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Investment Philosophy Document Important Information It is important to realise that this document does not take into account your individual circumstances, requirements and objectives it is a generic outline of our approach, beliefs and considerations when we consider the investment portfolio appropriate for your individual circumstances. To understand the investment portfolio we have recommended for your individual circumstances, you should refer to your Statement of Advice.

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Page 1: Investment Philosophy Document - McCarthy …mccarthyfinancial.com.au/.../07/Investment-Philosophy.pdfInvestment Philosophy Document Important Information – It is important to realise

Investment Philosophy Document

Important Information –

It is important to realise that this document does not take into account your individual circumstances, requirements and objectives – it is a generic outline of our approach, beliefs and considerations when we consider the investment portfolio appropriate for your individual circumstances. To understand the investment portfolio we have recommended for your individual circumstances, you should refer to your Statement of Advice.

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What McCarthy Financial do :-

Kevin McCarthy is authorised by GWM Adviser Services Limited to provide financial advice in relation to: · Wealth Accumulation · Income & Asset Protection · Tax Strategies · Superannuation · Retirement & Redundancy Planning · Estate Planning · Social Security · Debt Management and to provide advice and deal in the following financial products: · Basic Deposit Products · Non-basic Deposit Products · Non-cash Payment Products · Derivatives · Government Debentures, Stocks or Bonds · Life Products – Investment Life Insurance · Life Products – Life Risk Insurance Products · Managed Investment Schemes, including Investor Directed · Portfolio Services (IDPS) · Retirement Savings Account Products · Securities and Superannuation

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Table of Contents

Table of Contents ....................................................................................................... 1

Introduction ................................................................................................................ 4

1. Our Investment Beliefs ........................................................................................ 5

2. Constructing Investment Portfolios ...................................................................... 6

2.1 Determining an Appropriate Asset Allocation ............................................... 7

2.2 Constructing your Portfolio in line with our beliefs ...................................... 14

3. Implementing Your Portfolio .............................................................................. 29

4. Ongoing Performance & Review ....................................................................... 41

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Introduction

This document details the approach we use when we construct your investment portfolio in order to achieve your goals and objectives.

The document details our investment beliefs and the philosophy behind the approach we use in building our recommendations. Overall, our purpose is to outline how we aim to achieve your goals with the greatest certainty and lowest risks.

Your goals and objectives we are aiming to achieve will be outlined in your Statement of Advice (SoA).

We will continue to use this investment philosophy as we review your portfolio and we assess the progress towards your goals and objectives.

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1. Our Investment Beliefs

When we build and review your investment portfolio, we base our recommendations on a number of investment beliefs, which are fundamental to the way we operate our business.

We believe:

One of the best ways to grow wealth is to use exceptional investment managers which apply their skills, resources and research to build portfolios of individual investments.

Deep research is the only reliable way to identify exceptional investment managers. Brand and past performance are unreliable predictors of future performance.

Diversification is one way to provide more consistent investment outcomes.

A long-term approach should be used if your financial goals are long-term

Efficient implementation reduces the costs of running a portfolio.

As these beliefs are central to our recommendations, they are regularly referred to throughout this document as we outline our approach to creating your investment portfolio.

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2. Constructing Investment Portfolios

We use a 2 stage process when we build investment portfolios:

Stage 1 involves identifying an appropriate asset allocation for your goals, timeframe and risk tolerance. History and research has shown that asset allocation is responsible for over 90% in the variation in returns between portfolios, and is therefore one of the most important decisions we make for your portfolio1. We aim to select an asset allocation that is likely to achieve the returns required to achieve your desired goals, with the lowest amount of volatility possible.

Stage 2 involves constructing your portfolio, or deciding how to invest the different allocations to each asset class, in order to apply our investment beliefs. This process helps to maximise the returns and manage the risks associated with investing in each individual asset class that is appropriate for your goals, timeframe and risk tolerance.

1 Brinson et al, Determinants of Portfolio Performance II, Financial Analysts Journal, Jan/Feb 1995

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2.1 Determining an Appropriate Asset Allocation

The most important decision for your investment portfolio is your recommended asset allocation. This is because studies have shown that your chosen asset allocation is responsible for more than 90% in the variability of returns between portfolios.

The diagram below illustrates the process we go through to determine the asset allocation for your investment portfolio:

Identify Lifestyle Goals

& TimeframeIdentify Rate of

Return Required

Potential Asset

Allocation

Does the asset allocation

align with the risk

tolerance?

Recommended Asset

Allocation

Acceptable

Unacceptable

This section goes through each of these steps to provide us with the recommended asset allocation for your investment portfolio.

1. Your lifestyle goals and timeframe

The investment timeframe you have for you to achieve your lifestyle goals and objective is one of the main determinants in your asset allocation, and primarily the allocation between the main classification of different types of assets (ie defensive and growth assets). The shorter your timeframe, the more your portfolio should be exposed to defensive assets to reduce volatility; and similarly the longer your timeframe, the more your portfolio can recover from volatility and therefore can be more exposed to growth assets.

Your agreed investment timeframe to achieve your lifestyle goals will be outlined in your Statement of Advice.

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2. Rate of Return Required

In order to achieve their investment and lifestyle goals, some clients are likely to need to achieve a return greater than inflation. Inflation reduces the spending power of your money and not generating a return above inflation may result in you not being able to afford your desired lifestyle. Typically, the higher the rate of return required, the higher the risk you need to be willing to take to achieve your lifestyle goals and objectives.

The average return above inflation that we determine to achieve your goals and objectives will be outlined in your Statement of Advice. However, there will be some years where the actual return will be lower, even negative, and some years higher. Uncertainty in future investment returns means that the actual performance of your portfolio may differ from our straight line financial modelling that will be outlined in your Statement of Advice, and can therefore impact on your financial outcome.

3. Potential Asset Allocations

Once we have identified your investment timeframe and your required rate of return, we can determine which potential risk profile or asset allocation may be appropriate to achieve your lifestyle goals and objectives.

The typical risk profiles or asset allocations that we use for clients are outlined below:

Risk Profile / Asset Allocation

Description

59% Int‟l and 41% Aust Shares

This profile may be appropriate for investors with an investment horizon of at least five to seven years and a high risk tolerance. The full exposure to growth assets means that the portfolio will have greater fluctuations in value than portfolios with allocations to defensive assets. This strategy suits investors aiming to achieve capital growth over a long term timeframe and are comfortable with a share portfolio dominated by international shares. Given the 100% exposure in growth assets, investors will experience significant volatility.

