INFORMATION MEMORANDUM VANTA FUND

Issuer and Australian Financial Services Licensee Primary Securities Ltd ABN: 96 089 812 635 AFSL: 224107

3 Shuffrey Street Fremantle WA 6160 Phone: 08 9430 5262 admin@primarysecurities.com.au www.primarysecurities.com.au

CONTENTS

IMPORTANT INFORMATION 1

KEY INFORMATION SUMMARY 2

INVESTMENT OVERVIEW 5

RISK MANAGEMENT 6

MANAGEMENT OF THE FUND 7

INVESTING IN THE FUND 9

BENEFITS AND RISKS OF INVESTMENT 11

FEES & OTHER COSTS 16

TAXATION 17

COMPLAINTS 19

REPORTING 20

FURTHER INFORMATION 21

WHOLESALE CLIENT INFORMATION 23

GLOSSARY 25

CORPORATE DIRECTORY 28

IMPORTANT INFORMATION This is an important document that should be read in its entirety. If you do not understand it you should consult your professional advisers without delay. The Units offered by this Information Memorandum should be considered speculative. This Information Memorandum relates to the issue of units of the Vanta Fund (the Fund) and is offered to a limited number of parties (Recipients) who are invited to evaluate the opportunity to acquire units within the Fund. National Capital Management Pty Ltd (Investment Manager) is the Investment Manager of the Fund and is appointed as a corporate authorised representative (CAR 001275742) of Primary Securities Ltd (Trustee) to act as the Investment Manager and to give general advice in relation to the Fund. Primary Securities Ltd is the trustee of the Fund and issues units under an Australian Financial Services Licence (AFSL 224107). The information in this document is not intended to be relied upon as personal advice to investors or potential investors and has been prepared without taking into account the Recipient’s investment objectives, financial circumstances or particular needs. Recipients of this document are advised to consult their own professional advisers as to the legal, tax, financial or other matters relevant to the suitability of an investment in units of the Fund. An investment in any unit trust, including the Fund, is subject to risks of potential loss of income and the potential loss of capital as a result of specific events. RISKS An investment in the Fund is subject to investment and other known and unknown risks, some of which are beyond the control of the Investment Manager and Trustee and their directors, employees, advisers or agents. The Investment Manager and Trustee do not guarantee any rate of return or the performance of the Fund, nor does the Investment Manager or Trustee personally guarantee the repayment of capital or any tax treatment. Each investment in the Fund must be made by a Wholesale Client or Sophisticated Investor (as defined under the Corporations Act). REPRESENTATIONS LIMITED TO CONTENTS OF THIS IM No person has been authorised to make any representations concerning the Fund that are inconsistent with those contained in this Information Memorandum, as supplemented from time to time, and no person may rely on any such other information or representations if they are given or made. This offering is suitable only for investors whose need for liquidity is consistent with the limitations on redemption and transferability described in this Information Memorandum. INTENDED FOR DISTRIBUTION IN AUSTRALIA ONLY The distribution of this Information Memorandum, the Application Form (including electronic copies) outside Australia may be restricted by law. This Information Memorandum does not, and is not intended to, constitute an offer or invitation in any other place or jurisdiction in which, or to any person to whom, it would not be lawful to make such an offer or invitation. If you come into possession of these documents, you should observe such restrictions and should seek your own advice about such restrictions.

KEY INFORMATION SUMMARY FUND NAME Vanta Fund (the Fund)

NATURE OF THE OFFER The investment being offered is units in the Fund which is a unit trust. The Investment Manager intends to 'soft close' the Fund to further investment when assets under management reach capacity.

FUND'S OBJECTIVE The objective of the Fund is to provide you with long term capital growth without material correlation to any Australian asset class. Investments will be made in Australian and US corporate markets in the following asset classes: • Equities • Bonds • Commodities

FUND HOLDINGS Approximately 4-20 Investments at any given time

INVESTMENTS HELD The Fund will invest in equity securities listed on any global exchange however mainly the ASX and NYSE exchanges. The Fund will hold long and short positions [Maximum long exposure 70%, Maximum short exposure 30%]. Derivatives may be utilised to hedge against falling markets as well as for returns in rising markets. The Fund intends to hold a minimum of 10% cash.

INVESTMENT STRATEGY Long positions will be considered on companies/commodities which satisfy the following criteria; • Current price below intrinsic value; • Growth prospects in industry are expanding; • Structural/political change favouring the entity’s situation. Short positions will be considered if a company is situated with inverse conditions to the above criteria. Top down analysis will be utilised where the Investment Manager will pick a thematic industry shift/trend and filter down to the best exposures in ASX or US equity markets. The Fund looks for trends in both micro and macro levels. The macro level is determined by demographic, the micro by shorter-term factors such as corporate and private spending patterns. To spot trends, the Fund subscribes to various industry trade journals, global newspapers, forums, and every available news service.

MINIMUM INVESTMENT $10,000

RECOMMENDED INVESTMENT TIMEFRAME At least 2 years.

ISSUE PRICE The Trustee will issue Units in different Series, depending on when an investment in the Fund is made. As investors may apply for Units at different times, a separate and distinct Series of Units will be issued at each Valuation Date on which investor applications are received. The issuance of a new Series will enable Performance Fees to be allocated equitably among Unit Holders. As of each Valuation Date, the Fund will issue a new Series of Units at a Unit Price of $1.00.

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RISK PROFILE The Fund’s investments mean that the Fund is higher risk in nature. It is important that Unit Holders understand that the Fund bears high month-to-month volatility in exchange for stronger long-term capital growth. The principle risks associated with the Fund include: • changes in assets in which the Fund has invested; • the performance of investment markets generally; • key man risk to the management of the Fund. For more details

with respect to risks see Benefits and Risks of Investment

INVESTMENT MANAGER National Capital Management Pty Ltd (ABN: 19 155 702 042) (the Investment Manager)

REGULATORY National Capital Management Pty Ltd is a corporate authorised representative (CAR 001275742) of Primary Securities Ltd (ABN: 96 089 812 635 AFSL: 224107)

TRUSTEE Primary Securities Ltd (ABN: 96 089 812 635 AFSL: 224107)

ADMINISTRATOR Primary Securities Ltd (ABN: 96 089 812 635 AFSL: 224107)

ELIGIBLE INVESTORS Wholesale Clients and Sophisticated Investors as defined by the Corporations Act.

APPLICATIONS Please refer to Appendix A for instructions on investing in the Fund Applications are generally accepted at month end, subject to the request and cleared funds being received at least three business days before the end of the month.

MINIMUM INITIAL INVESTMENT

The minimum initial investment is $10,000. The Investment Manager and the Trustee may change the minimum investment from time to time.

MINIMUM SUBSEQUENT INVESTMENT The minimum subsequent investment amount for the Fund is $10,000.

