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Coronation - Senate Group Nov 2015
- 1. Market update andcurrent views Presentation to The Senate Group Peter Kempen November 2015
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- 3. 2 Markets have bifurcated •JSE: R100 invested in RESI 3 years ago now worth R82 FINDI 3 years ago now R182 • Global Equities: USD100 invested in MSCI World 5 years ago is now worth $163 MSCI GEM 5 years ago is now worth $91 The big miners have been carried out • Rand share price declines between 58.1% (Glencore) and 98.5% (Lonmin) since peak Rampant USD, especially against EM & commodity currencies • Our GEM fund lost 20% over the past 12 months on BRL & RUB currency movement alone Our performance • SA Multi-asset Comfortably first quartile 3 years plus, around average shorter periods • SA Equity Comfortably above average 2 years plus, behind average shorter periods because roughly 20% in miners Top 20 < Equity by ±3% p.a. given difference in concentration levels • Global Opps Equity FoF above average all periods Directly managed funds lagging shorter term because of ± 30% of equity in EM Performance
- 4. 3 Performance Source: Morningstar asat 30 September 2015 -30.00 -20.00 -10.00 0.00 10.00 20.00 30.00 40.00 1 Year 3 Year 5 Year 10 Year RateofReturn(%) ASISA SA Equity General Coronation Top 20 A Coronation Equity R ALSI Top 40
- 5. 4 Performance Source: Morningstar asat 30 September 2015 -30.00 -20.00 -10.00 0.00 10.00 20.00 30.00 1 Year 3 Year 5 Year 10 Year RateofReturn(%) ASISA MA High Equity Sector Coronation Balanced Plus A Balanced Plus Composite Index
- 6. 5 Performance Source: Morningstar asat 30 September 2015 -2.00 0.00 2.00 4.00 6.00 8.00 10.00 12.00 14.00 16.00 1 Year 3 Year 5 Year RateofReturn(%) ASISA SA MA Low Equity Coronation Balanced Defensive A STeFI 3m + 3%
- 7. -15% -10% -5% 0% 5% 10% 15% 20% Sep-94 Mar-95 Sep-95 Mar-96 Sep-96 Mar-97 Sep-97 Mar-98 Sep-98 Mar-99 Sep-99 Mar-00 Sep-00 Mar-01 Sep-01 Mar-02 Sep-02 Mar-03 Sep-03 Mar-04 Sep-04 Mar-05 Sep-05 Mar-06 Sep-06 Mar-07 Sep-07 Mar-08 Sep-08 Mar-09 Sep-09 Mar-10 Sep-10 Mar-11 Sep-11 Mar-12 Sep-12 Mar-13 Sep-13 Mar-14 Sep-14 Mar-15 Sep-15 Coronation Houseview EquityFund - 1 year rolling alpha 6 Short-term alpha is lumpy A successful track record comes with testing years Selling inflated rand-hedge stocks Buying depressed interest rate sensitive stocks As at 30 September 2015 Selling overvalued commodity and construction shares Selling inflated domestic stocks & buying cheap global JSE listed stocks Selling overvalued defensive domestics & buying depressed commodity stocks
- 8. 7 Alpha over meaningfulperiods It’s over the long term that we measure results As at 30 September 2015 -10% -5% 0% 5% 10% 15% 20% Sep-98 Mar-99 Sep-99 Mar-00 Sep-00 Mar-01 Sep-01 Mar-02 Sep-02 Mar-03 Sep-03 Mar-04 Sep-04 Mar-05 Sep-05 Mar-06 Sep-06 Mar-07 Sep-07 Mar-08 Sep-08 Mar-09 Sep-09 Mar-10 Sep-10 Mar-11 Sep-11 Mar-12 Sep-12 Mar-13 Sep-13 Mar-14 Sep-14 Mar-15 Sep-15 Coronation Houseview Equity Fund - long term alpha 5 year alpha 10 year alpha
- 9. Domestic Equity Funds Source:Morningstar, Coronation Research as at August 2015. Based on rolling 5 year return (as at month end) calculated over the past 10 years. 0% 25% 50% 75% 100% Coronation Equity R SIM General Equity R Prudential Equity A Coronation Top 20 A Foord Equity R Prudential Dividend Maximiser A PSG Equity A Allan Gray Equity A STANLIB Equity R Investec Value R Investec Equity R Nedgroup Inv Rainmaker A 1st Quartile 2nd Quartile 3rd Quartile 4th Quartile
- 10. Multi Asset HighEquity Funds Source: Morningstar, Coronation Research as at August 2015. Based on rolling 5 year return (as at month end) calculated over the past 10 years. 0% 25% 50% 75% 100% Coronation Balanced Plus A Foord Balanced R Rezco Value Trend A Allan Gray Balanced A Investec Opportunity R Prudential Balanced A PSG Balanced A STANLIB Balanced B1 SIM Balanced R Nedgroup Inv Managed R Investec Managed R 1st Quartile 2nd Quartile 3rd Quartile 4th Quartile
- 11. Global macro economicenvironment
- 12. US the onlymajor economy ready to start hiking interest rates • Although we do not expect a sharp cycle the improving economy no longer warrants zero interest rates • The big medium term (historical) reason for EM falling out of favour… remember the taper tantrum? Chinese stock market volatility must not be seen as a predictor of the economy • But the economy has slowed and a hard landing remains the greatest global macro worry • Fears about China is the proximate cause for August’s return of volatility • Policy has become more stimulatory as the economic slowdown continues Greece got to the edge of the cliff but not quite over it • Caused initial spike in volatility and eventual Grexit remains a possibility • No-one cares for now as the can has been kicked down the road Expect to hear about Greece again in 2017… • Deflation still the ECB’s major focus... no interest rate hikes on the horizon here Commodity prices fall further • Commodity producer currencies very weak Unsynchronized growth 11