15% Defensive, 85% Growth

This profile may be appropriate for investors with an investment horizon of at least five to seven years and a moderate to high risk tolerance, seeking a high exposure to growth assets. The bias to growth assets means that the portfolio will have greater short term fluctuations in value than portfolios with greater allocations to defensive assets. This strategy suits investors aiming to achieve capital growth over a long term timeframe and who want slightly lower volatility than that provided by a 100% growth asset mix. Given the 85% exposure to growth assets, investors will experience significant volatility.

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Risk Profile / Asset Allocation

Description

30% Defensive, 70% Growth

This profile may be appropriate for investors with an investment horizon of at least five years and a moderate risk tolerance. The bias to growth assets means that the portfolio will have greater short term fluctuations in value than portfolios with greater allocations to defensive assets. This strategy suits investors aiming to achieve capital growth over a medium to long term timeframe and who want lower volatility than that provided by a 100% growth asset mix. Given the 70% exposure to growth assets, investors will experience volatility.

50% Defensive, 50% Growth

This profile may be appropriate for investors with an investment horizon of at least three years and a low to moderate risk tolerance. A balanced split between growth and defensive assets means that the portfolio is expected to deliver relatively consistent returns over time. This strategy suits investors aiming to achieve capital growth over a medium term timeframe and who want lower volatility than portfolios with a higher allocation to growth assets. Given the 50% exposure to growth assets, investors will experience some volatility.

70% Defensive, 30% Growth

This profile may be appropriate for investors with an investment horizon of at least three years and a low to moderate risk tolerance. The bias towards defensive assets means that the portfolio is expected to deliver relatively stable returns over time. This strategy suits investors seeking regular income with an opportunity for some growth over a medium term timeframe and who want lower volatility than portfolios with a higher allocation to growth assets.

100% Defensive, 0% Growth

This profile may be appropriate for investors with an investment horizon of at least three years and a low to moderate risk tolerance. The bias towards defensive assets means that the portfolio is expected to deliver relatively stable returns over time. This strategy suits investors seeking higher than cash returns over the medium term.

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4. Your tolerance for risk

While we believe that the achievement of your lifestyle goals and objectives is of the utmost importance, an asset allocation that only reflects these goals and objectives may expose you to an uncomfortable level of investment risk and may lead to a short term loss of capital. For this reason, the final aspect that we undertake is to identify a risk profile (and associated asset allocation) that reflects your investment risk tolerance alone and see whether this is consistent with the proposed asset allocation.

To determine your attitude to risk we have used a series of assumptions and a mathematical model in conjunction with the information provided by you when you completed the Investment Risk Profile section of the Client Profile & Lifestyle Questionnaire. In this questionnaire your attitude to risk is graded on a scale of 1-7, where 1 is the most risk averse and 7 the most risk accepting investor. You should note that the questionnaire is not a scientific or definitive reflection of your attitude to investment risk. However, it is an indication of your current attitude and/or tolerance towards investment risk.

What do we mean by risk? Risk means different things to different investors. For some, investment risk means the likelihood of a loss of capital, while for others it is the level of volatility of an investment, or the risk of an asset not producing enough to live on.

Volatility is used to explain the size and frequency of fluctuations in the value of an investment on a daily, weekly or monthly basis. When we measure the risk of a portfolio, we look at the volatility of the investment.

Volatility and expected return are closely related. In general, the higher the volatility associated with an investment, the higher the return received by investors who accept this volatility. Low volatility investments offer relatively low returns as a reflection of their greater stability. This is called the risk/return trade-off.

How the different asset classes compare The following chart shows the range between the highest and lowest 1year returns for the major asset classes over the past 25 years. As can be seen, the range between maximum and minimum returns increases significantly as the investments move from debt (cash and bonds) towards growth assets (property and shares).

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Range of 1 year returns over the previous 108 years ending 31 December 2008

-40.4%

-27.3%

-39.0%

-19.1%

66.8%70.1% 67.3%

53.8% 56.3%

17.3%11.4% 9.6% 10.0%

5.6% 6.4% 4.6%

0.7%

-24.8%

0

+%

-%

Australian

Equity

Australian

Bonds

Australian

Cash

Source: Calculated by National Corporate Investment Services Limited using data presented in DMS Data Module offered through the Ibbotson

Associates‟ software program EnCorr. Based on copyrighted books by Dimson, Marsh, and Staunton, Triumph of the Optimists, Princeton University

Press, (c) 2002, and Global Investment Returns Yearbook 2003, ABN AMRO/London Business School (c) 2003. All rights reserved. Used with

permission.

Note: Top value is the highest, middle is the average and bottom is the lowest 1 year return observed over the period.

Global Equity

UnhedgedGlobal Equity

Hedged

Global

Bonds

As a result of this greater volatility, growth assets (such as property and shares) are expected to generate a higher long-term return than defensive assets (such as cash and bonds) which have a lower level of volatility. The chart below shows a stylistic representation of the expected return and volatility of the different asset classes:

5 Year Risk and Return Profile, After Inflation*

Domestic Equity

Global equity Hedged

Domestic listed property

Global nominal aggregate

Global equity Unhedged

Emerging markets equity

Unhedged

Private markets Hedged

Domestic cash

Domestic nominal

aggregateInflation

0%

2%

4%

6%

8%

10%

12%

0% 2% 4% 6% 8% 10% 12% 14% 16%

Risk

Retu

rn

Source: MLC Investments, *Base scenario assumptions as at 31 March 2009

Creating a portfolio to maximise returns for a given level of risk In general, most of today‟s portfolios created by investment professionals are based on what is referred to as “Modern Portfolio Theory” – a range of academic research that started in the 1950s. This research came up with the basic theory that investors should create their portfolio by choosing a combination of assets that offers the highest return for their chosen level of risk.

The main premise of Modern Portfolio Theory is that for every level of risk, there is an optimal combination of assets that will maximise returns. Quantitative methods can be used to measure risk and to diversify efficiently across different assets –

Source: MLC Investments Ltd., * Base scenario assumptions as at 31 March 2009

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however it is not the number of securities that matter, but the relationship of each asset to the others (referred to as „correlation‟).

The expected outcome of Modern Portfolio Theory is that there is a unique combination of asset classes that provides the best level of return for every level of risk. By diversifying across asset classes, you can generally achieve better returns for a given level of risk than would be possible for a single asset class – this is benefit of diversification.

The stylistic diagram below illustrates what we are trying to achieve – rather than using a single asset class, by combining different amounts to each asset class (represented along the black line), we can achieve a better return for every level of risk. This is referred to as the „efficient frontier‟.

