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Authorised Representative No: 001264243

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Corporate Governance

Corporate Governance Policies 1

The Responsible Entity has adopted the following policies and charters, which have been prepared having regard to the ASX Corporate Governance Principles and Recommendations.

  • Code of Conduct – This policy sets out the standards of ethical behaviour and integrity that the Responsible Entity expects from its Directors, officers and any employees.
  • Continuous Disclosure Policy – The Trust must comply with the continuous disclosure requirements of the ASX Listing Rules and the Corporations Act to ensure the Trust discloses to the ASX any information concerning the Trust which is not generally available and which a reasonable person would expect to have a material effect on the price or value of the Units. This policy sets out the Trust’s procedures and measures which are designed to ensure that the Trust complies with its continuous disclosure obligations.
  • Risk Framework – This framework is designed to assist the Trust to identify, evaluate, monitor and manage risks affecting the Trust’s business.
  • Securities Trading Policy – This policy is designed to maintain investor confidence in the integrity of the Responsible Entity’s internal controls and procedures and in particular to provide guidance to Directors, executives and any employees on avoiding any conflicts of interest or breaches of insider trading laws.
  • Communications Policy – This policy sets out the practices which the Trust will implement to ensure effective and efficient communication with its Unitholders.
  • Diversity Policy – This policy sets out the Trust’s objectives for achieving diversity amongst its Directors, executives and any employees.
  • Compliance Plan – This plan sets out the procedures for the Responsible Entity to comply with the Corporations Act and the Constitution. This plan is overseen by a ‘Compliance Committee’ and the Responsible Entity’s compliance with it is audited annually.
  • Compliance Committee – The Responsible Entity has established the Compliance Committee with a majority of external members. A Compliance Committee charter governs the key aspects of the Compliance Committee.

Corporate Governance Statement: Vitalharvest Freehold Trust

Complaints Resolution

Primewest Management Ltd (the Manager) has complaints handling and dispute resolution procedures which it follows to acknowledge, investigate, respond to and resolve complaints by investors. If an investor has a complaint, they can contact Primewest Management Ltd during business hours on 08 9321 7133.

Primewest Management Ltd will use reasonable endeavours to deal with and resolve the complaint within a reasonable time but in any case no later than 45 days after receipt of the complaint.

If an investor is not satisfied with the resolution of the complaint, the complaint can be referred to the Australian Financial Complaints Authority (AFCA), an external complaints resolution scheme of which the Responsible Entity is a member.

The AFCA’s contact details are:

Address: GPO Box 3, Melbourne, Victoria 3001
Telephone: 1800 931 678

AFCA’ role and terms of reference are specified in AFCA’ Rules available from their website at