Macquarie Investment Management Global Limited

Allegations: ASIC AND MIML HAVE AGREED THAT MIML BREACHED THE AUSTRALIAN CORPORATIONS ACT IN CONNECTION WITH ITS ROLE AS RESPONSIBLE ENTITY OF THE VAN EYK BLUEPRINT INTERNATIONAL SHARES FUND (A REGULATED FUND UNDER THE ACT) (VBI) BY FAILING TO EXERCISE SUFFICIENT CARE AND DILIGENCE IN RELATION TO VAN EYK'S DECISION TO INVEST VBI IN A CAYMAN FUND CALLED ARTEFACT, THE ONGOING MONITORING OF VAN EYK IN RELATION TO THE ARTEFACT INVESTMENT, AND VBI'S LIQUIDITY. VAN EYK WAS INVESTMENT MANAGER OF VBI. Status: Final Summary: MACQUARIE INVESTMENT MANAGEMENT LIMITED (MIML) AND ASIC HAVE FILED JOINT COURT SUBMISSIONS RELATING TO AN AGREED SETTLEMENT OVER MIML'S ROLE AS RESPONSIBLE ENTITY OF ONE OF THE VAN EYK BLUEPRINT FUNDS, VAN EYK BLUEPRINT INTERNATIONAL SHARES FUND (VBI). VBI WAS ONE OF THE BLUEPRINT SERIES OF FUNDS OF WHICH VAN EYK RESEARCH PTY LIMITED (VAN EYK, NOW IN LIQUIDATION) WAS INVESTMENT MANAGER. THE SETTLEMENT RELATES TO A 2012 DECISION, BY VAN EYK AS MANAGER, FOR VBI TO INVEST IN A FUND MANAGED BY A COMPANY CALLED ARTEFACT. MIML WAS APPOINTED RESPONSIBLE ENTITY OF THE VAN EYK BLUEPRINT FUNDS IN 2003. ON 1 AUGUST 2014, AFTER MIML LEARNED THAT ARTEFACT, CONTRARY TO ITS INVESTMENT MANDATE, HAD INVESTED IN AN ILLIQUID INVESTMENT, MIML SUSPENDED APPLICATIONS AND REDEMPTIONS FROM VBI AND THE THREE DIVERSIFIED VAN EYK BLUEPRINT FUNDS WHICH HAD INVESTED IN VBI. MIML THEN TERMINATED THE RELEVANT VAN EYK FUNDS, RETURNING TO INVESTORS ALL OF THE LIQUID ASSETS IN THE FUNDS, AND PUT SIGNIFICANT RESOURCES INTO REALISING THE REMAINING ILLIQUID ASSETS OF THE FUNDS FOR INVESTORS. BY APRIL 2015 MIML HAD ALREADY RETURNED TO INVESTORS APPROXIMATELY 89% OF FUNDS IN THE VBI FUND, WITH THE BALANCE OF THESE PROCEEDS LAST MONTH BEING RETURNED TO VBI INVESTORS, RESULTING IN A 102.2% RETURN ON VBI'S UNIT VALUE AT TERMINATION. FOLLOWING THIS SIGNIFICANT RECOVERY ACTION BY MACQUARIE, THE ENTIRE $30 MILLION WHICH VAN EYK DECIDED THAT VBI INVEST IN ARTEFACT IN 2012 HAS NOW BEEN RETURNED TO INVESTORS. ASIC AND MIML HAVE AGREED IN TODAY'S SETTLEMENT THAT, AS RESPONSIBLE ENTITY, MIML DID NOT EXERCISE SUFFICIENT CARE AND DILIGENCE IN RELATION TO VAN EYK'S DECISION TO INVEST IN ARTEFACT, THE ONGOING MONITORING OF VAN EYK IN RELATION TO ARTEFACT, AND VBI'S LIQUIDITY. MIML FURTHER NOTES ASIC'S ACKNOWLEDGEMENT OF THE EFFORTS MADE BY MIML TO HAVE INVESTORS' FUNDS REPAID. THIS MATTER AROSE WITHIN MIML'S NON-CORE OUTSOURCED RESPONSIBLE ENTITY BUSINESS WHICH MIML IS NO LONGER PURSUING.