5 Year Real Risk/Return Efficient Frontier

Risk

Re

turn

Low

Low

High

High

We aim to build our portfolios based on this premise – we construct a diversified selection of asset classes in order to maximise the return for your given level of risk.

An asset allocation for your risk tolerance

Your risk tolerance indicates how aggressive you are willing to be with your asset allocation (into one of the seven risk profiles or asset allocations explained on page 8).

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5. Determining your final asset allocation

The asset allocation that is appropriate for your risk tolerance may or may not be consistent with the asset allocation we have determined is appropriate for your return requirement and investment timeframe.

If it is consistent, then we can construct your investment portfolio with the appropriate asset allocation.

However, if it is not consistent, we need to review your risk tolerance, required rate of return based on your goals & objectives, and/or your investment timeframe to determine the most appropriate course of action for you & your individual circumstances to achieve a final asset allocation for your portfolio. This discussion will be outlined in your Statement of Advice.

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2.2 Constructing your Portfolio in line with our beliefs

Once we have determined an appropriate asset allocation for your portfolio (based on your risk tolerance, investment timeframe and return requirement), we then consider how we should construct your portfolio in line with our investment beliefs, including each of the underlying asset sectors.

We construct your portfolio based on our 5 key beliefs:

One of the best ways to grow wealth is to use exceptional investment managers which apply their skills, resources and research to build portfolios of individual investments.

Deep research is one reliable way to identify exceptional investment managers. Brand and past performance are unreliable predictors of future performance.

Diversification can lead to more consistent investment outcomes.

A long-term approach should be used if your financial goals are long-term

Efficient implementation reduces the costs of running a portfolio.

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1) One of the best ways to grow wealth is to use exceptional investment managers

An exceptional investment manager will have a clear, sound set of investment beliefs.

We believe that deep and disciplined research of individual securities can generate superior outcomes. For this reason we focus on investment managers that have a „bottom-up‟ philosophy that involves constructing investment portfolios out of securities that are anticipated to perform well.

We generally do not utilise investment managers which focus on:

passive indexing that merely mimics index returns

price momentum investing based on buying into an asset with rising prices with the hope that they will be able to sell later for a higher price, or

pure „top-down‟ approaches that assess broad economic trends to identify groups of investments, but do not take the effort to identify the best individual investments within those groups.

The Cost of Investor Mistakes Often, there is a cost the investor pays as a result of trying to pick their own asset classes, investment managers, or securities. For example, in a recent US study, Dalbar (a US based research organisation) found that over the 20 years to 2008 the S&P 500 (a US sharemarket index) returned 8.35% p.a.2 This outperformed the average investor over the same period by almost 7% p.a., as they received only 1.44% p.a. over the same period. That‟s the same as turning a $100,000 investment into $495,000 rather than $133,000 – or a difference of more than $360,000 over 20 years!

Rather than wasting our time & effort trying to be the best investment manager we can (ie by researching & selecting securities), we believe it is a lot better to hire the best investment managers we can find, and let them work to grow your wealth. We believe that the best managers know why they excel, and specialise their business accordingly – only by this are they able to growth wealth for investors.

Skilled investors do not get caught up in the emotion of investing which can often result in investors making silly investment decisions.

Using specialists Skillful investing involves knowing what you are good at, and sticking to it. You don‟t have to be the best at everything, just find and use what you believe are the best.

This typically results in the appointment of managers who specialise in a particular asset class – rather than managers who try to cover all asset classes. The theory

2 Dalbar Inc, “Quantitative Analysis of Investor Behaviour”, 2009.

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behind this is quite simple – it‟s easier to be good at one discipline than a range of them.

Take the example of an Olympic decathlete. They must spread their training, focus and physical strength across ten different events – as opposed to being able to concentrate on one specific discipline. There‟s no doubt a decathlete is an outstanding athlete, but when you compare their performances in each individual event with that of the specialists, it‟s clear an all-rounder cannot compete with individuals who specialise in just one event.

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2) Deep research is one reliable way to identify exceptional investment managers

No single investment manager will be the best performer in a single asset class at all times across different economic and market environments. In fact, there are actually very few firms in any asset class that are skilled investment managers and have a real and sustainable competitive edge. There is ample academic evidence3, in addition to our experience, that clearly shows brand and past performance are not helpful in identifying investment skill.

Therefore, when selecting managers, we want to look beyond past performance. As markets move in cycles, certain market conditions will suit certain types of managers. Even the best managers are likely to experience short-term underperformance if market conditions don‟t suit their investment strategy.

We believe the fundamentals of an investment manager (such as its investment philosophy, investment approach, people and ownership structure) are much better indicators of a manager‟s skill than past performance.

We use a research provider to select skilled investment managers from around the world:

Selected Complementary

Investment

Managers

Sub-set of investment managers

of considerable interest

Global universe of thousands of investment managers

3 For example, see Common Sense on Mutual Funds: New Imperatives for the Intelligent Investor, by

John C. Bogle (2000)

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3) Diversification can lead to more consistent investment outcomes

Diversification is a genuine way of reducing uncertainty without compromising expected future returns. Diversification involves spreading your investment amongst asset classes, investment managers and securities in order to reduce risk and the impact that any single one of these can have on your portfolio.

While most people understand the basic concept of diversification, many still don‟t fully diversify their portfolio. For example, just holding several stocks is not good diversification, especially if they have similar risk factors by belonging to similar industry group, asset classes, or even selected by investment managers using a similar investment process.

To fully utilise the benefit of diversification, we construct your portfolios so that it is diversified in three ways (each of which is described further below):

across asset classes

within asset classes

across investment managers.

(a) Diversification across Asset Classes

As different asset classes (eg shares, property, bonds and cash) perform differently under different economic and market conditions, diversifying across asset classes reduces the impact of downward fluctuations in any one asset class over the short-term, yet still capture the benefits of potentially higher returns of growth assets.

The benefit of diversifying across asset classes is illustrated in the diagram below – you can see that an equally weighted allocation to each of the asset classes produces a more consistent return over time, without compromising the benefit of being exposed to those asset classes (generally growth assets, such as shares and property) that will provide the highest long-term returns.

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Diversification Reduces Volatility Calendar Year Total Returns from 1901 to 2008

-40%

-20%

0%

20%

40%

60%

80%

1901

1904

1907

1910

1913

1916

1919

1922

1925

1928

1931

1934

1937

1940

1943

1946

1949

1952

1955

1958

1961

1964

1967

1970

1973

1976

1979

1982

1985

1988

1991

1994

1997

2000

2003

2006

1 Y

ear

Re

turn

Australian Equity Global Equity (unhedged) Global Equity (hedged) Australian Bonds

Global Bonds (hedged) Australian Cash Equal Weighted Portfolio

Source: Calculated by National Corporate Investment Services Limited using data presented in DMS Data Module offered through the Ibbotson Associates‟ software

program EnCorr. Based on copyrighted books by Dimson, Marsh, and Staunton, Triumph of the Optimists, Princeton University Press, (c) 2002, and Global

Investment Returns Yearbook 2003, ABN AMRO/London Business School (c) 2003. All rights reserved. Used with permission.

