FINANCIAL SERVICES GUIDE

1. Issue date

   1 January 2010

2. Contact details

   Zenith Investment Partners Pty Ltd
   Level 5, 160 Queen Street
   Melbourne VIC 3000
   Tel: (03) 9642 3320
   Fax: (03) 9642 3319
   Email: info@zenithpartners.com.au
   www.zenithpartners.com.au
   ABN 60 322 047 314

3. Services that Zenith is licensed to provide

   Zenith is the holder of Australian Financial Services License No. 226872 which was issued by the Australian Securities & Investments Commission (ASIC) on 10 April 2003. This licence authorises Zenith to carry on a financial services business to:

   1. provide general financial product advice for the following classes of financial products:
      1. debentures, stocks or bonds issued or proposed to be issued by a government
      2. interests in managed investment schemes including
      3. investor directed portfolio services
      4. securities; and
      5. superannuation to retail and wholesale clients.

   Advice on financial products is defined under the Corporations Act 2001 (Cth) (“the Act”) as being either personal or general in nature.
   Zenith does not provide personal financial advice.

   When giving general advice, under the provisions of Section 949A of the Act, Zenith is required to warn you that:

   1. the advice has been prepared without taking into account your objectives, financial situation or needs;
   2. that you should consider the appropriateness of the advice, in the light of your own objectives, financial situation or needs, before acting on the advice; and
   3. if our advice relates to the acquisition or possible acquisition of a particular financial product, you should obtain a copy of, and consider, the PDS or offer document for that product before making any decision.
4. How Zenith is renumerated for its services

   Zenith provides services to wholesale clients via subscription to its website with regard to general advice and commissioned research. Zenith charges standard fees for these services which are tailored in relation to the depth of services provided. These services include:

   1. Research Reports: Individual Managed Fund reports, Sector, Market and Economic reports.
   2. Customised Model Portfolios: Tailored for clients, customised by administration platform.
   3. Investment Committee: Quarterly participation, tailored client agendas.
   4. Advisor Group Fund Development: Assist adviser groups in developing their own products.
   5. Recommended List: Comprehensive list of funds across all asset classes.
   6. Tools: Performance tables, charts, search engine, asset class forecasts.

   Zenith also receives remuneration for services relating to the provision of third party reviews of fund managers products (Zenith Product Assessments). Remuneration for these reviews is undertaken at a fixed price which is payable upfront prior to the release of any report. Standard pricing may vary depending on the asset class, but is fixed within that asset class. Payment for the reimbursement of verifiable travel costs and disbursements incurred while undertaking the review also applies.

   Remuneration for product assessments is not linked to the ratings outcome. Neither Zenith nor its directors or employees receive any commissions or remunerations based on transaction volumes, gifts or any other benefits from an issuer of a financial product that may materially influence the direction of reports. As such, Zenith is of the opinion that under Section 923A of the Financial Services Reform Act, it can fulfil the requirements of use of the term ‘independent’ in its services.

5. How we deal with conflicts of interest

   Zenith has a conflict of interests' policy governing the assessment of managed funds. Zenith (its Directors and employees) generally do not have a material interest in any of the financial products on which it provides investment research. Should Zenith, its Directors or staff have any financial interests in such a product, action will be taken in accordance with our conflicts of interest policy, which may include disclosure of these interests in the relevant report, declining to provide investment research or exclusion of any individuals with a material interest from the research process.

   It should be noted that Zenith also separates any internal discussions relating to setting remuneration from fund managers for the provision of investment research from the analysts concerned in researching the products.

6. Dispute resolution

   Zenith is committed to maintaining high standards of client services and accountability. Any concerns should be directed to us via the contact details supplied in this FSG. In the event that any complaints handling is not satisfactory, you may request that the matter be referred to the Financial Industry Complaints Service Limited (FICS) of which Zenith is a member.

   FICS is an external dispute resolution scheme established to provide free advice and assistance to consumers to help them in resolving complaints relating to members of the financial services industry, including life insurance, pooled superannuation trusts, funds management, financial advice, stock broking, investment advice and sales of financial or investment products. There is no charge to consumers for any service provided by FICS in handling complaints.

   Contact details
   Postal address
   The Financial Industry Complaints Service Limited
   PO Box 579
   Collins Street
   West Melbourne Vic 8007

   Physical address
   Level 13
   31 Queen Street
   Melbourne Vic 3007
   Tel: 1300 78 08 08
   Fax: (03) 9621 2291
   Email: fics@fics.asn.au

7. Professional Indemnity Insurance

   Zenith maintains adequate professional indemnity insurance in accordance with its obligations to Section 912B of the Act.