Elevation Capital Management Limited

FSP Number: 9601

Disclosure Statement – Version 18

Date: 15 October 2019

The disclosures made in this document are required under the Financial Markets Conduct Act 2013 ("Act") and the Securities Markets (Investment Advisers and Brokers) Regulations 2007. The disclosures are made on behalf of Elevation Capital Management Limited (“Elevation Capital”) and the executives / contractors named below who act for it on a day-to-day basis.

Background to Elevation Capital Management Limited: Elevation Capital is a global fund manager established in October 2006 by Christopher Swasbrook (Managing Director), Craig Stobo (Chairman) and Andrew Harmos (Non-Executive Director). Elevation Capital currently manages the Elevation Capital Global Shares Fund [formerly Elevation Capital Value Fund].

Executives: Elevation Capital has three full-time executives Christopher Swasbrook (Managing Director & Portfolio Manager), Kevin Zou (Fund Operations, Compliance & Research), and Richard Milsom (New Business Development, Investor On-boarding & Communication/s) who are responsible for day-to-day operations. All executives receive remuneration by way of salary and an annual discretionary bonus from Elevation Capital for their duties.

All Executives and Directors each individually invest into the Elevation Capital Global Shares Fund on the same terms as all other investors.

Securities: Elevation Capital’s Managing Director & Portfolio Manager (Christopher Swasbrook), New Business Development, Investor On-boarding & Communication/s (Richard Milsom) and Chairman (Craig Stobo) are all available to discuss the structure and features of the Elevation Capital Global Shares Fund with investors and potential investors. They may also provide views and general comment in connection with global market developments and trends (including by way of email commentary or other research documents).

Elevation Capital, its executives and its directors do not provide investment advice in connection with any securities including in relation to the Elevation Capital Global Shares Fund.

Income: Elevation Capital receives a management fee from the Elevation Capital Global Shares Fund. There are no performance fees payable to the Manager. Additionally, the Manager does not receive any sales commission or brokerage in connection with the issue or sale of units in the Elevation Capital Global Shares Fund. All fees are clearly disclosed in the relevant Product Disclosure Statement (“PDS”) which is available on request or by visiting: www.elevationcapital.co.nz.

Procedures for dealing with investment money: Elevation Capital does not receive investment proceeds directly from investors. Such investment proceeds must be paid to the relevant Elevation Capital Applications Account. These bank accounts are held in the name of the Trustee – Public Trust ("PT"). Elevation Capital does not have access or signing authority to make external payments from these accounts.

Insurance: Elevation Capital has NZ$1mln of Public Liability Coverage with Berkshire Hathaway International Insurance Limited and a combined aggregate limit for both Professional Indemnity and Directors & Officers Insurance of NZ$1.5mln with Berkshire Hathaway International Insurance Limited.

Dispute Resolution: Should any dispute arise, investors should contact the Chairman of Elevation Capital – Craig Stobo to arrange a resolution. Elevation Capital is also a member of the Insurance & Financial Services Ombudsman Scheme ("IFSO") dispute resolution scheme. IFSO can be contacted by telephone: 0800 888 202, or in writing: PO Box 10845, Wellington 6143.

Legal Disclosures: Elevation Capital, its executives and its directors have not been: convicted of any offence against the Act or the Securities Act 1978 or of a crime involving dishonesty; a director or principal officer of a body corporate when that body corporate committed any offences or crimes involving dishonesty; adjudicated bankrupt; prohibited by an Act or by a court from taking part in the management of a company or business; subject to an adverse finding by a court in any proceeding that has been taken against them in their professional capacity; expelled from or prohibited from being a member of a professional body; or placed in statutory management or receivership.