When we recommend your asset allocation in your Statement of Advice, we ensure it is diversified across asset classes that are appropriate for your return objective, investment time horizon and risk profile.

(b) Diversification within Asset Classes

Within each asset class you are investing in, we want to ensure your portfolio is diversified across regions, countries, industries and currencies. This approach to investing ensures that your portfolio is not concentrated in a particular region or industry, which helps to reduce the impact of a regional or industry downturn.

Each asset class has its own form of diversification that we consider. The section below outlines the diversification available within the MLC Wholesale portfolios. This only provides an indication of how we consider diversification within asset classes, it does not indicate the diversification available within your particular portfolio that will be outlined in your Statement of Advice.

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Australian Shares

We look to ensure that portfolios are diversified across the major industries, as well as across individual securities. The industry group allocation of the MLC Australian share exposure (as at 30 June 2009) is outlined in the pie chart below.

Australian Equity Strategy

Industry Exposure as at 30 June 2009

2.2%10.3%

8.7%

7.0%

31.1%

4.4%

8.3%

0.2%

19.7%

6.5%

0.7%

0.8%

Cash

Consumer Discretionary

Consumer Staples

Energy

Financials

Health Care

Industrials

Information Technology

Materials

Telecommunication Services

Utilities

OtherSource: MLC Investment Specislists

The top 10 securities within the Australian share exposure (as at 30 June 2009) were:

Australian Share Strategy Industry Weight

BHP Billiton Materials 6.3%

National Australian Bank Financials 5.9%

Australia & New Zealand Banking Group Financials 5.8%

Westpac Financials 5.1%

Telstra Telecommunication Services 4.5%

Commonwealth Bank of Australia Financials 2.7%

Suncorp-Metway Financials 2.5%

Brambles Industrials 2.3%

Origin Energy Energy 2.2%

Woolworths Consumer Staples 2.2%

Source: MLC Investments Ltd.

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Global Shares

We look to ensure that portfolios are globally diversified across countries, major industries and individual securities. The regional exposure of the MLC Global share exposure (as at 30 June 2009) is outlined in the chart below:

Global Equity Strategy

Country Exposure as at 30 June 2009

1.2%

46.3%

8.3%

4.1%

26.9%

9.1%

1.2%

2.9%

Africa

America

Asia

Australia

Europe

Japan

Other

South America

Source: MLC Investment Specialists

The sector allocation of the same exposure (as at 30 June 2009) is outlined in the chart below:

Global Equity Strategy

Industry Exposure as at 30 June 2009

3.3%

9.4%

11.1%

9.4%

15.1%

12.6%

7.6%

11.7%

5.6%

3.7%

1.6%

8.9%

Cash

Consumer Discretionary

Consumer Staples

Energy

Financials

Health Care

Industrials

Information Technology

Materials

Telecommunication Services

Utilities

Other

Source: MLC Investment Specialists

Source: MLC Investments Ltd.

Source: MLC Investments Ltd.

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The top 10 securities within this global share exposure (as at 30 June 2009) were:

Global Share Strategy Country Industry Weight

Johnson & Johnson United States Health Care 1.2%

JP Morgan Chase United States Financials 0.9%

Google United States Information Technology 0.9%

Roche Switzerland Health Care 0.9%

Schlumberger United States Energy 0.9%

Wal-Mart Stores United States Consumer Staples 0.8%

Nestle United States Consumer Staples 0.8%

Microsoft United States Information Technology 0.8%

HSBC Holdings United Kingdom Financials 0.8%

3M United States Industrials 0.8%

Property Securities

We consider the diversification of property exposure across different property sub-sectors, many different countries and hundreds of securities. The property sub-sector allocation of the MLC portfolio (as at 30 June 2009) is outlined in the pie chart below:

Global Property Strategy

Industry Exposure as at 30 June 2009

4.5%

9.3%

0.1%

4.7%

3.2%

8.6%

26.3%

7.6%

28.0%

6.7%

1.0%

Cash

Diversified REITs

Health Care Facilities

Hotels Resorts and Cruise Lines

Industrial REITs

Office REITs

Real Estate Management and Development

Residential REITs

Retail REITs

Specialised REITs

OtherSource: MLC Investment Specislists

Source: MLC Investments Ltd.

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We consider the geographical diversification of property portfolios. For example, the same exposure is diversified across many different countries / regions (as at 30 June 2009), as outlined in the chart below:

Global Property Strategy

Country Exposure as at 30 June 2009

41.2%

9.8%9.0%

19.9%

13.1%

7.0%

America

Asia

Australia

Europe

Japan

Other

Source: MLC Investment Specislists

The top 10 securities in the same property securities exposure (as at 30 June 2009) are indicated in the table below:

Property Securities Country Industry Weight

Hong Kong Land Holdings Singapore Real Estate Management & Development 5.9%

Unibail France Retail REITs 4.6%

Simon Property Group United States Retail REITs 4.3%

Westfield Group Australia Retail REITs 4.1%

Mitsubishi Estate Japan Real Estate Management & Development 3.7%

Avalonbay Comms United States Residential REITs 3.4%

Starwood Hotels United States Hotels Resorts and Cruise Lines 3.3%

Vornado Realty Trust United States Diversified REITs 2.7%

Mitsui Fudosan Japan Real Estate Management & Development 2.5%

Kerry Properties Hong Kong Real Estate Management & Development 2.4%

Source: MLC Investments Ltd.

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Bonds

We also consider the diversification of bond / debt asset or fixed interest asset exposure across different countries and sub-debt asset classes. As at 30 June 2009, the sub-debt asset class exposure of the MLC Wholesale Diversified Debt fund is illustrated in the pie chart below:

Diversified Debt Strategy

Sub-Debt Asset Class as at 30 June 2009

29.9%

19.1%

12.2%

7.6%

28.6%

2.6%

Australian Nominal Bonds

Australian Inflation Linked Bonds

Global Nominal Bonds

Global High Yield

Global Real Return Strategies

Cash

Source: MLC Investment Specislists

As at 30 June 2009, the defensive part of Horizon 4 – Balanced Fund was invested in around 1,500 securities.