- 13. 12 US: Recovery inemployment means rates will start rising Source: I-net
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- 15. 14 China: more evidenceof slowdown
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- 17. 16 GEM currencies veryweak vs. USD
- 18. CNY devaluation incontext - Other EM & Commodity currencies hammered 17
- 19. Future of emergingmarkets
- 20. 19 EMs are caughtin a macro driven storm • Concerns over Chinese growth combined with Fed hike expectations and a strong USD • There has been a collapse in EM since the Chinese stock market started declining with an acceleration since the renminbi was devalued by ±3% • Many commodities and EM currencies are at levels not seen since the ‘90’s • Capital outflows from EM are now being compared to those of the GFC Surge in EM outflows hits share prices and currencies …yet life continues to go on for the companies in which we invest, their long term prospects are attractive and valuations are very low
- 21. 20 Not a fairillustration of the opportunities available in emerging markets MSCI GEM Index
- 22. 21 Large MSCI GEMindex holdings mostly are/have: • Below average businesses – banks, energy, tech hardware • Significant state ownership / state regulation • Poor stewards of capital • Cyclical earnings An investment in these companies does NOT represent the opportunity set in EM If you invest in poor businesses, expect poor long term returns Right now: • Global macroeconomic environment is uncertain and looks especially poor in EMs • Expect volatility to continue but in EMs you can find… • Great businesses At attractive valuations With powerful long term structural drivers That make great long term investments And can’t be captured in the DM space Think beyond the index
- 23. Russian Food Retail:the long-term opportunity 22 Top 5 grocery retailers in Russia are 20% of market (vs. 60-70% in established markets)
- 24. Where else canyou get growth like this? • Exceptional businesses • Great management teams • Experienced crises like this before and thrived • At attractive valuations Russia Food Retail 368 610 1 014 1 500 1 893 2 194 2 568 3 204 4 002 5 006 6 046 7 200 8 344 9 694 0 2 500 5 000 7 500 10 000 12 500 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 F2015 Magnit Convenience Store Base 23
- 25. Brazilian Private Education– why invest? 24 Government target not very aggressive 33% target DL centres exclusively private sector run Private sector has taken 90% of new campus students over this period Powerful incentive to study further given uptick in lifetime earning potential Tertiary education almost non-existent outside the wealthy
- 26. Loan growth 1.3– 3.0x nominal GDP for close to 20 years now • But still under-banked by most metrics Indian Banks 25
- 27. 26 Mortgages and retailloans still very small in the mix Indian Banks
- 28. 27 Public sector bankslosing market share to private sector Indian Banks
- 29. 28 Several businesses inmany industries rapidly capturing the market Large investible universe spread across: • Search • eCommerce • Online travel • Mobile Value Added Services • Gaming • Video • Classified advertising • Recruitment • Property • General portals China Internet Stocks
- 30. 29 Online shopping alreadylarger than USA and still growing fast China Internet Stocks – JD.com / Alibaba
- 31. 30 The “Google” ofChina China Internet Stocks - Baidu 0 250 000 500 000 750 000 1 000 000 1 250 000 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Baidu - number of advertisers
- 32. 31 It is normalto second guess allocation to an asset class when it has underperformed so significantly BUT A long term specific allocation to GEM is still appropriate Global equity managers are generally structurally underweight GEM • Where global managers do invest in GEM it tends to be a narrow universe of the biggest, most liquid names in the asset class Industry structural drivers that are common in GEM are simply not present in DM All asset class returns may be lower going forward Cannot afford to miss out on long term return opportunities where they are available Why invest directly in GEM?