Allegations: ASIC AND MIML HAVE AGREED THAT MIML BREACHED THE AUSTRALIAN CORPORATIONS ACT IN CONNECTION WITH ITS ROLE AS RESPONSIBLE ENTITY OF THE VAN EYK BLUEPRINT INTERNATIONAL SHARES FUND (A REGULATED FUND UNDER THE ACT) (VBI) BY FAILING TO EXERCISE SUFFICIENT CARE AND DILIGENCE IN RELATION TO VAN EYK'S DECISION TO INVEST VBI IN A CAYMAN FUND CALLED ARTEFACT, THE ONGOING MONITORING OF VAN EYK IN RELATION TO THE ARTEFACT INVESTMENT, AND VBI'S LIQUIDITY. VAN EYK WAS INVESTMENT MANAGER OF VBI. Status: Pending Sanction Detail: NONE Summary: MACQUARIE INVESTMENT MANAGEMENT LIMITED (MIML) AND ASIC HAVE FILED JOINT COURT SUBMISSIONS RELATING TO AN AGREED SETTLEMENT OVER MIML'S ROLE AS RESPONSIBLE ENTITY OF ONE OF THE VAN EYK BLUEPRINT FUNDS, VAN EYK BLUEPRINT INTERNATIONAL SHARES FUND (VBI). VBI WAS ONE OF THE BLUEPRINT SERIES OF FUNDS OF WHICH VAN EYK RESEARCH PTY LIMITED (VAN EYK, NOW IN LIQUIDATION) WAS INVESTMENT MANAGER. THE SETTLEMENT RELATES TO A 2012 DECISION, BY VAN EYK AS MANAGER, FOR VBI TO INVEST IN A FUND MANAGED BY A COMPANY CALLED ARTEFACT. MIML WAS APPOINTED RESPONSIBLE ENTITY OF THE VAN EYK BLUEPRINT FUNDS IN 2003. ON 1 AUGUST 2014, AFTER MIML LEARNED THAT ARTEFACT, CONTRARY TO ITS INVESTMENT MANDATE, HAD INVESTED IN AN ILLIQUID INVESTMENT, MIML SUSPENDED APPLICATIONS AND REDEMPTIONS FROM VBI AND THE THREE DIVERSIFIED VAN EYK BLUEPRINT FUNDS WHICH HAD INVESTED IN VBI. MIML THEN TERMINATED THE RELEVANT VAN EYK FUNDS, RETURNING TO INVESTORS ALL OF THE LIQUID ASSETS IN THE FUNDS, AND PUT SIGNIFICANT RESOURCES INTO REALISING THE REMAINING ILLIQUID ASSETS OF THE FUNDS FOR INVESTORS. BY APRIL 2015 MIML HAD ALREADY RETURNED TO INVESTORS APPROXIMATELY 89% OF FUNDS IN THE VBI FUND, WITH THE BALANCE OF THESE PROCEEDS LAST MONTH BEING RETURNED TO VBI INVESTORS, RESULTING IN A 102.2% RETURN ON VBI'S UNIT VALUE AT TERMINATION. FOLLOWING THIS SIGNIFICANT RECOVERY ACTION BY MACQUARIE, THE ENTIRE $30 MILLION WHICH VAN EYK DECIDED THAT VBI INVEST IN ARTEFACT IN 2012 HAS NOW BEEN RETURNED TO INVESTORS. ASIC AND MIML HAVE AGREED IN TODAY'S SETTLEMENT THAT, AS RESPONSIBLE ENTITY, MIML DID NOT EXERCISE SUFFICIENT CARE AND DILIGENCE IN RELATION TO VAN EYK'S DECISION TO INVEST IN ARTEFACT, THE ONGOING MONITORING OF VAN EYK IN RELATION TO ARTEFACT, AND VBI'S LIQUIDITY. MIML FURTHER NOTES ASIC'S ACKNOWLEDGEMENT OF THE EFFORTS MADE BY MIML TO HAVE INVESTORS' FUNDS REPAID. THIS MATTER AROSE WITHIN MIML'S NON-CORE OUTSOURCED RESPONSIBLE ENTITY BUSINESS WHICH MIML IS NO LONGER PURSUING.