(c) Diversification across Investment Managers

Different investment styles excel at different times under different economic and market conditions. By combining managers with different, but complementary, investment styles, your portfolio is likely to have a more consistent return than is possible with a single investment manager.

Source: MLC Investments Source: MLC Investments Ltd.

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Combining Managers Reduces VolatilityExcess Return vs the S&P/ASX 300 (All Ords before 1/4/2000)

Rolling 12 Month Periods - May 1999 to June 2009

-20%

-15%

-10%

-5%

0%

5%

10%

15%

20%

25%

Jun-

00

Sep

-00

Dec

-00

Mar

-01

Jun-

01

Sep

-01

Dec

-01

Mar

-02

Jun-

02

Sep

-02

Dec

-02

Mar

-03

Jun-

03

Sep

-03

Dec

-03

Mar

-04

Jun-

04

Sep

-04

Dec

-04

Mar

-05

Jun-

05

Sep

-05

Dec

-05

Mar

-06

Jun-

06

Sep

-06

Dec

-06

Mar

-07

Jun-

07

Sep

-07

Dec

-07

Mar

-08

Jun-

08

Sep

-08

Dec

-08

Mar

-09

Jun-

09

12

Mo

nth

Ex

ce

ss

Re

turn

vs

AS

X 3

00

50% DFA & 50% JFCP Dimensional Aust Value JF Capital Partners - Bmk based

Source: MERCER, MLC Investments

We diversify portfolios across many managers within each asset sector.

4) A long-term approach should be used

We believe that successful investing is a long-term process. Instead of trying to outguess the market (eg by trading in and out of asset classes and investment managers on a short-term basis) we look to set a target weighting to each asset class and manager based on our long-term expectations. We then maintain these weightings via a disciplined rebalancing process.

Don’t react to short-term performance Some markets, managers or securities may not perform as well as others (and may even go down) from time to time. Successful investors know this is just market noise, and more often than not making changes in response to this noise is likely to destroy value.

In times of negative returns, there is a natural temptation to chase the perceived higher returns from other investment options. Studies show that investors who switch funds to the best performing asset class of the previous year, chasing higher returns, are often worse off than investors who maintain their investment in a balanced portfolio. Say you invested $100,000 at the end of 1991:

If you chased the best performing asset class from the previous year, your investment today would be valued at $300,518. A compound return of 9.6% p.a.

But if you stay invested in a balanced portfolio, your investment would now be worth $387,743. A compound return of 12.0% p.a.

Simply by chasing returns, you would have generated a lower return on your original investment of over $87,000, and this does not even incorporate the additional costs incurred (both fees and taxes) of switching between products.

We often create more volatility in investments by switching course and trying to catch the best performing asset class.

Source: MERCER, MLC InvestmentsLtd.

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The Chaser vs a Strategic Balanced PortfolioValue of $100,000 invested in 31 December 1991

$-

$100,000

$200,000

$300,000

$400,000

$500,000

$600,000

1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Year End

The Chaser

Strategic Balanced Fund

Source: MLC Investment Specialists. The Strategic Balanced Fund has the same asset allocation as the Median Manager in the Mercer Pooled Fund

Survey as at 30 June 2008. Index returns used are S&P/ASX 300 (All Ords before 1/4/2000), MSCI All Countries Index (MSCI World Gross before

1/7/2002), S&P/ASX 200 Listed Property Index, UBS Warburg Composite Bond Index (All Maturities), Lehman Global Aggregate Hedged $A (MLC

Customised Bond Index before 1/12/2000), UBS Warburg Inflation Linked Bond Index (All Maturities) and UBS Warburg Bank Bill Index.

However, this doesn‟t just apply to asset classes, but also applies to investment managers and even securities. Short-term fluctuations in returns are not a reason to change your portfolio – you need to apply discipline and reaffirm your belief that your portfolio is appropriate for your circumstances.

This is why we don‟t change our portfolio to try and take advantage of short-term trends – it puts your money at risk and will often go unrewarded. Instead, we set a strategic allocation and then continually rebalance to your target allocation in a disciplined manner.

Rebalance portfolios to their target allocation Over time, asset classes and investment managers will perform differently at different periods – this different performance means portfolios become “unbalanced”, or no longer in line with your original asset class and investment manager weightings. For example, if shares perform better than other assets in the portfolio, the actual allocation to shares will increase above the target allocation. This is illustrated in the diagram below.

Source: MLC Investments Limited.

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Rebalancing a 60/40% Australian Stock/Bond Portfolio

40%

45%

50%

55%

60%

65%

70%

75%

Jul-9

0

Feb-9

1

Sep

-91

Apr

-92

Nov

-92

Jun-

93

Jan-

94

Aug

-94

Mar

-95

Oct-9

5

May

-96

Dec

-96

Jul-9

7

Feb-9

8

Sep

-98

Apr

-99

Nov

-99

Jun-

00

Jan-

01

Aug

-01

Mar

-02

Oct-0

2

May

-03

Dec

-03

Jul-0

4

Feb-0

5

Sep

-05

Apr

-06

Nov

-06

Jun-

07

Jan-

08

Aug

-08

Mar

-09

Sto

ck

All

oc

ati

on

Unrebalanced 60/40 Stock Bond

Rebalanced 60/40 Stock Bond

Upper Limit

Lower Limit

Target

Source: MLC Investment Specialists. Stocks are represented by the S&P/ASX 300 Index (All Ords before 1/4/2000) and bonds are represented by UBS Warburg Composite Bond

Index (All Maturities).

47.9% Stocks

72.9% Stocks

In order to make sure the portfolio continues to be appropriate for your circumstances, we generally undertake a process of „rebalancing‟. Effectively, this means reducing your allocation to the better performing asset classes and/or investment managers (selling „high) and increasing your allocation to the poorer performing asset classes and/or investment managers (buying „low‟).

While intuitively this is what you want to do when investing, without this discipline many people don‟t and they end up destroying some of their hard earned wealth.

Buy

Outperform

Underperform

Sell Upper Trigger

Lower Trigger

Strategic Target

Buy

Outperform

Underperform

Sell Upper Trigger

Lower Trigger

Strategic Target

With disciplined rebalancing, you can manage the drift in your asset & manager mix, and keep it consistent with your desired target allocation. This means you are not exposed to risks or different performance characteristics you did not agree to when you first invested.

Source: MLC Investments Limited.

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5) Efficient implementation reduces the costs of running a portfolio

Great investment ideas can only result in great outcomes if they are efficiently implemented.

