally believe that managements’ actions speak louder than words when assessing the merits of an investment and the quality of management. We are also cognisant that engagement may, on occasion, place the Funds in a position where they may be restricted in trading a share, sometimes for lengthy periods. Furthermore, given the publicly available information on companies today (including transcripts and recordings of results, conferences, presentations, investor Q&A’s and detailed filings and company reports), engaging with investee companies does not typically add particular value to the investment decision. However, as part of our approach to responsible investing, we recognise our responsibility as stewards of our investors’ capital and that engagement on ESG-related matters is, on occasion, an effective component of our investment process.

   Our engagement activities are guided by our consideration of what is in the best interests of the Funds we manage for investors and subject to applicable laws and regulations in the relevant jurisdiction. Our engagement on ESG-related matters includes complying with the engagement requirements of the EU Shareholder Rights Directive.

   Where we conduct engagement activities with our investee companies, we prioritise our efforts and resources generally on areas that we believe may provide the most positive impact on the Funds. We generally conduct our engagement activities privately, but may consider public engagement, where appropriate, among other methods of escalation. Our engagement activities with investee companies may be for various reasons, including influencing corporate practice on ESG-related issues, encouraging improved ESG disclosure or gaining a better understanding of ESG strategy.

   We track our engagements in an internal register to facilitate monitoring, review and reporting on our engagement efforts.

5. Reporting

   As a signatory to the PRI, we have made a commitment to transparency and recognise its importance in creating higher standards for responsible investment practices and for the wider financial market. We will make the PRI’s Transparency Report and the PRI Assessment Report available to investors upon request.

   We report our proxy voting activity on a quarterly basis. These reports provide a summary of our voting activity during the period in addition to individual details of how we voted on each resolution. These reports are made available on our website and on request.

   Our annual Responsible Investing and Stewardship Report constitutes the annual reporting on Contrarius’ engagement and voting activities, as required by the Shareholder Rights Directive II (Directive (EU) 2017/828). As part of this report, we disclose information and examples of our engagement activity together with a summary of our proxy voting activity and a description of the most significant votes during the period. In this report we also make available relevant climate-related disclosures for the benefit of current and prospective investors in the Contrarius Funds. This report is made available on our website and on request.

6. Related Policies and Documents

   The following documents, as well as this Policy, are available on our website (www.contrarius.com):

   • Shareholder Rights Engagement Policy;
   • Conflicts of Interest Policy;
   • Proxy Voting Policy;
   • Quarterly Summary and Detailed Proxy Voting Records; and,
   • Responsible Investing and Stewardship Report.