Allegations: ON THE BASIS OF THE ORDER AND OFFERS OF SETTLEMENT BY THE AFFILIATES THE COMMISSION FOUND THAT: 1) THE AFFILIATES SERVED OR ACTED AS AN INVESTMENT ADVISER TO REGISTERED INVESTMENT COMPANIES ("FUND SERVICE ACTIVITIES") AS OF APRIL 1, 2015 AND, NOTWITHSTANDING THE ENTRY OF AN INJUNCTION AGAINST AN AFFILIATE (MCUSA) ON THAT DATE, CONTINUED TO ENGAGE IN FUND SERVICE ACTIVITIES AFTER APRIL 1, 2015; 2) AS A RESULT OF THE ENTRY OF THE INJUNCTION AGAINST THE AFFILIATE, SECTIONS 9(A)(2) AND 9(A)(3) OF THE INVESTMENT COMPANY ACT TOGETHER ALSO PROHIBITED THE AFFILIATES FROM ENGAGING IN FUND SERVICE ACTIVITIES AS OF APRIL 1, 2015; 3) THE AFFILIATES DID NOT CONTACT THE COMMISSION STAFF TO BEING THE PROCESS OF OBTAINING EXEMPTIVE RELIEF UNTIL APRIL 7, 2015; AND 4) AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, EACH OF THE AFFILIATES VIOLATED SECTION 9(A) OF THE INVESTMENT COMPANY ACT. Status: Final Sanction Detail: N/A Summary: IN JULY 2015, THE AFFILIATES ENTERED INTO A SETTLEMENT OF AN ADMINISTRATIVE PROCEEDING WITH THE US SEC. THE AFFILIATES ARE EACH A SERIES OF THE REGISTRANT THAT ADVISE OR SUB-ADVISE REGISTERED INVESTMENT COMPANIES ("FUND SERVICE ACTIVITIES"). THE US SEC'S ORDER FOUND THAT THE AFFILIATES VIOLATED SECTION 9(A) OF THE INVESTMENT COMPANY ACT DUE TO ENGAGING IN FUND SERVICE ACTIVITIES FROM APRIL 1, 2015 THROUGH MAY 15, 2015 WITHOUT EXEMPTIVE RELIEF. DUE TO AN INJUNCTION AGAINST AN AFFILIATE ON APRIL 1, 2015, THE AFFILIATES REQUIRED EXEMPTIVE RELIEF UNDER SECTION 9 OF THE INVESTMENT COMPANY ACT TO CONTINUE TO BE ELIGIBLE TO PROVIDE FUND SERVICE ACTIVITIES AFTER APRIL 1, 2015. ON MAY 15, 2015, THE US SEC STAFF, ACTING UNDER DELEGATED AUTHORITY FROM THE US SEC, GRANTED TEMPORARY EXEMPTIVE RELIEF FROM SECTION 9(A) OF THE INVESTMENT COMPANY ACT WITH RESPECT TO THE INJUNCTION. ON AUGUST 3, 2015, THE SEC GRANTED TO MIMGL PERMANENT EXEMPTIVE RELIEF FROM THE PROVISIONS OF SECTION 9(A) INDICATING THAT THE SEC HAS DETERMINED THAT MIMGL HAS MET THE STANDARD FOR RECEIVING EXEMPTIVE RELIEF. WITHOUT ADMITTING OR DENYING THE VALIDITY OF THE US SEC'S FINDINGS, THE AFFILIATES EACH AGREED TO PAY A PENALTY OF $20,000.