After spending considerable time and effort in constructing your portfolio, we don‟t want to find that you have lost valuable returns through implementation leakages. Some common implementation leakages include:

Inefficient structuring of investment vehicles, incurring extra transaction costs and taxes when running, trading and transitioning the portfolio.

Inefficient cash flow management resulting in more buying and selling than should be required to keep the portfolio in line with its strategic targets.

Inefficient transition management when changing managers or asset classes, incurring extra transaction costs, taxes and market impacts.

When we select how to implement your portfolio, we look to ensure that these potential costs are all carefully managed so you don‟t lose valuable returns, which means you end up with more in your pocket at the end of the day.

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3. Implementing Your Portfolio

There are four main options we have available in implementing your investment portfolio. We may choose to:

1. Purchase direct investments This would involve buying many individual shares through the Australian and global sharemarkets, fixed-interest products through various financial institutions and then continuously monitoring these individual securities and ensuring your portfolio is re-balanced to align with your strategic asset allocation. However, selecting which of the millions of securities around the world are most likely to meet your goals is almost impossible. Specialist investment managers are able to focus on researching and selecting the most appropriate securities.

2. Purchase a variety of specialist managed funds This would involve selecting a range of specialist managed funds for your portfolio, and continuously monitoring and rebalancing these funds to ensure your portfolio remains in line with your strategic asset allocation. However, choosing investment managers is also a complicated and involved process, and it is next to impossible for any individual to replicate the depth of resources available to research houses. This can also be a more expensive outcome due to the lack of scale.

3. Use a ‘core and satellite’ portfolio approach This involves selecting a fund to be the core of your portfolio, and using a range of specialist funds as „satellites‟ to tailor the portfolio to your needs and circumstances. Generally, we use a multi-manager core where our nominated research provider reviews and invests the large portion of your portfolio. We then focus our resources and energy on the satellite options to ensure that your portfolio is tailored to your unique objectives and requirements. This approach gives us the efficiency of using a multi-manager core portfolio, and allows us to focus our research effort on achieving the specific needs and objectives of your investment portfolio.

4. Use a specialised multi-manager service This would involve appointing a specialised facility which researchers and invests on your behalf in what it believes is the most appropriate assets and investment managers. This also rebalances your investments between asset classes and investment managers, so that your portfolio remains in line with your strategic asset allocation. This is a more practical approach, which employs one of the best and most focussed research houses, who provide multi-manager portfolios for all types of risk/return profiles.

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We generally use the fourth approach for our clients‟ portfolios. This allows us to focus our time and energy on ensuring we have selected the most appropriate multi-manager from the approximately 40 multi-managers within Australia. This allows us to focus on achieving your goals and strategies, and allows full-time professionals to focus on managing your underlying investments.

The following diagram indicates our typical approach and involvement in implementing your investment portfolio

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How we select a multi-manager for your portfolio

When selecting a multi-manager, we assess the available multi-managers against a range of selection features, which we believe will assist in providing you with a desirable investment solution. We have grouped these selection features into 4 key areas, as outlined below:

Selection Feature

Inv

es

tme

nt

Str

ate

gy Proven, disciplined approach (minimum 10 yrs)

Well resourced and ongoing review capability

No limits to asset classes due to scale

Proven leader in investment innovations

Se

lec

tin

g

Ma

nag

ers

Proven, disciplined approach (min 10 years)

Own research team dedicated to Australian portfolios

No conflicts of interest in selling research

Regular manager reviews

Resources to attain best managers

High conviction, tax aware investment mandates

Ble

nd

in

g

Ma

nag

e

rs Enough managers to reduce risk

Extensive resources in blending managers

Imp

lem

e

nta

tio

n Extensive resources in rebalancing and managing cashflow

Extensive resources in transition management

Closely monitors managers

Efficient structures to reduce costs

We also ensure that the fee charged by the multi-manager is competitive within the market, and reasonable given your portfolio requirements and individual circumstances.

And we validate our research by using supporting recommendations and reports from leading research houses, such as Lonsec, ChantWest or Standard & Poors‟

Once we have selected a multi-manager, we continue to review them against these selection features (and any new selection feature we identify are appropriate over time) to ensure you have the most appropriate multi-manager looking after your portfolio over time.

We have reviewed many multi-managers against this criteria, and generally we use MLC as our preferred provider of multi-manager investment solutions. The next section outlines our views and rationale for selecting MLC as our preferred provider (you should refer to your Statement of Advice for more information on why we believe our recommendations are appropriate for you and your individual circumstances).

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Why we have selected MLC as our preferred multi-manager investment provider

When we consider any multi-manager, we assess them against the criteria outlined above. This section details how we believe MLC performs against each of these criteria, and why we have chosen to partner with them to assist our clients in achieving their investment goals.

Investment Strategy

MLC has a proven asset allocation process (illustrated below) that it has employed and continually refined since 1985. The process takes into account multiple scenario analysis to ensure your portfolio is robust across many market conditions and economic environments.

Histor ical Back testing

Mark et BehaviourUnderstanding Objectives

SAA Scenarios

Model:- Matrix of scenario returns

- Probability distributions

Scenarios

Analysis:Assess

trade-offs

Objective Function &

Optimisation Analysis

Strategy must meet product requirements robus tly and effic iently

Investor Circumstances

& Objectives

Business Requirements

– absolute versus peer

returns

- Fee & liquidity

constraints

Recognising uncertainty

by defining potential

futures

Starting valuations

Define scenario

probabilities

Multiple Objectives: Maximise returns s.t.

- Absolute risk tolerance

- Peer risk tolerance

- Fee tolerance

- Illiquidity tolerance

Trial Allocations

Test the scenario

against the

historical scenario set

The Asset Allocation Process

MLC employs a dedicated capital markets team which continually reviews the assumptions and assets classes to ensure that your portfolio has an investment strategy that reflects the latest available current research.

MLC‟s scale gives you access to a depth within and across asset classes that other managers often can‟t provide.

MLC‟s culture of innovation means they are often one of the first managers to provide investors access to new asset classes in their portfolio to improve their return or reduce risk (as illustrated in their history of evolution on the next page).

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Global listed property

Long Term Absolute Return Portfolio

Started employing unconventional long-term investment strategies

Emulation introduced to improve the efficiency of the Australian share portfolios

Move to high conviction portfolios within global equities.

Managers employed withexplicit real return objectives.

Asset classes introduced Behind the scenes initiatives

2008

2007

2006

2005

2004

2003

20022001

2000

1999

1998

1997

1996

1995

1994

1993

1992

1991

1990

1989

1988

1987

1986

1985

Global Private markets

Emerging equity markets

Global bonds/Inflation-linked bonds

Refinement of asset allocation process with the significant development of the scenario set to more than 40 scenarios, & 4 base cases.