- 33. 32 GEM Fund upside(weighted average) and PE 0.0% 22.5% 45.0% 67.5% 90.0% 112.5% 0.0 4.5 9.0 13.5 18.0 22.5 11-Oct-10 11-Nov-10 14-Dec-10 17-Jan-11 15-Feb-11 22-Mar-11 26-Apr-11 30-May-11 4-Jul-11 8-Aug-11 12-Sept-11 17-Oct-11 21-Nov-11 3-Jan-12 6-Feb-12 12-Mar-12 16-Apr-12 21-May-12 25-Jun-12 30-Jul-12 3-Sept-12 8-Oct-12 13-Nov-12 14-Dec-12 22-Jan-13 25-Feb-13 2-Apr-13 6-May-13 6-Jun-13 8-Jul-13 12-Aug-13 16-Sept-13 17-Oct-13 18-Nov-13 20-Dec-13 3-Feb-14 10-Mar-14 14-Apr-14 19-May-14 23-Jun-14 28-Jul-14 1-Sept-14 6-Oct-14 10-Nov-14 15-Dec-14 26-Jan-15 2-Mar-15 7-Apr-15 11-May-15 17-Jun-15 20-Jul-15 Ave P/E (left) Ave Upside (right)
- 34. 33 GEM share ofworld GDP is up from 35% in 1993 to 50% today FX reserves in EM were half of DM in 2000, they are now double that of DM There has been (and will continue to be) improvement in economic situations • E.g. Brazil Debt/GDP is half what it was in 2002 Foreign direct investment into GEM has increased 10 fold from 2005 to 2014 • This is 30% faster than in DM While EM companies represented 5% of the Fortune Global 500 from 1980 to 2000, they are now 26% Set backs currently experienced resulting from rising US rates, shrinking commodity demand and a slowing global economy are normal and have been witnessed in most economies over time GEM has survived two massive crises in the recent past: Asian crisis of 1998 and the GFC of 2008 and come out of each stronger GEM will learn from this crisis and emerge stronger, and increasingly relevant GEM will remain relevant Source - http://foreignpolicy.com/2015/08/31/what-future-for-emerging-markets/
- 35. 34 SA vs. GEM •GEM is a very different investment set from SA • SA has also provided great long term returns despite volatility DM vs. EM valuations • Upside to fair value on most stocks in our GEM coverage list far exceeds that in DM “Hot money” is fleeing EMs • These investors were never making long term allocations • “Smart money” should not be influenced by the actions of “quick money” Market performance vs. economic performance & company performance • Dislocation between company performance and macroeconomic environment • Recessions are often good for businesses over the long term Weaker players exit => reduces excess capacity Market share increases for the remainder • Stock markets move out of sync with economic performance Don’t disinvest when (macro) times are tough Don’t invest only when times are good A long term, through the cycle allocation is appropriate Size of allocation depends on valuations, which are very attractive today Some final points to consider
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- 37. 36 Low commodity pricesand sluggish growth in trading partners undermining exports Reserve Bank intent on normalizing interest rates but in the weak economy a very mild cycle anticipated Lower oil has taken some pressure off inflation Combination of rising interest rates and a sluggish economy not good for already highly rated domestic equities Global environment a headwind, but we have added to our woes by scoring own goals: • Eskom – big blow to confidence and growth • The visa debacle • Poor fiscal discipline • Corruption and wasteful spending at SOE’s Downward commodity cycle and own goals
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- 40. 39 Undisciplined government spending Source:Prescient Securities (data from WEO database and the NT Budget Review)
- 41. 40 Sorry saga atthe SOE’s
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- 43. 42 Our exposure todomestic equities is low across all balanced funds on valuation grounds Massive divergence continues • Resources has sold off dramatically • Bid for SAB at very high multiple Corporate action in the platinum sector encouraging Banks relatively attractive More SA companies looking to expand off-shore • Mediclinic, Truworths, Foschini, Brait, Woolworths, Steinhoff among the more recent movers JSE listed global stocks such as Naspers, Richemont, MTN, Steinhoff and British American Tobacco continues to offer the SA investor much needed geographic diversification and offers reasonable value SA Equities
