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Cbus Policy Cbus Liquidity Management Plan Summary 1. Purpose and objectives of the policy 3. Governing legislation and regulatory requirements This document outlines the key elements of the United Super Pty Ltd (the Trustee) Liquidity Management Plan (the Plan) for the Construction and Building Unions Superannuation Fund (the Fund; Cbus). The key elements of the legislative requirements are contained within: ■■ Superannuation Industry (Supervision) Act 1993 (the SIS Act) ■■ Liquidity refers to the availability of Fund assets to meet its commitments. These assets include cash and other assets that can be converted to cash within 30 days, without a significant adverse impact on their value. Prudential Standard SPS 530 – Investment Governance 4. Definition of an illiquid investment and liquidity risk The Plan is designed to ensure that there are sufficient funds available to meet payments, transfers and withdrawals for Cbus’ members, while retaining member equity. The purpose of the Plan is to describe the Trustee’s understanding and definition of liquidity and liquidity risk in the context of the Fund, including setting out the principles and strategies the Trustee considers when managing liquidity risk in both normal and stressed liquidity environments. 2. Responsibilities and accountability Note that this is a summary of the policy. Date of this Policy: April 2016 Cbus’ Trustee: United Super Pty Ltd ABN 46 006 261 623 AFSL 233792 Cbus ABN 75 493 363 262 MySuper authorisation 75 493 363 262 473 05/16 The Trustee is at all times responsible for the Fund’s investments, including establishing, reviewing and giving effect to an investment strategy for each investment option that has regard to the liquidity of the investments covered in the strategy and the expected future cash flow requirements. The Trustee believes that it is appropriate for the Fund to take a long term view when making investment decisions and that by doing so it can increase the probability of achieving its investment objectives. The liquidity of an investment is generally considered to be a measure of how quickly it can be converted to cash, without negatively impacting its value. Hence, the key factors that influence liquidity levels in an investment relate to its nature and characteristics, such as: ■■ The type of investment, e.g. equity, bond, property; ■■ The structure of the investment, e.g. direct holding, units in a trust, pooled superannuation trust; ■■ The marketability of the asset; ■■ Whether the asset trades on listed or private markets; and ■■ The size of the holding relative to normal trading volumes. An illiquid investment is an investment that cannot be converted to cash within, or reasonably close to, 30 days or where conversion to cash over that period, by itself, would have a significant adverse impact on its realisable value. Liquidity risk for the Fund is the risk that the Fund is unable to meet its financial obligation to beneficiaries as they fall due, either at all or by selling assets at materially discounted prices. Liquidity Policy Summary page 2 5. Why invest in illiquid assets The Trustee believes that additional returns can be achieved through exposure to illiquid assets over the long term. As a long term investor, the Trustee believes it has an advantage over other investors that may have a shorter time horizon and that by investing in illiquid assets the Fund can benefit from an illiquidity premium (the additional return that can be obtained by investing in an illiquid asset). In addition to the illiquidity premium, exposure to illiquid assets can also provide the Fund with diversification benefits and a reduction in volatility, due to different exposures to risk factors and the appraisal based valuations of unlisted assets. However, the Trustee recognises that the Fund needs a degree of liquidity in each option in order to meet its ongoing obligations to beneficiaries and to ensure appropriate risk management and equity between transacting and non-transacting members. As such, the Trustee explicitly considers liquidity issues when setting the strategic asset allocations and target portfolios of each of the options offered to members. 7. Liquidity risk control framework, monitoring and reporting Trustee aims to further develop over time its systems and processes to identify lead indicators of increased likelihood of Liquidity Events. The Trustee’s Risk Register sets out the control framework for managing liquidity risk. 9. Liquidity events Overall, the Trustee is willing to accept a Moderate level of residual risk with respect to liquidity risk and has identified a number of risk indicators, aligned to its appetite, for various levels of illiquidity in the Fund. The Trustee has established a liquidity monitoring framework to routinely monitor a range of key lead indicators of liquidity risk. If the monitoring framework identifies a significant, or potentially significant, liquidity issue it must be raised with the Investment Committee Chairman as soon as practicable. 8. Liquidity management In summary, the Trustee’s approach to managing liquidity risk involves: ■■ ■■ 6. Liquidity profile of investments ■■ The Fund manages most of its investments via a pooled arrangement in which the underlying assets from each diversified option are invested collectively across the various asset classes. The allocation to these asset classes within each option is the main determinant of the overall risk and return characteristics, including an option’s liquidity profile. Hence, the Trustee first aims to understand the liquidity characteristics of each asset class before developing target exposures for the individual options. ■■ Explicitly considering liquidity when setting and reviewing asset allocations for each option; Monitoring key indicators of changes in net cash flow and/or investment markets; Regularly testing liquidity in the Fund over a range of stressed scenarios; and Maintaining a Liquidity Action Plan for managing liquidity crisis events. Whilst the Trustee has a Liquidity Action Plan to help guide its response to a full blown Liquidity Event, the Trustee’s strong preference is to avoid a Liquidity Event by identifying and responding to lead indicators that liquidity risk is building before a crisis eventuates. The Trustee has in place a comprehensive liquidity monitoring system, which is designed to identify such signs and allow the Fund to react before the liquidity crisis occurs. Identifying potential risks in advance is an area of focus for the Trustee. While it is not always possible, proactively avoiding risk is preferred to reacting after it materialises. As such, the A Liquidity Event is a significant, unexpected, increase in the exposure to illiquid assets. The Trustee considers a Liquidity Event to have occurred in the Fund when the allocation to illiquid assets in the Growth (Cbus MySuper) option rises, or is reasonably expected to rise, above 55 per cent. 10. Liquidity stress testing At least every six months, the Fund conducts a liquidity review that includes stress testing the Growth (Cbus MySuper) option to ensure the level of liquidity risk remains within the Trustee’s tolerance levels. The stress testing involves assessing the impact on liquidity from a series of shocks, with each shock calibrated on the basis of extreme movements in history. The shocks to be considered include (amongst other things): ■■ Sharp falls in equity markets; ■■ A material fall in the Australian dollar; ■■ An increase in member switching from the Growth option into cash; ■■ A significant reduction in net cash flows into the Fund. 11. Liquidity action plan The Fund has a Liquidity Action Plan that it can put in place if liquidity risk is deemed to be too high or if it reaches a maximum threshold. Generally there will be five phases to any liquidity action plan: ■■ Identification and evaluation of a potential liquidity crisis; ■■ Liquidity crisis escalation procedures; ■■ Consideration of the implementation of contingency measures; ■■ Implementation of the response; and ■■ Increased monitoring and reporting.