Incorporation of serial correlation into modelling.

Strategic Overlay

2009

Commodities

Insurance Related Investments (IRIs)Bank Loan fund

Multi-Asset Strategies

Diversified debt strategies tailored to each portfolio‟s risk/return objective

Tax effectiveness of a manager‟s investment approach became an important consideration

Moved away from regional global share mandates, allowing managers broader investment choice

Started employing managers with high conviction portfolios within Australian shares

High yield corporate and emerging markets debt

Strategic currency hedging within global shares

MLC improves diversification with a lower bias to the Australian market than its competitors,MLC introduces the manager of managers investment process to Australia, with a strategic approach to asset allocation & disciplined rebalancing

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Selecting Managers

MLC have been selecting managers for over 20 years continually refining the core process to identify those managers with a competitive edge, and unlike some others does not rely on past performance which can result in destroying wealth.

Capital International („Capital‟) is a good example of a manager who has experienced periods of over and under performance at various intervals since MLC included them as a global share manager in 1985. Their excess performance (measured against the MSCI All Countries Index) over rolling 1-year periods is illustrated below.

When Capital was first appointed and at various times during their appointment, they experienced prolonged underperformance relative to the index. While Capital has underperformed at times, MLC has not lost conviction in their competitive edge and their ability to add value over the long term. By keeping Capital as a global share manager, MLC investors have been rewarded by subsequent out-performance. Since their inclusion as a global share manager within MLC‟s portfolios in 1985, Capital has generated an average of 2.8% p.a. (as at 30 June 2009) above the index.

Capital International Rolling 12 Month Excess Returns

-20%

-10%

0%

10%

20%

30%

40%

Jun-

86

Jun-

87

Jun-

88

Jun-

89

Jun-

90

Jun-

91

Jun-

92

Jun-

93

Jun-

94

Jun-

95

Jun-

96

Jun-

97

Jun-

98

Jun-

99

Jun-

00

Jun-

01

Jun-

02

Jun-

03

Jun-

04

Jun-

05

Jun-

06

Jun-

07

Jun-

08

Jun-

09

12 M

on

th R

etu

rn %

p.a

.

Source: MLC Investment Specialists

Instead, some of the key criteria that MLC looks for in selecting managers include:

o Investment philosophy - A manager‟s investment philosophy represents their core set of investment beliefs. Having a logical and defensible investment philosophy is essential to being a successful investment

Source: MLC Investments Source: MLC Investments Ltd.

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manager. If a manager cannot enunciate their philosophy, it probably does not exist.

o Investment approach - This refers to the process the manager uses to effect their investment philosophy. If the philosophy involves fundamental research, does the manager have excellent research resources? If it involves quantitative models, have the models been developed rigorously, and are they implemented efficiently?

o Investment staff - MLC reviews the quality of the staff, their investment and industry experience, formal educational qualifications, the synergy of the team, appropriateness of the team size and structure, incentive structure, and firm culture.

o Ownership structure - MLC examines the stability and composition of the ownership structure, equity participation by investment professionals, and incentives resulting from the ownership structure.

o Research - The validity of a manager‟s screening processes, its criteria to identify research opportunities, available resources for research, model-building expertise, sources of insight and willingness to research some or all of the markets are considered.

o Portfolio construction - The role of the benchmark, risk management, definition of risk, use of quantitative tools and/or techniques, how stock weighting decisions are made, and portfolio construction guidelines are just some of the areas that MLC examines.

o Implementation - A manager‟s decision-making structure, dealing process, compliance issues, and whether their current assets impede their ability to execute the necessary trades in a timely and cost-effective manner are considered.

o Tax efficacy – A manager‟s awareness of the tax impact of investment decisions and the steps taken to manage the portfolio as efficiently as possible form a tax perspective.

o Assets under management - MLC reviews managers‟ business plans, growth in assets under management, absolute level of assets under management, and the ability to implement their investment philosophy given assets under management.

MLC have a specialist internal team focused solely on researching and selecting managers.

MLC do not sell their manager or asset class research to other providers, and is therefore not subject to conflicts of interest that this can introduce, but works on implementing their research in the best possible manner for your portfolio.

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MLC‟s close relationship with managers provides the background for regular and ongoing reviews which often allows MLC to act before others. MLC‟s ongoing review process is illustrated below:

MLC‟s dedicated research team and scale gives them access to excellent managers that are often not-accessible to others.

MLC use their scale and relationships to encourage managers to run high-conviction, tax-aware mandates, seeking to provide a better after-tax return outcome, as illustrated in the diagram below.

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Blending Managers

MLC has sufficient scale to be able to diversify across many managers, without the higher costs and complexity that can reduce returns.

MLC uses proprietary software to analyse every portfolio across up to 26 different style measures, ensuring an appropriate blend of managers to meet objectives and desired risk and return characteristics. The combination of these measures for the MLC Australian Share strategy is illustrated below:

Style Measure vs ASX 300

MLC Australian Equity ManagersFrom December 2001 to June 2009

60%

80%

100%

120%

140%

160%

180%

Dec

-01

Mar

-02

Jun-

02

Sep

-02

Dec

-02

Mar

-03

Jun-

03

Sep

-03

Dec

-03

Mar

-04

Jun-

04

Sep

-04

Dec

-04

Mar

-05

Jun-

05

Sep

-05

Dec

-05

Mar

-06

Jun-

06

Sep

-06

Dec

-06

Mar

-07

Jun-

07

Sep

-07

Dec

-07

Mar

-08

Jun-

08

Sep

-08

Dec

-08

Mar

-09

Jun-

09

Date

Ac

tiv

e M

on

ey

Re

lati

ve

Re

lati

ve

Wallara

Balanced

Northcape

Northward

Concord

Contango

Lazard

Jardine

DFA

MBA

MLC

Source: MLC Investment Specialists

Source: MLC Investments Ltd.

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Implementation

MLC has a dedicated implementation team to rebalance portfolios to within 2% of their target asset allocation and manager line-up using considerable cashflows, reducing the impact of transaction costs and taxes.

MLC carefully manages all transitions to reduce the impact of any implementation leakage on returns.

MLC continually monitor managers‟ activities to ensure their portfolios are in line with their mandates, so you can be confident you are getting the right outcome for the appointed investment managers.

MLC has efficient investment structures and arrangements to minimise transaction costs and taxes incurred by clients in the running of their portfolios, and provide comfort that your portfolio is not treated as part of MLC‟s assets.