REDEMPTIONS You may redeem all or part (subject to the minimum redemption amount) of your investment by submitting a redemption request. Redemptions are effect at month end, subject to the redemption request being received at least three business days before the end of the month.

MINIMUM REDEMPTION The minimum redemption amount for the Fund is $10,000

SOFT LOCK-UP Redemptions are discouraged within the first 12 months of investment to enable the fund to achieve its desired performance. If Units are redeemed within the first 12 months of investment, an exit fee of 5% of the total Net Asset Value of the Units will apply. The Trustee and Investment Manager have discretion to waive any exit fee in whole or in part.

DISTRIBUTIONS The net income of the Fund will be distributed to Unit Holders annually, as 30 June. Unit Holders may elect to receive all or some of the distributions in cash or otherwise all distributions will be reinvested in the Fund, unless otherwise advised on the Application Form or in writing or by email to registry@primarysecurities.com.au.

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MANAGEMENT FEE 1.5% plus GST per annum

PERFORMANCE FEE 15% plus GST of the increase in the unit price where a High Water Mark is exceeded. A High Water Mark ensures that performance must exceed the previous unit valuation before receiving any performance fee. This ensures the Fund cannot receive a benefit more than once for the same performance.

EXPENSES Expenses (Trustee fees, administration, accounting, secretarial) will be paid by the Investment Manager. Transactional expenses (brokerage, stamp duty, bank chargers, custodian fees) will be charged to the Fund.

INCEPTION DATE 2 May 2019

DATE OF THIS INFORMATION MEMORANDUM 13 May 2019

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INVESTMENT OVERVIEW INVESTMENT PHILOSOPHY The Fund will invest in Global equities, commodities, currencies & bonds. The aim is providing Unit Holders in the Fund above average returns by investing in opportunities that arise as a result of a combination of the strategies explained below. INVESTMENT PROCESS RESEARCH – TOP DOWN The Investment Manager will be looking for companies that reflect trends that their research has revealed to offer potential sustained rewards for Unit Holders. The Investment Manager will be vigilant for changes in these trends as they may occur. The Investment Manager is constantly analysing various industry trade journals, global live news feeds and forums. INTRISIC VALUE The Fund will invest in companies, commodities, derivatives which satisfy the above criteria that is, if the Investment Manager’s research predicts the current price of the asset is below intrinsic value. There is a relationship between Intrinsic value factors to market price. These are:

• General market factors: o Technical o Manipulative o Psychological

• Future value factors: o Management and reputation o Competitive conditions and prospects o Possible and probable changes in volume, price and costs

• Intrinsic value factors: o Earnings o Dividends o Assets o Capital structure o Terms of the issue o Other

In an uncertain environment this form of fundamental analysis is considered by the Investment Manager to be a safer method of investing for above average returns. INVESTMENT IMPLEMENTATION The Fund will establish an investment portfolio across the following asset classes:

• US and Australian equities & derivatives of these assets • Commodities involving derivatives • Currencies involving physical and derivatives

In order to fully achieve the best returns possible, the Investment Manager will invest in the asset instruments mentioned above., Liquidity is an important part of the Fund, the Investment Manager will be investing in mainly liquid assets.

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RISK MANAGEMENT Risk is a very important consideration in achieving a desired return. The Trustee and Investment Manager take risk management seriously. Risk is defined as the possibility of loss or injury (Buffet,1993). Traditional models for calculating risk (Sharpe ratio, Beta) have proven to be incredibly inaccurate in determining volatility of an asset. The Investment Manager believes the real way to limit risk is to be diligent in forecasting. In the event an investment does not behave as predicted, the Investment Manager will be reanalysing the position and will decide whether to liquidate the position given the new scenario regarding the asset. Investing in the Fund will lead to the unit price fluctuating every month. It’s important to know the Investment Manager is aiming to achieve above average returns over for the long term of the Fund. Speculation in asset classes is rife with short term desires, therefore large swings in the price of an asset without a change in fundamentals will not necessarily lead to a liquidation of the asset. Volatility in returns will be common and is considered normal. To reduce fund downside volatility and investment drawdowns, the Investment Manager may protect the equity investments of the Fund against specific market corrections by hedging market risk. The Investment Manager has access through its prime broker to short many equities, commodities and currencies. This provides a hedge against downward market conditions which will profit the Fund. In addition to hedging, the Investment Manager will continuously adjust the position sizes and the level of cash in the Fund. The mandate states that at least 10% of assets under management held in cash, this can be up to 100% at the Investment Managers discretion.

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MANAGEMENT OF THE FUND INVESTMENT MANAGER The investment manager of Fund is National Capital Management Pty Ltd (ABN: 19 155 702 042). The Trustee may terminate the Investment Management Agreement with immediate effect at any time by written notice to the Investment Manager if the Investment Manager suffers an Insolvency Event; makes one or more investments which do not comply with the Investment Strategy set out in this Information Memorandum; does not remedy a breach within 10 days; fails its annual assessment or there is a breach of warranty. JAMES NAUGHTON, B Com James is the founder, CEO and CIO of National Capital Management Pty Ltd. After graduating from university, James became a stockbroker at the age of 21. He has previously worked with Morgan Stanley and Patersons securities in the equities division. James provided services to clients by providing advice to family offices, institutional investors and sophisticated investors. James has a Bachelor of Commerce majoring in Corporate Finance, Investment Finance, Financial Accounting with a minor in Law. TRUSTEE AND ADMINISTRATOR – PRIMARY SECURITIES LTD The trustee and administrator of the Fund is Primary Securities Ltd ABN 96 089 812 635 which holds AFSL No 224107. The Trustee was formed in 1999 and currently operates registered and unregistered schemes throughout Australia. The Trustee’s focus is to look after the interests of Unit Holders using the qualities, capabilities and experience of its team. The Trustee’s four executive directors, professional and administrative employees plus lawyers, accountants, analysts, and scheme specific consultants have many years of practical and professional experience. Further information regarding the Trustee is available by looking at its website www.primarysecurities.com.au. THE TRUSTEE’S ROLE The Trustee has the legal responsibility to operate the Fund and act on behalf of Unit Holders in accordance with the Trust Deed and its fiduciary obligations. Information about the fees that the Trustee receives from the Fund, and its entitlement to expenses incurred in operating the Fund are set out in Fees and Other Costs. THE TRUSTEE’S BOARD OF DIRECTORS The Trustee’s board comprises David Butterfield, Robert Garton Smith and Natasha Olsen. DAVID BUTTERFIELD, ACA, FTI Chairman of Primary Securities Ltd David Butterfield is a Chartered Accountant and Management Consultant with significant professional experience. His professional career commenced in 1969 when he worked for Touché Ross & Co and then Price Waterhouse & Co. He commenced his own accounting practice in 1977.