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- 46. Company 30-Jun-08 31-Jul-15 Price movePricePrice Anglo American 548.00 159.87 -71% Exxaro 144.45 74.91 -48% Impala 309.00 45.51 -85% SAB 178.05 661.48 272% Truworths 22.95 85.55 273% Bidvest 98.38 307.90 213% AVI 12.95 79.80 516% Mr Price 15.00 252.20 1581% Spar 49.50 197.87 300% Relative performance Resources versus industrials Source: I-Net 45
- 47. 46 Relative performance Resources vs.FINDI Source: I-Net
- 48. Commodities & theminers
- 49. JSE classification showsbasic materials as 28% in Top 20 and 23% in Equity 9% / 6% is Mondi which is anything but a typical resource company 19% / 17% in ‘traditional’ resource companies On a look through basis roughly half of this is SA based mines and the rest is outside of SA Predominantly exposed to diversified miners and Platinum Lower risk commodities with less ‘China’ risk Exposure to the miners 48
- 50. Setting the scene Supercycleand aftermath Up 900% -75% Source: I-Net Bridge 49
- 51. 50 Chinese consumption ofraw materials Source: www.visualcapitalist.com
- 52. 51 The current outlookfor commodity demand is weak across the board • Weakness in China, the major engine of demand growth • Rest of the world struggling too • Longer term threats of electric vehicles and renewable energy gaining traction Most commodities are in oversupply (still growing or not closing quickly enough) • Barriers to exit is likely to keep supply in the market for longer than expected • Last supercycle projects still being delivered • Governments often support loss-making industries to protect jobs Earnings have already collapsed and at spot prices most commodity companies are under increasing pressure and earnings and cash flows will be low Despite this, we believe the valuations of the mining companies are attractive enough to warrant a reasonable position in our funds • We prefer commodities where supply growth will be more muted in the long-term Platinum, copper, diamonds • We prefer companies with high quality, low cost, long life assets Impala and Northam Anglo American Sasol Resources sector view
- 53. 52 Earnings are lowand heading lower Price-to-earnings ratios Historic Spot Normal I-net Coronation estimate Coronation estimate Anglo American 51.1 1427 5.3 Exxaro 6.7 9.2 5.2 Impala 115.4 Neg 3.1 BHP Billiton 15.6 34.9 11.9 Glencore 21.3 137 4.4 Northam -15.4 Neg 3.8 Amplats 22.6 Neg 6.0 Sasol 8.7 11.2 8.2 … but long-term valuation looks compelling
- 54. 53 Returns and valuationsat multi decade lows
- 55. From already lowlevels we have seen further severe weakness Since June Rand basket down 15% Significant implications for miners Collapse in PGM prices 54 Source: I-net
- 56. 55 45% of industryproduction unable to cover cash costs 70% of industry production unable to cover cash costs + sustaining capex Only mines viable at these prices are • Amplat’s open pit Mogalakwena (needs more capex) • Zimbabwe – comes with its own specific set of challenges (ownership, taxes) etc. Logical response: cut loss making production Seen some of this already: • Amplats: 400k oz. at Rustenburg and Union • Lonmin: 100k oz. Barriers to exit in the industry are high: • Reducing labour incredibly difficult • Overheads spread over a smaller production base increasing unit costs Consequences are severe
- 57. 56 General commodity sell-off Concernsabout areas of China slowdown specific to PGMs • Platinum: jewellery demand • Palladium: auto sales Anti-diesel lobby in Europe Concerns about growth in recycling Concerns about changes in drivetrain technology: • Battery electric vehicles Concerns about changes in vehicle ownership patterns and replacement cycle: • UBER • Ride-sharing What is causing the rout?