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The benefits of MLC’s multi-manager approach

Having selected MLC as our preferred supplier of multi-manager portfolios, it is worthwhile highlighting the benefits that such an approach can bring to our clients when we recommend to include it in their tailored portfolios.

1. Aims to deliver better returns

The key benefit of MLC‟s Manager of Managers Investment Process is that it uses exceptional investment managers to build portfolios of individual investments based on serious research. MLC uses exceptional investment managers and liberates them to be the best they can be.

The MLC investment process has consistently generated returns that are very strong compared to similar funds. The following graph shows the return history of MLC's flagship fund, the MLC Horizon 4 Balanced Portfolio, against its peers over rolling 5 year periods for the last 10 years. It shows that MLC has consistently delivered strong peer relative returns on an after-tax and after fees basis, and has never been fourth quartile over this period. The graph shown below is Horizon 4 – Balanced Fund in Superannuation as it reflects the peer relative returns on an after fee and after tax basis, what investors actually receive in their hands.

MLC MK Sup Horizon 4 Balanced Excess Return in Personal Super Multi-Sector Balanced Growth

from Apr 1995 to Jun 2009

MLC vs Median (after tax and fees)

-2.0%

-1.5%

-1.0%

-0.5%

0.0%

0.5%

1.0%

1.5%

2.0%

Apr-9

5

Oct-9

5

Apr-9

6

Oct-9

6

Apr-9

7

Oct-9

7

Apr-9

8

Oct-9

8

Apr-9

9

Oct-9

9

Apr-0

0

Oct-0

0

Apr-0

1

Oct-0

1

Apr-0

2

Oct-0

2

Apr-0

3

Oct-0

3

Apr-0

4

Oct-0

4

Apr-0

5

Oct-0

5

Apr-0

6

Oct-0

6

Apr-0

7

Oct-0

7

Apr-0

8

Oct-0

8

Apr-0

9

Ro

llin

g 5

Ye

ar

Ex

ce

ss

Re

turn

(%

p.a

.)

MLC Upper Quartile Lower QuartileData source: Retail Mercer MPA

Note: MLC MK Sup GS - Horizon 4 Balanced prior to 1st January 2007

82% above Median

2. Aims to deliver lower risk.

MLC‟s Manager of Managers Investment Process delivers diversification across assets and investment managers in a single portfolio. Diversification helps reduce your exposure to some of the risks of investing. MLC‟s focus on broad diversification has meant MLC has often led the market in introducing new strategies and asset classes to improve expected returns or reduce risk.

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This diversification has resulted in consistently low relative risk. The following graph shows the risk history of MLC's flagship fund, the MLC Horizon 4 Balanced Portfolio, against its peers over rolling 5 year periods for the last 10 years. It shows that MLC has consistently delivered lower risk than similar funds.

MLC MK Sup Horizon 4 BalancedStandard Deviation in Personal Super Multi-Sector Balanced Growth

from Apr 1995 to Jun 2009

MLC vs Median (after tax and fees)

4.0%

5.0%

6.0%

7.0%

8.0%

9.0%

10.0%

Apr

-95

Oct-9

5

Apr

-96

Oct-9

6

Apr

-97

Oct-9

7

Apr

-98

Oct-9

8

Apr

-99

Oct-9

9

Apr

-00

Oct-0

0

Apr

-01

Oct-0

1

Apr

-02

Oct-0

2

Apr

-03

Oct-0

3

Apr

-04

Oct-0

4

Apr

-05

Oct-0

5

Apr

-06

Oct-0

6

Apr

-07

Oct-0

7

Apr

-08

Oct-0

8

Apr

-09

Ro

llin

g 5

Ye

ar

Sta

nd

ard

De

via

tio

n (

% p

.a.)

MLC Upper Quartile Median Lower QuartileData source: Retail Mercer MPA

Note: MLC MK Sup GS - Horizon 4 Balanced prior to 1st January 2007

As a result of this process, the MLC investment process over the last 20 years has delivered superior returns at a lower risk than the average manager, as the following graph shows:

MLC Moderate Option Comparison with the Mercer Pooled Fund Survey Universe

Annualised Risk and Return from February 1981 to June 2009(after tax and after fees)

MLC Moderate Option

8.0%

8.5%

9.0%

9.5%

10.0%

10.5%

11.0%

11.5%

12.0%

8.0% 8.5% 9.0% 9.5% 10.0% 10.5% 11.0%

Standard Deviation (% p.a.)

An

nu

al

Re

turn

(%

p.a

.)

22 funds started this race in February 1981.

Where the lines intersect shows the median

risk and return result of the 7 managers who

survived the 28 year period.

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4. Ongoing Performance & Review

We will review your portfolio‟s performance at our regular reviews, to ensure it continues to be relevant for your circumstances, and the most appropriate to achieve your goals and objectives. When we review the portfolio‟s performance, we consider:

Changes to your circumstances, goals or objectives that require an adjustment to your recommended portfolio.

The economic and market environment impact on:

o Different asset class performance compared to our long-term expectations.

o Investment Manager performance in absolute and benchmark relative returns, and future expectations.

We review this performance in light of the investment beliefs and the approach we use to constructing your portfolio outlined in this document.

For example, we understand that markets and investment managers are often cyclical in nature, and may go through periods of poor, or even, negative returns (in either an absolute or benchmark relative sense). We do not make changes to your portfolio based purely on past performance. Instead, we only make changes to provide an improved likelihood of achieving your goals and objectives, with greater certainty or lower risk. In particular, given we use MLC to provide investment advice for our multi-manager investment solutions, they undertake a considerable amount of research and monitoring of investment managers. We therefore review their research and monitoring to ensure they continue to do an appropriate job for our clients‟ portfolios.

Any rebalancing we need to undertake to adjust your portfolio back to our agreed allocations.

We do not make adjustments to your investment portfolio based on a period of poor peer relative, or even negative, returns as this often results in wealth destruction. We will assess each asset class, investment manager and investment against its future expectations to determine whether we believe your investment portfolio remains the most appropriate portfolio to achieve your desired goals and objectives.

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About the Author.

Kevin McCarthy B Bus (Acctg) and Dip FP. Kevin has a Bachelor Business Degree majoring in Accounting, has completed the Certified Practising Accountant Program (CPA) and additionally, has completed an advanced Diploma in Financial Planning. He has been in the Financial Services industry since 1989 with experience in Public Practice (tax and business services), Corporate Treasury, Commercial Accounting with one of Australia‟s largest Publicly Listed Companies and extensive experience in all facets of Financial Planning. Kevin is an Authorised Representative of GWM Adviser Services Limited. His authorised representative number is 274077.