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Since then David has been involved in pooled investments. Around 50% of his clients were film and/or television producers. David structured and helped fund numerous Australian productions over a thirty-year period. He has also been instrumental in structuring and funding live productions. Since 2003 he has been the Managing Director of two funds management businesses in property, securities and derivatives, CFO and COO of an institutional funds management business investing in securities and derivatives and also acts as a Responsible Manager on other AFSL's mainly with a property focus. His specialties include AFSL advice, strategic advice, project and transaction management, taxation and general business advice. ROBERT GARTON-SMITH, LLB, B Com, GDipFinPlanning (Sec Inst), F Fin Managing Director of Primary Securities Ltd Robert Garton-Smith is the Managing Director and owner of Primary Securities Ltd and has been its responsible manager in relation to managed investments since inception. He has degrees in law, commerce and financial planning and is a legal practitioner as well as being a Fellow of the Financial Services Institute of Australia. He is a member of the Law Society of Western Australia and the Australian Compliance Institute. Robert has worked in the area of managed investments since preparing Australia's first feature film prospectus in 1981. He has prepared and overseen dozens of managed investment schemes relating to film, forestry, viticulture, horticulture, manufacturing, mortgages, equities and real estate, and also prepared share, debenture stock and unsecured notes issues. Robert has practiced law since 1970 and is admitted as a practitioner in Australia, England and Wales. He remains the principal of the corporate and commercial law practice Garton Smith & Co, which now has a small practice advising in relation to managed investments, corporate, real estate and intellectual property. NATASHA OLSEN, LLB Director/Company Secretary of Primary Securities Ltd Natasha has a Bachelor of Laws Degree from Notre Dame University and was admitted to practice law by the Supreme Court of Western Australia in November 2015. Natasha is a member of The Law Society of Western Australia. With the exception of two years in London, Natasha has been employed by Primary since its formation and has considerable experience of all aspects of the business. Natasha is in charge of operations.

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INVESTING IN THE FUND ELIGIBILITY TO INVEST The Fund is open to Wholesale Clients and Sophisticated Investors as defined by the Corporations Act. The Fund is not open to investors in the USA or any of its territories or protectorates. MINIMUM INVESTMENT Initial Investment The minimum initial investment amount for the Fund is $10,000 and may only be made using the Application Form on the website of the Trustee. You can invest any amount over that minimum. The minimum initial investment amount may change from time to time. Additional Investment Additional investments may be made by existing Unit Holders and must be for a minimum of $10,000. Additional investments may only be made by using the Application Form on the website of the Trustee. APPLICATIONS If you decide that you wish to invest in this Information Memorandum for the Fund, please complete and submit an Application Form found on the website of the Trustee and by providing the relevant certified identification documents. Applications for new Units are processed monthly on the last day of each month (Valuation Date) at which time Units will be issued. Once applications have been approved and Units allotted a confirmation will be sent to applicants as soon as practicable after the relevant valuation date setting out details of the Units that applicants have applied for. Application money should be paid by electronic funds transfer into the following bank account Bank: Westpac Banking Corporation Account Name: Primary Securities Ltd as trustee for the Vanta Fund BSB: 036-048 Account Number: 452473 Reference Your Unit Holder Name The Trustee has the right to accept or reject any Application in whole or in part in its absolute discretion. No Units will be issued unless and until the relevant Application Money has been received in cleared funds. APPLICATION PRICE OF UNITS Series Class Units The Trustee will issue Units in different Series, depending on when an investment in the Fund is made. As Unit Holders may apply for Units at different times, a separate and distinct Series of Units will be issued at each Valuation Date on which Unit Holder applications are received. The issuance of a new Series will enable Performance Fees to be allocated equitably among Unit Holders. As of each Valuation Date, the Fund will issue a new Series of Units at a Unit Price of $1.00. Series Class of Units Units issued in a Series will have income and capital entitlements that may differ from that of Units in each other Series. Every Series of Units in the Fund will only bear Performance Fees relating to the actual performance of that respective Series of Units.

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Consolidation of Series Class of Units The Trustee in consultation with the Investment Manager, may for some or all issued Series of Units in respect of which a Performance Fee has been paid, consolidate those particular Series of Units into a single Series of Units from time to time, if necessary, by redeeming and reissuing Units. If a Performance Fee has not been paid in respect to a particular Series of Units, then that Series of units will retain its identity as a separate and distinct Series of Units. REDEMPTION At the end of every month, Unit Holders may redeem their investment if they wish to do so, subject to giving notice to do so at least five business days prior to the end of the month. The Administrator will process redemptions on the Valuation Date and the redeeming Unit Holder will receive a return of their initial investment within 2 weeks of the Valuation Date. The Trust Deed provides that the Trustee may take up to 180 days to pay redemption proceeds, subject to any suspension. The Trustee expects that this will usually only take up to 14 days, however, in unusual circumstances, payment of redemption proceeds may take longer. For more information on the action the Trustee take to mitigate the risk of delayed payment see “Fund Liquidity Risk”. Investments that are withdrawn within the 12 month time period are subject to a 5% redemption fee. The Investment Manager and Trustee reserves the right to waive this fee. DISTRIBUTIONS The Administrator will pass on all Distributions half yearly within 30 days after receipt from the Fund. Distributions will be paid to Unit Holders after calculating distributable income for the year ended 30 June each year. The Trustee gives notice that in some circumstances, it may pay distributions more frequently than once a year, in which case Unit Holders will receive an interim distribution. Unit Holders may elect to receive all or some of the distributions in cash or otherwise all distributions will be reinvested in the Fund, unless otherwise advised. SUSPENSION The Trustee may temporarily suspend the determination of the Net Asset Value, the issue or redemption of Units and the payment of redemption proceeds, during any period or part thereof: • if a Force Majeure event exists;

• if the realisation of Investments by the Fund is not possible or cannot be affected at prices which

would be realised if the Investments by the Fund were realised in an ordinary functioning market;

• if there is a breakdown or failure in the systems including communication failure of the Trustee or of any administrator or agent appointed by the Trustee or a breakdown or failure of any other means of communication normally employed to determine the value of the Investments by the Fund on an ongoing basis.

Any suspension will be notified to Unit Holders in writing and where possible, all reasonable steps will be taken to promptly bring any period of suspension to an end. The Trustee may suspend the Management Fee and Performance Fee during any period of suspension. In the event of a suspension where you have lodged a redemption request, you may cancel the redemption request at any time provided that such cancellation is received before the termination of the period of suspension. Where the request is not cancelled, the day on which the redemption of the Units will be affected will be the first redemption date following the end of the suspension.

