Goldleaf Australian Asset Management Limited (GAAML)

Sustainable Investment Policy

1. Purpose

This document is designed to set out investment expectations for GAAML and the investment mandates it manages. GAAML acknowledges that it seeks to maximise risk adjusted return for its investors within a framework of sustainable and responsible investment.

GAAML understands that a sustainable economy and healthy community are importantto long-term wealth creation for our investors. Investing sustainably and analysing Environmental, Social and Governance (ESG) risks are strongly aligned with our purpose as investment managers.

This Sustainable Investment Policy (‘Policy’) explains how GAAML incorporates ESG analysis in its investment process. The Policy details:

• 2 – Introduction: What is Sustainable Investment?
• 3 – GAAMLmethod of managing ESG risks:
• ESG factors and risks
• Integrating ESG into our investment decisions
• Corporate governance analysis
• Section 4 – Our governance process for sustainable investing and ESG.

2. Introduction: What is Sustainable Investment?

Sustainable or Responsible Investment factors in long-term impacts on people, society and the environmentwhen making and managing investments. GAAML believes that these factors when coupled with financial analysis will lead to superior long-term investment outcomes for our clients.

2.1 ESG integration

ESG integration involves ensuring that material Environment, Social and Governancerisks are appropriately analysed and considered in GAAML’s investment process. By taking into account ESG risks such as climate change, occupational health and safety, and corruption GAAML is better able to optimise its risk-adjusted long-term returns. Ignoring ESG risks increases the potential to experience adverse economic consequences at some point, which in turn will negatively impact investment value.

Examples of ESG risks include:

GAAML can implement its Sustainable Investment Policy by;

I. reducing investments where ESG risks are increasing

II. engaging with businesses to promote positive change

III. excluding investment in excessive ESG risk areas

2.2 Business engagement

Where practical GAAML undertakes to engage with company management to improve practices in relation to ESG issues which are important to long-term investor outcomes. In some cases poor ESG credentialed businesses can benefit greatly from improved ESG practices and deliver strong investment returns.

2.3 Exclusions

Exclusions refers to businesses or industries that are deemed unfit for investment. This is a last resort and defines companies reasonable expected to cause harm such as human death, irreparable environmental damage and gross inequality. Excluded companies must also show no prosect of positive ESG change.

2.4 Impact investing

This involves achieving a sustainability-related goal that typically has a positive environmental or social outcome whilst also generating an attractive risk-adjusted returns. Investments in renewable energy, pollution reduction or affordable housing are examples.

3. GAAML approach to Sustainable Investing

3.1 ESG beliefs and key principles

GAAML’s main role is to deliver the best risk-adjusted returns to its investors. Incorporating ESG considerations as part of our investment process makes our investment decisions more robust and assists GAAML to achieve better investment outcomes and mitigate risk. .Our key principles are:

• Failing to consider material ESG issues means being unaware of important business and investment risks.
• To achieve the best investment outcomes GAAML acknowledges that some poor but improving ESG outcome businesses may be underpriced, and some highly ranked but deteriorating ESG outcome businesses may be overpriced.
• We can assist a virtuous investment circle by assisting business, where practical, to improve their ESG outcomes. As an investor we benefit from lessening ESG risks.

To that end Goldleaf Australian Income Fund Limited is a signatory to the United Nations Principles for Responsible Investment (UNPRI)

3.2 How ESG is incorporated in our investment process

a) Investment research:

• Where possible we assess the relative ESG risks of the business we may invest in and the industry in which it operates.
• We decide whether the ESG risks could effect our investment return.

b) Investment monitoring:

• We review businesses ESG processes as part of our regular investment due diligence.
• Investment reviews include exploring where ESG risks have been identified, realised or avoided.

3.3 Corporate governance and proxy voting

Corporate governance

GAAML believes that better corporate governance by the companies to which we provide finance leads to better investment returns. Higher transparency and better governance controls reduce the risk of default.

Proxy voting

Proxy voting is where a vote is cast on behalf of a shareholder. Shareholder voting can directly influence the ESG behaviour of companies, their boards and management.

Although GAAML rarely holds equity in listed entities it undertakes to vote in accordance with its philosophy od minimising ESG risks and positively influencing ESG outcomes in the companies in which it invests.

4. Governance Process

GAAML is responsible for ESG policy across all its funds. This includes:

• Ensuring that ESG issues are appropriately considered throughout the investment process.
• Ensuring that this Policy is implemented

• Undertaking a six-monthly review to ensure that:
• ESG issues (where applicable) within portfolios have been managed in accordance with the principles in this Policy, and
• ESG risk factors within portfolios have been balanced with other risk factors consistent with achieving investment objectives.
• Reviewing the Policy annually.

The GAAML Investment Committee are responsible for the implementation and continued evolution of the Policy.