- 58. 57 SA and Zimbabwehave 55% of global supply of PGMs Autocats absorb 45% of Platinum and 80% of Palladium... tightening emission controls a positive 30% of Platinum goes into jewellery • Predominantly China where increasing wealth levels and rise of middle income consumer are long term drivers PGMs less dependent on China than most base metals PGMs have some attractive fundamental drivers
- 59. 58 Trading on PE’sof 5-6x normal earnings Trading at discount to replacement cost: • Cost to build 1 vertical shaft + concentrator on Western Bushveld: R11 - R13bn • The majors operate many shaft complexes • Yet trade at market caps way below the cost to replicate their infrastructure: Lonmin: R3bn Northam: R17bn Implats: R30bn Compelling valuation
- 60. 59 Bonds • Excessively lowand even negative bond yields for low risk sovereigns offer no value • Domestic bonds offer relatively far better value • Corporate debt preferred to government debt Equities • Global (fairly valued) preferred to domestic (expensive) • Within global equities EM’s certainly cheaper but with clearly higher risk Property • On a bottom-up view we find some value in selected counters but in general the very low bond yields have pushed global property yields too low • Domestic property has likewise run hard but in a low yield world and relative to very pricey equities offers reasonable value Current asset allocation view
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- 62. 61 Expected asset classreturns as at 31 July 2015 Last 10 years (ZAR) 10 year forecast (ZAR) Local equity 17.2% 7 – 10% Global equity 14.1% 10 – 13% Local property 20.4% 7 - 10% Local bonds 8.2% 6 – 9% Global bonds 10.5% 5 - 7% Cash 7.5% 6 – 8% Inflation 6.2% 6% + Asset allocation is the most important decision you make in investments Above table shows importance of alpha generation in achieving targeted return Big difference between rear-view mirror and windscreen
- 63. 23 Alpha much morevaluable in lower return environment Increase in purchasing power over n years at different real return rates “The greatest shortcoming of the human race is our inability to understand the exponential function” - Albert A. Bartlett Real return: 0.5% 1.5% 2.5% 3.5% 4.5% 10% n = 10 years 0.05 X 0.15 X 0.26 X 0.38 X 0.52 X 1.46 X n = 30 years 0.15 X 0.52 X 1.01 X 1.65 X 2.48 X 13.95 X
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- 65. 64 Commodities near theend of the down cycle as evidenced by many loss making producers GEM currencies (tougher to call) have experienced a big cycle already • There could be even more pain, but its difficult to argue the pain has just started Developed world stocks trade around fair value GEM stock markets have had a deep down cycle, now offering far more upside than downside SA stock market has held up quite well. Many high quality stocks trading at very high multiples in a low growth economy. Downside risk not to be ignored The lower return world we have warned about repeatedly is here Most upside can be found in bombed out cyclical sectors, but uncertainty around global and domestic growth limits our appetite for these stocks Investment outlook Where are we in the cycle?