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BENEFITS AND RISKS OF INVESTMENT SIGNIFICANT BENEFITS Some of the benefits which can be obtained by investing in the Fund include the following:

• No entry fees;

• Specialist knowledge and monitoring – the Investment Manager has extensive experience and knowledge of portfolio management and derivative transactions. Professional investment management expertise allows the Investment Manager to research and monitor the markets daily.

PRINCIPAL RISKS OF INVESTMENT IN THE FUND Before you make an investment decision, it is important to identify your investment objectives and the level of risk you are prepared to accept. This may be influenced by factors such as:

• The timeframe over which you are expecting a return on your investment and your need for regular income versus longer-term capital growth.

• Your level of comfort with volatility in returns.

• The general and specific risks associated with this indirect investment in the Fund.

• Risks associated with the structure through which your investments are made. As such, it may be important for you to obtain personal advice about your financial circumstances and needs, as well as the suitability of the Fund. GENERAL RISKS All investments have an inherent level of risk. Generally, there is a trade-off between higher expected returns for higher expected risk – represented by the variability of investment returns. Investment risk may also result in loss of income or capital invested and possible delays in repayment. Unit Holders could receive back less than they initially invested and there is no guarantee that they will receive any income. SPECULATIVE FINANCIAL PRODUCTS RISK The Investment manager may invest in speculative investments with increased levels of investment risk. The value of the Fund’s investments may fall or fluctuate widely which will affect the investments held. Changes in economic, political or market conditions or the regulatory environment may adversely impact the Fund and its investments. In addition, other factors may affect investments (i.e. interest rates, exchange rates) and consequently the value of the Fund may fall. There are no assurances that the Investment Manager will anticipate these developments. UNDERPERFORMANCE OF THE FUND’S INVESTMENT STRATEGY The strategy chosen for the Fund may underperform its stated performance objectives, even if the general market performs well. Neither the Trustee nor the Investment Manager can assure performance of the investment strategy, so underperformance of the Investment Manager is one of the key risks for the Unit Holder. The decision to exercise discretions, or not to exercise them, can adversely or profitably affect the value of the investments and therefore also the investment returns. Unit Holders have no recourse to the Trustee or the Investment Manager for how either of them exercise any of their discretions.

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GEARING RISK If the securities are internally geared the usual risks arising from gearing apply. Although gains on the capital invested may be magnified, so may losses in the event of one or more negative investment experiences. SCHEME RISK There are risks particular to investing in the Fund including that the Fund could be terminated, fees and charges could change, the Trustee could be changed and so too could the Investment Manager. There are risks involved in the proper monitoring of the Investment Manager (to ensure portfolio directions are consistent with the Fund’s investment mandate), in executing transactions and also holding of the Fund’s assets. KEY MAN RISK The main to risk to the Fund is key man risk in relation to the Investment Manager, James Naughton. CURRENCY RISK The Fund invests in overseas securities which are purchased in the currency of the securities and not in Australian Dollars (AUD). The value of the securities will also be affected if there are movements between the value of the foreign currency and the AUD. This is particularly important if the AUD rises compared to the foreign currencies as losses may occur. The Fund actively manages all currency exposures. OPERATIONAL RISKS The internal systems and practices of the Investment Manager may cause losses. For example, if the systems and practices are not stringently carried out losses may be incurred by not placing or selling securities expeditiously, or trading the wrong securities, or by making incorrect payment instructions. REGULATORY RISK This is the risk that a government or regulator may affect the value of securities of the Fund, by introducing regulatory or tax changes. MARKET RISK Economic, technological, political or legislative conditions and even market sentiment can (and do) change and this can mean that changes in the value of investment markets can affect the value of investments held in the Fund. LIQUIDITY RISK Liquidity risk is the risk that the Trustee or the Investment Manager will have difficulty in realising Financial Products necessary to fund withdrawals in a timely manner. For example, illiquid securities that are rarely traded on the ASX or are restricted or suspended from trading may not be able to be sold quickly, if at all. MARGIN CALL RISK The Fund may be exposed to margin calls, whereby the Fund must either deposit additional funds or suffer mandatory liquidation of the pledged securities. Margins and positions will be constantly monitored to reduce this risk. This can occur in Derivatives trading when prices move adversely against the open position and requires the Fund to deposit more cash or close out trades. In equity trading Margin Calls can be triggered by adverse movements in the price of the equities held that were purchased by borrowed funds or a Margin Loan, the impact is the same, the Fund must either deposit cash or sell Financial Products held. The Fund is only expected to have a gearing ratio of up to 25%. DIVERSIFICATION RISK Lack of diversification across asset classes by the Fund (for example equities, bonds, commodities, currencies and cash) may result in returns having higher volatility. However, this risk is limited considering the mandate of the Fund.

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DERIVATIVE RISK A range of financial derivatives, for example, futures and options, may be used to implement investment decisions and to manage risk in the Fund. An investment in derivatives is a sophisticated financial product and can result in gains or losses that are large in proportion to the money invested in them. The Fund does not intend to enter into any derivative transactions that are not exchange traded. LEVERAGE RISKS The use of leverage, while aimed at increasing the opportunity of providing positive returns, can also increase the risk of losses. When the Fund trades Financial Products on a leveraged basis a relatively small price movement in the Financial Product may result in immediate and substantial losses to the Fund. This may result in losses in excess of the amount invested. Conversely, gains realised may cause the Net Asset Value to increase at a faster rate than would otherwise be the case without leverage. The Fund is only expected to have a gearing ratio of up to 25%. Currently the Fund only trades on Financial Products available through the Interactive Brokers platform. LEVERAGE RISK CARRIES HIGHER FEES The Investment Manager may leverage the Fund’s Financial Products by using Derivatives which may cause the Fund to assume a larger exposure to a Financial Product by posting a much smaller amount as a margin. When this occurs, the gain or loss is calculated based on the full amount (or face value) of the derivative, not the amount of the margin. Fees associated with Derivatives are also determined by the full value of the Derivative and these would include Transaction Costs and interest or funding costs. These fees would also vary depending on the derivative or leverage used. Borrowing Risk There is a risk that the Fund will not be able to repay borrowed funds in certain circumstances or that a rise in interest rates will increase the interest payable on borrowed funds. Borrowing (not including leverage due to derivatives positions) by the Fund will be restricted to 70% of NAV. COUNTERPARTY RISK This risk is the risk that a counterparty to a given agreement may not meet its contractual obligations. Obviously, this risk can be managed by choosing to deal with counterparties with superior risk profiles. DISCRETION RISKS The Trustee vests certain discretion with the Investment Manager, including in the operational implementation of the Fund, adjustments following corporate actions, the timing of transactions, and the method used to dispose of securities on the sale of securities. STOCK SELECTION RISKS Within each asset class, individual securities like shares can be affected by risks that are specific to that security. For example, the value of a company’s shares can be influenced by changes in a company’s management, its business environment or profitability. These can also impact on the company’s ability to repay its debt. INVESTING IN NON-FIXED INTEREST RISK Generally, a fall in interest rates will reduce the income generated by non-fixed interest Financial Products held by the Fund. There is a risk that the issuer of the Financial Products will not be able to meet principal and interest payments as and when they become due. A rise in interest rates will affect adversely the value of non-fixed interest Financial Products.

