Summaries of our policies
Code of Conduct
The Directors of Brookfield Multiplex Limited (“Brookfield Multiplex”) have adopted a Code of Business Conduct and Ethics. The Code applies to all employees of Brookfield Multiplex Limited and its subsidiaries including Brookfield Multiplex Capital. All employees within Brookfield Multiplex receive a copy of the Code and the supporting policies. It is expected that all Brookfield Multiplex Capital employees will observe the Code.
The Code prescribes the minimum moral and ethical standards of conduct required of all the company’s directors, officers and employees. Violations of the Code can have severe consequences and will result in the appropriate discipline being taken, up to and including discharge where warranted by the circumstances.
Brookfield Multiplex prides itself as being a good employer and corporate citizen that is committed to avoiding and resolving disputes and is straightforward, fair and forthright in its communications and dealings.
Securities Trading Policy
Purpose
The directors of Brookfield Multiplex Capital are committed to ensuring that they comply with their legal obligations as well as conducting business in a transparent and ethical manner. Directors and Brookfield Multiplex Capital employees (including their immediate family or any entity for which they control investment decisions), must ensure that any trading in Brookfield Multiplex Capital securities is undertaken within the framework set out in the Securities Trading Policy.
The purpose of the Policy is to describe the restrictions for trading in any financial products, as defined in s1042A of the Corporations Act, in managed investment schemes, which are issued by entities controlled by Brookfield Multiplex Capital. The restrictions extend to cover financial products issued or created over financial products issued by Brookfield Multiplex Capital, or financial products nominated by Brookfield Multiplex Capital.
Continuous Disclosure Policy
Brookfield Multiplex Capital is committed to the promotion of investor confidence by providing full and timely information to the market about fund activities and to comply with the continuous disclosure requirements contained in the Corporations Act 2001 (the “Act”) and the Australian Stock Exchange (“ASX”) Listing Rules (the “Rules”).
Brookfield Multiplex Capital is the investment division of Brookfield Multiplex Limited; it is responsible for the design and implementation of investment strategies for various investment products for the Brookfield Multiplex Group. There are five Responsible Entities (“RE”) in the Brookfield Multiplex Capital division, some of which are RE’s of listed registered managed investment schemes.
Purpose
The purpose of the Brookfield Multiplex Capital Continuous Disclosure Policy is to:
- reinforce Brookfield Multiplex Capital’s commitment to the continuous disclosure obligations imposed by the Act and the Rules and to describe the processes implemented by it to ensure compliance;
- ensure that timely and accurate information about Brookfield Multiplex securities is provided equally to all security holders and market participants; and
- educate, and to provide a guide to, all relevant personnel of Brookfield Multiplex Capital on what is continuous disclosure and how they can ensure they meet their individual responsibilities.
Commitment to Continuous Disclosure
Brookfield Multiplex Capital will immediately notify the market of any information or any major development related to the businesses or financial condition of Brookfield Multiplex Securities, which a reasonable person would expect to have a material effect on, or lead to a substantial movement in, the price or value of units in the fund. This will be notified to the market by way of an announcement to the ASX.
In certain circumstances, the Rules permit Brookfield Multiplex Capital not to disclose material information. The Continuous Disclosure Officer or their nominee will determine what information must be disclosed, and where there is disagreement whether information identified by a Director or Executive Officer warrants an ASX release.
Communications Policy
Introduction
Brookfield Multiplex Capital (and all its entities) is committed to effectively communicating with its investors and facilitating an efficient and informed market regarding our listed and unlisted property funds.
This Policy should be read in conjunction with Brookfield Multiplex Capital’s Continuous Disclosure Policy.
Contact with the Market
Throughout the year, Brookfield Multiplex Capital (and its entities) follows a calendar of regular disclosures to the market on its financial and operational results.
Guiding Principle
Brookfield Multiplex Capital must ensure it does not communicate inside information to an external party except where that information has previously been disclosed to the market generally.
