BT Investment Management Limited and its subsidiaries (‘BTIM’) are committed to implementing and maintaining good corporate governance policies. The policies have been considered in light of the ASX Corporate Governance Council’s Corporate Governance Principles and Recommendations and other relevant standards.

Board & Committees

The Board of BTIM has adopted a Board Charter which sets out its roles and responsibilities.

To assist in the execution of its duties and responsibilities, the Board has established the following committees, each of which has its own charter:

• Audit and Risk Committee; and
• Remuneration and Nomination Committee.

The Board may also establish other committees from time to time if required.

Market Disclosure Policy

BTIM has adopted a Market Disclosure Policy designed to assist BTIM in keeping the market fully informed and in meeting its continuous disclosure obligations under the ASX Listing Rules.

Diversity Policy

BTIM is committed to enabling every employee to be valued for their distinctive skills, experience and perspective. Our Diversity Policy outlines our intent to provide a diverse and inclusive workplace across all levels of our organisation.

Compliance Policies

BTIM has adopted a set of policies to promote transparency, fair dealing and the protection of stakeholder interests. These include Conflicts of Interest Policy, Code of Conduct and Insider Trading Policy.

Code of Conduct

BTIM has adopted a Code of Conduct which applies to all employees and Directors. The Code of Conduct requires all employees and Directors to observe high standards of corporate and individual behaviour in the context of their employment. The Code provides that employees and Directors should:

• act with honesty and integrity
• respect the law and act accordingly
• respect confidentiality and do not misuse information
• value and maintain their professionalism
• appropriately manage conflicts of interest

Conflicts of Interest Policy

BTIM has adopted a Conflicts of Interest Policy, which is intended to identify, monitor and manage conflicts of interest. The policy sets out the procedure for managing potential conflicts, including procedures relating to:

• participation in activities that involve an actual or perceived conflict with duties and responsibilities to BTIM or transactions which are prejudicial to BTIM;
• participation in dealings that involve an actual or perceived conflict with the interests of a customer or a position which unfairly puts the interests of one customer before another's, regardless of the size or nature of that relationship;
• where acting as a trustee, ensuring that employees make decisions in that capacity having regard to the fiduciary obligation to act in the best interests of the fund members; and
• acting in accordance with the terms of BTIM's investment mandates.

  Statement of Director Independence (165KB)

  Director Selection and Appointment Process (125KB)

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Insider Trading Policy

BTIM has adopted an Insider Trading Policy and a Personal Account Trading Policy governing trading in securities by Directors and employees. These policies set out applicable insider trading laws and procedures to be followed when dealing and trading in securities (including notification and clearance procedures).

Directors and employees are not permitted to deal in any securities (including shares in BTIM) where the individual is in the possession of price sensitive information which is not generally available to the market, and must not provide such price sensitive information to other persons (including fellow employees) who may use such information to trade in securities. In addition, employees must not trade in BTIM's Shares or other securities during a specified blackout period. These blackout periods occur 4-6 weeks prior to the Company’s half year or year end results or its quarterly announcements in relation to funds under management. There are limited exceptions for acquisitions pursuant to employee share or option plans.

If a Director deals in BTIM’s shares, BTIM must advise the ASX within five business days, in accordance with the Corporations Act and the Listing Rules.

Proxy Voting

BTIM regards corporate governance and the exercise of voting power as an important aspect of investment decision-making. BTIM will not become involved in day-to-day management issues but recognises that it can influence company policy on matters of corporate governance by virtue of shareholdings under our management. In accordance with industry practices, and the IFSA guidelines in particular, BTIM uses that influence for the benefit of its clients.