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DEFAULT RISKS Debt assets of the Fund are subject to default risk that may expose the Fund to loss on crystallisation or enforcement against registered security such as real property that does not achieve return of the capital position of the Fund. HEDGING RISK Normally, a Hedge consists of taking an offsetting position in a related security, such as a Derivative. Risks that may arise to the Fund when using Derivatives as a Hedge are liquidity risks and pricing risk when trying to unwind the Hedge; there could be slippage and the Hedge may not be able to be unwound at the same price as the original asset. There could also be margin calls should the price move adversely against the hedge. Having a hedged position would also eliminate gains on the original trade should the price move in favour of the original trade. SHORT SELLING RISKS The Fund may engage in selling Financial Products short. Short selling allows the Unit Holder to profit from declines in market prices to the extent such declines exceed the Transaction Costs and the costs of borrowing the Financial Products. A short sale creates the risk of an unlimited loss, as the price of the underlying Financial Product could theoretically increase without limit, thus increasing the cost of buying those Financial Products to cover the short position. There can be no assurance that the Financial Products necessary to cover a short position will be available for purchase. Purchasing Financial Products to close out the short position can itself cause the price of the securities to rise further, thereby exacerbating any loss. REALISATION RISK The risk the Fund may not be able to withdraw from or sell any part of all of the Financial Products held by the Fund at fair value. SERVICE PROVIDER RISKS The failure of any of the service providers used by the Fund may also affect the returns on investment, for example if the Trustee, Investment Manager or other underlying agents fail to perform their obligations. CUSTODIAN RISK The Fund holds its investments through its Custodian, Interactive Brokers LLC. If the Custodian loses the assets (whether through incompetence or by defalcation or any other method) this can cause losses to the Fund. Generally, however, all assets are held separately from the assets of the Custodian and therefore not subject to loss through insolvency. VALUATION RISK Valuation risk is prevalent where the assets are illiquid or unlisted, for example: real estate. The Fund however limits its investments to listed assets that trade in liquid financial markets. On occasions, trades on specific securities may be halted which may cause problems in relation to the valuation of the relevant securities RISKS ASSOCIATED WITH LIMITED OPERATING HISTORY The Investment Manager has extensive experience in making and recommending investments in Financial Products of the type proposed for the Fund, but the Investment Manager and the Fund have limited operating history. In addition, there can be no assurance that the investment performance of the Fund will be comparable to that of the investments previously made by the Investment Manager. Moreover, past performance is not a reliable indicator of future performance. RISK MITIGATION Full time risk monitoring is conducted at the trading desk level by the Investment Manager via the use of a risk analysis platform. Risk parameters are programmed, and any breaches are flagged and addressed. Risk is monitored independently of the trading desk at monthly risk meetings, which include parties independent of the Investment Manager. The Trustee also monitors investments and risk reports regularly.

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This enables the Trustee to ensure that the Fund’s investments are compliant with investment mandate. Unit Holders are encouraged to obtain independent legal, accounting and/or financial planning advice in relation to this Offer.

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FEES & OTHER COSTS MONTHLY FEES AND EXPENSES The Investment Manager charges a monthly fee of 1/12th of 1.5% plus GST of the Net Asset Value of the Fund. These fees payable monthly from the Fund. PERFORMANCE FEE The Investment Manager charges a performance fee equal to 15% plus GST of the increase in the Net Asset per Unit where the High Water Mark is exceeded. The Performance Fee is calculated and payable six monthly as at 30 June and 31 December. TRUSTEE & ADMINISTRATION FEES OF THE FUND Nil. Fees are to be paid by the Investment Manager. TRANSACTION COSTS/CUSTODIAN FEES As incurred in the normal trading of the Fund’s strategy. These costs will be incurred by the Fund. TRANSFER FEE For each transfer of the Units in the Fund by the Unit Holder, a $100 plus GST fee will be incurred and payable to the Trustee. EXIT FEE If units are redeemed within 12 months from the time of investment, the Trustee will apply a 0.5% of the total NAV per unit of each series, redeemed, to be paid to the Investment Manager. The Trustee and Investment Manager reserve the right to waive any exit fees. MARKETING EXPENSES The Investment Manager may employ and make payment to persons or entities that provide various Unit Holder relations and placement agent related services. These fees will be paid by the Investment Manager. EXPENSES The Investment Manager is responsible for meeting all general expenses of the Fund (excluding brokerage or transaction fees incurred for buying and selling investments) out of the Management Fee. ADDITIONAL EXPLANATION OF FEES AND COSTS The High Water Mark is the previous highest Net Asset Value per Unit of the Fund at the end of the most recent period in respect of which a Performance Fee was paid to the Investment Manager, or where no such fee has been paid, the initial issue price of the Units

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TAXATION There are tax implications that arise when investing in the Fund, about which the Trustee or the Investment Manager do not provide advice. Due to the complex and fluid nature of the Australian taxation regime, and the potentially complex taxation and/or social security implications of investing, Unit Holders should obtain professional advice regarding their own circumstances. Unit Holders should be aware that the tax treatment of their investment and distributions depend on their own particular circumstances. The Trustee and the Investment Manager recommend you consult your own professional tax advisers before making an investment in the Fund. At the end of the Fund’s financial year, Unit Holders will be provided with details of assessable income, capital gains, tax credits and any other relevant tax information referable to entitlements from the Funds. Whilst the Fund has provision for separate classes, all Assets of the Fund may be taxed without regard to separate classes which may impact on distributions or on the winding up of the Fund. While the Trustee is a registered tax adviser, any reference to tax is incidental and must be confirmed with your own tax adviser or registered tax agent. Before investing in the Fund, prospective investors should seek their own independent tax advice in relation to the taxation implications which may arise from investing in the Fund. TAXATION OF THE FUND The Fund itself does not normally pay income tax as all taxable income is distributed to Unit Holders in proportion to their Unit holding. Although the Fund should not be subject to Australian tax, distributions made by the Fund will generally be included in the assessable income of a Unit Holder. The Trustee will provide you with details of any portion of any distribution that is tax-free or tax-deferred, together with any imputation credit entitlement, foreign tax credit entitlement or capital gain arising in respect to the distribution. The taxable amount distributed must be included in your assessable income for the year in which the distribution was made. TAXATION OF AUSTRALIAN RESIDENT INVESTORS The tax comments below relate to Australian resident Unit Holders who hold their Units in the Fund on capital account. A resident Unit Holder will be assessed on his/her share of the net taxable income of the Fund to which they are entitled for a particular income year (even if the distribution is reinvested in additional Units in the Fund). Capital gains tax liabilities may arise on the disposal of Units and Unit Holders should obtain professional advice prior to making a decision to redeem their Units. CAPITAL GAINS TAX You may be subject to capital gains tax on the disposal of Units. In this regard, a redemption or transfer will constitute a disposal of Units for capital gains tax purposes. The calculation of a Unit Holder’s capital gain or loss may also be affected by any tax-free or tax-deferred distributions made by the Fund. TAXATION OF NON-RESIDENT UNIT HOLDERS Unit Holders who identify themselves as non-residents on the Application Form are treated as non-residents and distributions may be subject to the relevant withholding tax provisions of the Australian income tax laws.