Inside information is defined as information that:
- is not generally available; and
- if it were generally available, a reasonable person would expect to have a material effect on the price or value of particular securities (that is, the information would, or would likely, influence persons who commonly acquire units or securities in deciding whether or not to apply for, acquire or dispose of those units/securities.
Communication with Shareholders / Investors
Website
Brookfield Multiplex Capital maintains the following website: www.brookfieldmultiplexcapital.com
All recent company information is posted Brookfield Multiplex Capital’s website, including:
- Annual reports
- Half yearly reports
- “Capital” quarterly update magazine
- Announcement/releases to the ASX
- Corporate governance practices
The website also contains:
- a link to the share registrars for investors
- a live feed (20 minute delay) from the ASX for share price information
- daily or monthly unit price information and history for unlisted funds
- quarterly fund facts
Reports to Investors
Brookfield Multiplex Capital provides annual reports to investors for each financial year ending 30 June, a half yearly report for the period ending 31 December and a quarterly magazine issued following the close of each quarter (31 March, 30 June, 30 September and 31 December). These reports are posted on the website on their day of release.
Investors may elect to receive a hard-copy of these reports by advising Brookfield Multiplex Capital Customer Service on 1800 570 000 or via email: clientservices@brookfieldmultiplex.com
Unit Pricing
Brookfield Multiplex Capital updates unlisted fund unit prices on a daily, monthly or quarterly basis dependent upon fund reporting requirements. Listed unit prices are updated every via a direct feed from the ASX (20 minute delay).
Annual General Meetings
Brookfield Multiplex Capital holds an annual general meeting (AGM) for Multiplex Acumen Vale Syndicate in October each year. The date, time and venue of the AGM are notified to the ASX when the financial reports are lodged, generally in August each year.
Brookfield Multiplex Capital will choose a date, venue and time considered convenient to the greatest number of its investors.
A notice of meeting will be accompanied by explanatory notes on the items of business and together they will seek to clearly and accurately explain the nature of the business of the meeting. A copy of the Notice of Meeting will be placed on Brookfield Multiplex Capital’s website.
If investors cannot attend to vote on the motions proposed by appointing a proxy. The proxy form included with the notice of meeting will seek to explain clearly how the proxy form is to be completed and submitted.
Brookfield Multiplex Capital will request the auditor to attend each AGM to answer questions about the conduct of the audit and the preparation and contents of the Auditors Report.
Conflicts of Interest Policy
Introduction
Brookfield Multiplex Capital is dedicated to ensuring it conducts its investment management business in accordance with all applicable laws and regulations. As a manager of property and property related assets through a range of investment vehicles, and on behalf of retail and wholesale customers, there is potential for entities within Brookfield Multiplex Capital to be in a position of conflict when dealing with these clients.
Conflicts of interest can have a significant impact on the quality and integrity of the financial services provided to our clients
Definition
Conflicts occur when some or all of the interests of our clients are inconsistent with some or all of the interests of an Australian Financial Services Licence (“AFSL”) holder, or their representative providing the financial service to our client.
Purpose
The purpose of the Conflicts of Interest Policy is to document the measures that Brookfield Multiplex Capital has put in place to manage a range of matters that may result in actual or perceived conflicts of interest. This Policy is designed to demonstrate Brookfield Multiplex Capital’s commitment to having adequate conflicts management arrangements that are tailored to the nature, scale and complexity of its business.
Mechanisms for Managing Conflicts of Interest
Brookfield Multiplex Capital utilises three mechanisms for managing conflicts of interest. These are:
- controlling conflicts of interest;
- avoiding conflicts of interest; and
- disclosing conflicts of interest.
Brookfield Multiplex Capital will do more than simply disclose conflicts of interest. Our policies are focused on their control and avoidance where appropriate.
Whistle blowing Policy
Brookfield Multiplex supports employees should they have any concern associated with their employment and has adopted a separate Whistle-Blowing Policy to define the processes and protections available to employees.