- 66. Sticking to ourknitting… 65 “Investment risk resides most where it is least perceived, and vice versa. When everyone believes something is risky, the unwillingness to buy usually reduces its price to the point where it is not risky at all. Broadly negative opinion can make it the least risky thing, since all optimism has been driven from the price… When everyone believes something embodies no risk, they usually bid it up to the point where it’s enormously risky. As no risk is feared, no reward for risk bearing is demanded or provided. That can make the thing that is most esteemed the riskiest” - Howard Marks, Oaktree
- 68. The content ofthis presentation and any information provided may be of a general nature and may not be based on any analysis of the investment objectives, financial situation or particular needs of the potential investor/client. As a result, there may be limitations as to the appropriateness of any information given. It is therefore recommended that the potential investor/client first obtain the appropriate legal, tax, investment or other professional advice and formulate an appropriate investment strategy that would suit the risk profile of the potential investor/client prior to acting upon such information and to consider whether any recommendation is appropriate considering the potential investor’s/client’s own objectives and particular needs. Coronation Asset Management (Pty) Ltd is not acting, does not purport to act and is not authorised to act in any way as an advisor. Any opinions, statements or information contained herein may change and are expressed in good faith. Coronation Asset Management (Pty) Ltd does not undertake to advise any person if such opinions, statements or information should change or become inaccurate. The value of the investments may go down as well as up and past performance is not necessarily a guide to future performance. Coronation Fund Managers Ltd is a full member of the Association for Savings and Investment SA (ASISA). Coronation Asset Management (Pty) Ltd is an authorised financial services provider (FSP 548). Disclaimer 67
- 69. FAIS requirements CORONATION ASSETMANAGEMENT (PTY) LTD Registration No. 1993/002807/07 Herein after referred to as ‘Coronation’ INFORMATION IN TERMS OF THE FINANCIAL ADVISORY AND INTERMEDIARY SERVICES ACT Coronation is a licensed Category II and Category IIA Financial Services Provider in terms of section 8 of the Financial Advisory and Intermediary Services Act 37, 2002 (licence number 548). Coronation is not authorised to provide advice in terms of the Financial Advisory and Intermediary Services Act 37, 2002. Coronation has been authorised to render discretionary intermediary services. Coronation is authorised to provide financial services for the following financial products: Long-Term Insurance : Category C; Pension Funds Benefits (excluding retail pension benefits); Securities and Instruments : Shares; Securities and Instruments : Money market instruments; Securities and Instruments : Debentures and securitised debt; Securities and Instruments : Warrants, certificates and other instruments; Securities and Instruments : Bonds; Securities and Instruments : Derivative instruments; Participatory interests in Collective Investment Schemes; Short Term Deposits; Long Term Deposits Coronation is a licensed Hedge Fund Financial Services Provider. The following exemptions are applicable to the licence: Exemption of investment managers and linked investment services providers and their related functionaries from fit and proper requirements (Board Notice 97 of 2003). Exemption of financial services providers as regards to representatives (Board Notice 95 of 2003). The following employees have been appointed as Key Individuals and/or Authorised Representatives: Key individuals Anton Pillay; Karl Leinberger; Kirshni Totaram; Neville Chester; John Snalam; Louis Stassen; Llewellyn Smith Authorised representatives Adrian van Pallander; Hendrik Groenewald; Alistair Lea; Karl Leinberger; Pieter Hundersmarck; Anton de Goede; Kirshni Totaram; Pranay Chagan; Kyle Wales; Quinton Ivan; Charles de Kock; Sarah-Jane Morley (married Alexander); Dirk Kotze; Sean Morris; Duane Cable; Mark le Roux; Louis Stassen; Neill Young; Siphamandla Shozi; Gavin Joubert; Neville Chester; Stephen Peirce; Godwill Chahwahwa; Pallavi Ambekar; Suhail Suleman; Peter Leger; Tracy Burton; Nishan Maharaj; Nomathibana Matshoba; Nicholas Hops (supervised); Brian Thomas; Steve Janson; Mauro Longano (supervised); Harry Moolman (supervised); Alex Dearman (supervised); Gus Robertson All Key Individuals and Representatives meet the fit and proper requirements as set out in the Board Notices to the Financial Advisory and Intermediary Services Act 37, 2002. Coronation holds professional indemnity and fidelity insurance cover as stipulated in the General Code of Conduct and Board Notices to the Financial Advisory and Intermediary Services Act 37, 2002. Any information disclosed to any of Coronation’s Authorised Representatives in their professional capacity will be treated as confidential unless written consent is obtained to disclose such information, or the disclosure of such information is required in the public interest or under a particular law. The appointed Compliance Officers are: Jamie Rowland Mark Barratt Stephan Kemp Tel: 021 680 2809 021 680 2099 021 680 7703 Fax: 021 680 2859 021 680 2199 021 680 7753 Cell: 082 434 4622 072 595 5277 082 351 2401 E-mail: jrowland@coronation.co.za mbarratt@coronation.co.za skemp@coronation.co.za Coronation’s Conflicts of Interest Management Policy, in terms of General Code of Conduct Regulations issued in terms of the Financial Advisory and Intermediary Services Act, No 37 of 2002, is available on Coronation’s website, www.coronation.com, or on request from the Compliance Officer. All complaints are taken seriously and Coronation’s aim is to ensure that all complaints are investigated and addressed in a timely and fair manner. To lodge a complaint, please contact either your Fund Manager or one of the compliance officer’s listed above. 68
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