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Non-resident Unit Holders should seek professional tax advice regarding their local, as well as Australian, tax obligations. GOODS AND SERVICES TAX (GST) The Fund is registered for GST. The issue or redemption of Units in the Fund and receipt of distributions are not subject to GST. The Fund may be required to pay GST included in management and other fees, charges costs and expenses incurred by the Fund. However, to the extent permissible, the Trustee will claim on behalf of the Fund a proportion of this GST as a reduced input tax credit. Unless otherwise stated, fees and charges quoted in this IM are exclusive of GST and take into account any available input tax credits. If the Trustee is unable to claim input tax credits on behalf of the Fund, the Trustee retains the ability to recover the entire GST component of all fees and charges. The impact of GST payments and credits will be reflected in the Unit Price of the Fund. Unit Holders should seek professional advice with respect to the GST consequences arising from their Unit holding. TAX INDEMNITY In the event that the Trustee incurs a liability for any kind of tax or impost on account of a Unit Holder, the Trustee has broad powers of recoupment from income due to the Unit Holder. In the event that the Trustee is required under any statutory or common law to pay tax in its capacity as Trustee of the Fund, the Trustee is empowered under the Trust Deed to pay the tax from the Assets of the Fund. TAX FILE NUMBER OR AUSTRALIAN BUSINESS NUMBER (ABN) You should advise us of your TFN, ABN or alternatively provided exemption details when you make an application to become an investor. If you do not advise us of your TFN, ABN or alternatively provided exemption details, you may have tax deducted from your distributions at the highest marginal tax rate plus the Medicare Levy and the Deficit Repair levy. This taxation information is of a general nature only. Investors should seek their own advice in relation to their own circumstances.

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COMPLAINTS

DISPUTES RESOLUTION AND COMPLAINTS HANDLING PROCEDURES The Trustee has appointed solicitor Anna Catelli, B Juris., LLB., Dip. Ed., as its Complaints Officer. If you have a complaint please contact the Trustee: Telephone: 08 9430 5262 Email: catelli@primarysecurities.com.au Post PO Box 732, Fremantle WA 6959 COMPLAINTS HANDLING METHODS – WHOLESALE CLIENTS The Trustee will deal with all Complaints made by Complainants who are Wholesale Clients according to the following methods: (a) all Complaints are to be acknowledged promptly;

(b) Complaints that do not require investigation are to be resolved immediately or expeditiously;

(c) otherwise, within 21 days of the Complaint being made, the Complaint is to be investigated, the

Complainant is to be given an opportunity to provide information, the Complaint is to be properly considered, and a report is to be prepared;

(d) a decision is to be made by the Managing Director and the decision communicated to the Complainant with the reasons for the decision within 28 days of the Complaint being made;

(e) at the same time of advising the Complainant of the outcome of the Complaint the Trustee will also advise the Complainant that they may complain to the Australian Financial Complaints Authority (AFCA) should the Complainant be unhappy with the outcome of the Trustee’s Complaint handling procedure. Wholesale Clients should be aware that AFCA is available in very limited circumstances to Wholesale Clients;

(f) if AFCA is not available to the Complainant, the only avenues are dispute resolution services, arbitration or litigation.

AFCA may be contacted: • by phone on 1300 931 678; • by email to info@afc.org.au • by writing to GPO Box 3, Melbourne , VIC 3001. AFCA will first invoke a conciliation process. If the Complainant still does not get a satisfactory outcome the Complainant has the right to have the matter arbitrated by an adjudicator or panel. Each Complaint is handled in confidence and without affecting any legal rights of the Complainant should they remain dissatisfied. Any issues arising from complaints that have material ramifications for other Unit Holders shall be reported by the Complaints Officer to the board of the Trustee.

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REPORTING Unit Holders in the Fund are provided with comprehensive reporting comprised of the following: TRANSACTION CONFIRMATION REPORT You will receive a Confirmation Report for any applications and redemptions to and from the Fund. MONTHY UNIT HOLDER STATEMENT You will receive a monthly Unit Holder statement summarised by the Investment Manager for Vanta Fund. The statement details your total unit holdings, applicable unit price, current value of your investment and concise review from the Investment Manager. DISTRIBUTION REPORTS You will receive a Distribution Report upon allocation of any annual (or special) distribution notifying you of the value of your reinvestment and/or payment to your nominated bank account. ANNUAL TAXATION STATEMENT If the Fund has paid a distribution during the financial year you will receive a Taxation Statement. These are issued annually to provide you with taxation information including a detailed summary of the components of distributions that have been paid. MONTHLY PERFORMANCE REPORTS You will receive a Monthly Report that provides an overview of the Fund’s performance.

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FURTHER INFORMATION TRUST DEED The Trust Deed is available for inspection at the offices of the Trustee during normal business hours or by contacting Primary by email at registry@primarysecurities.com.au and requesting that a copy be made available to you. The Trustee may amend the Trust Deed. Operation of the Fund The Fund has been established and will operate and conduct its business in accordance with the requirements and conditions of Australian law including the Australian Corporations Act, the Australian Corporations Regulations and any relevant policy of the ASIC as they shall relate to the provision of financial services or the operation of a financial services business in Australia. The Fund is also subject to various other controls and similar laws and regulations in other jurisdictions. Limitation of Liability The Trust Deed contains Limitation of Liability provisions indemnifying the Trustee in respect of the Fund’s activities that are broader than the protections that would apply in the absence of those provisions. In general, the Trustee (and all employees, directors and agents) are to be held harmless from any losses arising out of activities involving the Fund, except to the extent that those losses are found to have resulted from gross negligence, fraud or dishonesty of the Trustee. The Trustee agrees, under the terms of the investment management agreement between the Trustee and the Investment Manager, that the Investment Manager (and all employees, directors and agents) will be indemnified and held harmless by the Trustee against any losses arising out of activities involving the Fund, except to the extent that those losses are found to have resulted from gross negligence, fraud or dishonesty. Management of Conflicts of Interest In the conduct of the Fund’s business, conflicts may arise between the interests of the Investment Manager and/or those of the Trustee and those of Unit Holders. In such event, Unit Holders acknowledge and consent to the Investment Manager’s and the Trustee’s good faith exercise of discretion in handling the Fund’s business so that should any conflict of interest arise, it is resolved fairly. Other Activities The Trustee and the Investment Manager are not restricted from entering into other investment relationships or engaging in other business activities, even though those activities may be in competition with the Fund and/or may involve substantial amounts of the Trustee’s or our time and resources. The Investment Manager may in the future serve as the investment manager of other investment funds and/or pooled investment vehicles, as well as separate client accounts. The Trustee may offer a range of other products and services to the Investment Manager and other clients including acting as placement agent for the Fund or other funds with similar investment objectives. These activities could be viewed as creating a conflict of interest in that our time, effort and resources are not devoted exclusively to the business of the Fund, but must be allocated between that business and the other activities. The performance of other accounts that the Investment Manager may manage - even those with substantially the same investment objectives as the Fund’s - can be expected to differ from the Fund’s performance. This may be due to, among other things, differences in overall size, available cash at the time investment opportunities become available, and portfolio composition at the time of applications to or redemptions from the Fund or the relevant other accounts.

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Anti-Money Laundering/Counter-Terrorism Financing (AML/CTF) Laws The Fund must comply with anti-money laundering laws, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, which requires the Trustee of the Fund to have an AML/CTF Program and comply with a range of other requirements. Under the Trustee’s AML/CTF Program and the AML/CTF Act, the Trustee is required to collect and verify certain identification information (Know Your Customer (KYC) Information) from all Unit Holders in the Fund. If you do not provide the KYC Information when requested, processing of applications or redemptions may be delayed or refused. The Trustee may be required to disclose your personal information or your transactions to the Australian Transaction Reports and Analysis Centre (AUSTRAC). Under AML/CTF laws, the Trustee may be required to deny you (on a temporary or permanent basis) access to your Units. This could result in a loss of the capital invested, or you may experience significant delays when you wish to transact on your Units. The Trustee or Investment Manager are not liable for any loss you may suffer as a result of compliance with AML/CTF laws. US Foreign Account Tax Compliance Act (FATCA) /Common Reporting Standards As part of the application process you must complete a self certification form. This form is being used to comply with legislation which gives effect to the OECD Common Reporting Standard and the US legislation known as FATCA. The Trustee is required to collect and report to the Australian Taxation Office (ATO) certain information about the tax residency of account holders. The ATO shares this information with the competent authorities of other jurisdictions as a means of countering global tax evasion. For more information, refer to the ATO website: http://www.ato.gov.au Privacy By completing the Application Form, you are providing personal information for the primary purpose of the Trustee and Investment Manager providing this product to you. Information supplied by you on your Application Form and held by the Trustee includes your name, address, tax file number, bank account details, telephone contact numbers and identification information. Details of your investment holdings and transactions in the Fund and distribution instructions are also held. This information may be disclosed to the service providers of the Fund, including the Investment Manager, legal firms, accounting firms, auditors, consultants and other advisers for the purpose of Unit Holder servicing, reporting and administering your investment and the Fund. It is currently not proposed to disclose your personal information to any overseas based recipients. Without the provision of your personal information, it may be impossible to process your application or provide an appropriate level of service to you. Your information may be accessed by regulatory bodies when required by law, such as the ATO, ASIC, AUSTRAC and other Australian and International government organizations. In most cases your personal information will be collected directly from you although the Trustee or Investment Manager may also collect your personal information from third parties such as a financial planner, including where information is missing from the application form that you send. The Trustee and Investment Manager manage your personal information in accordance with the Privacy Act 1988 and the Trustee’s Privacy Policy. The Trustee’s Privacy Policy outlines how you may access the information the Trustee holds about you and how you may seek to correct this information if you believe it is incorrect or out of date. It also contains information about how you may complain about a possible breach of privacy and how the Trustee will deal with such a complaint. You can obtain a copy of the privacy policy and any additional information you require relating to how your personal information is managed by writing to the Trustee, whose contact details are shown in the Corporate Directory.

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WHOLESALE CLIENT INFORMATION Following is a summary of the main categories of what constitutes a “wholesale client”.

1. Invest at least $500,000 at one time (excluding superannuation monies).

2. Invest at least $500,000 together with an associate at one time (excluding superannuation monies).

Reasons the Unit Holder and someone else can be associated include: The other person is a trustee of a trust in

relation to which the Unit Holder benefits or is capable of benefiting.

The other person is a person with whom the Unit Holder is acting in concert, or proposes to act in concert, in respect of the investment.

The other person is a person with whom the Unit Holder is, or is proposing to become associated, whether formally or informally, in any other way in respect of the investment.

3. The Unit Holder and a body corporate which the Unit Holder wholly owns and controls together invest at least $500,000 in aggregate.

See below for the meaning of ‘control’.

4. The Unit Holder has an accountant’s certificate that shows that they have net assets of at least $2.5 million or gross income for each of the last two financial years of at least $250,000. The certificate must not be more than 2 years old.

And in calculating the $2.5 million or $250,000 the Unit Holder can include the net assets or gross income (as relevant) of any company or trust it controls. See below for meaning of ‘control’.

5. The Unit Holder is a company or trust controlled by someone who has an accountant’s certificate as mentioned in number 4.

‘Control’ means you have the capacity to determine the outcome of decisions about the company or trust’s financial and operating policies. The practical influence you can exert (rather than the rights you can enforce) is the issue to be considered and any practice or pattern of behaviour affecting the company or trust’s financial or operating policies is to be taken into account (even if it involves a breach of an agreement or a breach of trust).

6. The Unit Holder is a business which is not a small business.

A small business is one that employees less than 100 employees if that business is or includes the manufacture of goods, or otherwise is a business which employs less than 20 people.

7. The Unit Holder is a subsidiary or holding company of another body corporate which is a wholesale client.

8. The Unit Holder has a financial services licence.

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9. Unit Holder is the trustee of a superannuation fund with net assets of at least $10 million.

10. The Unit Holder controls at least $10 million.

Including any amount held by an associate or under a trust that the Unit Holder manages.

11. The AFSL holder considers the Unit Holder to be a sophisticated Unit Holder.

a. The Trustee or another AFSL holder must be

satisfied on reasonable grounds, that the client has previous experience in using financial services and investing in financial products that allows the client to assess: (i) the merits of the Trust; (ii) the value of the Units in the Trust; (iii) the risks associated with holding

Units in the Trust; (iv) the client’s own information needs

and (v) the adequacy of the information

given by the Trustee.

b. The Trustee or the other AFSL holder must give the client before or at the time when the Units are issued, a written statement of the Trustee’s or AFSL holder’s reasons for being satisfied as stated above.

c. The client must sign a written statement before or at the time when the product or service is provided, acknowledging that the Trustee or other AFSL holder:

(i) Has not provided the client a Product Disclosure Statement or any other document that would normally be required to be given to a retail client and

(ii) has no other obligations towards the client that would apply if the client were retail.

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GLOSSARY ABN means Australian Business Number

AFSL means Australian Financial Services Licence

Allotment means the allotment of Units to Unit Holders

AMIT means attribution managed investment trust

AML/CTF Act means the Anti-Money Laundering and Counter-Terrorism Financing Act 2006

Applicant means any person who has completed and delivered to Primary or to a duly authorised lawful agent of Primary an Application and made payment or provided other consideration as required on the Application but who is not yet an Unit Holder

Application means an application to become a Unit Holder using the Application Form that accompanies this information memorandum

Application Form means the application form in relation to this information memorandum on Primary’s website or that accompany this information memorandum

Application Money means the Issue Price per Unit payable by an Applicant with their Application

ASIC means the Australian Securities and Investments Commission established under the Australian Securities and Investments Commission Act, 2001, or any delegate thereof

Assets means the sum of all the assets of the Fund

ASX means Australian Stock Exchange

ATO means Australian Tax Office

AUD means Australian dollar

AUSTRAC means the Australian Transaction Reports and Analysis Centre

Australia means the Commonwealth of Australia and includes all its territories

Authority means any Federal, State or local governmental or other public body or authority of any kind, including any relevant Minister of the Crown having jurisdiction in relation to the matter

Buffet means Warren Buffet the US financier

CEO means chief executive officer

CFO means chief financial officer

CIO means chief investment officer

Complainant means a person making a Complaint; Complaint means any expression of dissatisfaction with the service offered or provided whether internal or external, and if external, whether by an Unit Holder or otherwise

COO means chief operating officer

Corporations Act means the Corporations Act 2001 of the Commonwealth of Australia

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and includes any rule, regulation, notice, order, policy or by-law made under that act

Correlation is a measure of how investments move in relation to one another and when. When assets move in the same direction at the same time, they are considered to be highly correlated. When one asset tends to move up when the other goes down, the two assets are considered to be negatively correlated

Custodian means Interactive Brokers LLC

Derivatives means an arrangement or product (such as a future, option, or warrant) whose value derives from and is dependent on the value of an underlying asset, such as a commodity, currency, or security

FATCA/CRS means the US Foreign Account Tax Compliance Act/Common Reporting Standard

Financial Products means investments made in Global equities, commodities, currencies & bonds

Financial Year means the period from 1st July (unless from the context the period must commence later by reason that it is the first such period) to 30th June inclusive in the next following year (unless from the context the period must conclude earlier by reason that it is the last such period)

Fund means the Vanta Fund

Hedge means where the Fund makes an investment to reduce the risk of adverse price movements in an asset. Normally, a hedge consists of taking an offsetting position in a related asset, such as, buying a position to offset a sold trade, using a derivative or purchasing a related option

High Water Mark means the Net Asset Value of the Fund at the end of the most recent period after a performance fee was paid

GST means the goods and services tax imposed under A New Tax System (Goods and Services Tax) Act 1999 or other laws implementing the GST including all amendments

Investment Manager means National Capital Management Pty Ltd ABN 19 155 702 042

Issue Price means the amount of $1.00 per Unit for the initial offer, and thereafter means the Net Asset Value plus Transaction Costs on the last day on which the Net Asset Value was calculated prior to the issue of the Units divided by the number of Units on issue, rounded up or down as appropriate to the nearest one tenth of one cent (or otherwise as Primary decides)

KYC means Know Your Client

Long (position) means the buying of a security such as a stock, commodity or currency with the expectation that the asset will rise in value. In the context of options, long is the buying of an options contract

NAV or Net Asset Value means the value of the assets less the liabilities of the Fund

NCM or National Capital Management means the investment manager of Fund

NYSE means New York Stock Exchange

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Offer means the offer to issue Units in the Fund made pursuant to this IM

Options means the right but not obligation to acquire or sell an asset

Register means the register of the Unit Holders

Series means the units of a distinct and separate series of the Fund

Short (position) means the selling of a security that the seller does not own

Sophisticated Investor means an investor as defined in section 708(8)(c) and (d) or section 761GA of the Corporations Act

State means a State of Australia and also includes a Territory of Australia

Transaction Costs means when calculating the Issue Price of a Unit, the amount that Primary reasonably estimates as reflecting any costs and expenses including any Taxes which would be incurred if all the Assets were to be acquired at the relevant time and excluding the cost of the Assets, but Primary Entity may (subject to the Corporations Act) at any time in connection with a particular Application treat these costs to be a lesser sum or zero

Trust Deed means the Trust Deed for Fund dated 2 May 2019

Trustee means the Trustee of the Fund, Primary Securities Ltd ACN 089 812 635, AFSL No 224107

Unit means one of the equal undivided interests comprising an interest in assets and income of the Fund

Unit Holder means the person (or in the case of joint Unit Holders or successors or permitted assignees, each of those persons) who becomes a Unit Holder in the Fund as a result of either: • the Allotment of Units; • the transmission, transfer, mortgage, assignment or other

disposal of Units pursuant to the Trust Deed and the provisions of the Corporations Act, the expression Unit Holders means all the Unit Holders for the time being in the Fund.

US means United States

USD means US dollar

Wholesale client has the same meaning as in the Corporations Act

Valuation Date means generally the last day of the month when the Net Asset Value of the Fund is calculated, or any other date at the discretion of the Trustee, with the approval of the investment manager

Vanta means the Vanta Fund, a unit trust established under the Trust Deed

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CORPORATE DIRECTORY INVESTMENT MANAGER National Capital Management Pty Ltd ACN 155 702 042 CAR 001275742 Suite 1, 105 Forrest Street, Cottesloe, Western Australia, 6011 Phone: +61433 847 474 Email: james.naughton@vantafund.com Website: vantafund.com TRUSTEE AND ADMINISTRATOR Primary Securities Ltd ABN 96 089 812 635 Australian Financial Services Licence No 224107 3 Shuffrey Street, Fremantle, Western Australia 6160 Phone: (08) 9430 5262 Email: registry@primarysecurities.com.au Website: www.primarysecurities.com.au PRIMARY’S DIRECTORS David Butterfield (Chairman) Robert Garton-Smith (Managing Director) Natasha Olsen CUSTODIAN OF VANTA FUND Interactive Brokers LLC

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