Continuous disclosure and updates

Cromwell Funds Management Limited (CFM) is the Responsible Entity of the Cromwell Phoenix Global Opportunities Fund ARSN 654 056 961 (the Fund).

As outlined in the PDS dated 26 October 2021, the Fund invests in a portfolio of internationally listed, predominantly small capitalisation securities, which at the time of their acquisition, are considered to be trading at discounts to their observable net asset values (NAVs). Investments are likely to be selected outside the constituents of global large capitalisation indices and will mostly have a free float market capitalisation of less than US$5 billion at the time of initial investment.

This means the Fund is benchmark unaware. The choice of a reference portfolio is indicative only and it can therefore change without any material impact.

CFM wishes to update the reference to benchmark in section 5.2 (Investment Return Objective) to

• outperform the Vanguard Total World Stock ETF (AUD) (“Benchmark”) after fees and costs.

A comparison of the previous reference benchmark to new can be seen below:

Chart – a comparison of the previous reference benchmark

_{The information contained in the PDS is up to date as at 26 October 2021. The update to the benchmark reference in the PDS contained in this notice does not contain any materially adverse information. Where permitted, updates to information contained in the PDS will be published as a continuous disclosure notice on the website for the Fund located at www.cromwell.com.au/gof. A paper copy of the PDS or any other updated information for the Fund will be given, or an electronic copy made available, to a person without charge upon request.}

_{If you have any questions or would like to know more about the Cromwell Phoenix Global Opportunities Fund, please visit www.cromwell.com.au/gof or contact Cromwell’s Investor Services Team on 1300 268 078 or email invest@cromwell.com.au.}

_{Cromwell Funds Management Limited ABN 63 114 782 777 AFSL 333 214 (CFM) has prepared this notice and is the responsible entity of, and the issuer of units in, the Cromwell Phoenix Global Opportunities Fund ARSN 654 056 961 (Fund). In making an investment decision in relation to the Fund, it is important that you read the product disclosure statement dated 26 October 2021 (PDS). A target market determination (TMD) is also available. The PDS and TMD are issued by CFM and are available from www.cromwell.com.au/gof or by calling Cromwell’s Investor Services team on 1300 268 078. This notice has been prepared without taking into account your objectives, financial situation or needs. Before making an investment decision, you should consider the PDS and assess, with or without your financial or tax adviser, whether the Fund fits your objectives, financial situation or needs. CFM and its related bodies corporate, and their associates, do not receive any remuneration or benefits for the general advice given in this notice. If you acquire units in the Fund, CFM and certain related parties may receive fees from the Fund and these fees are disclosed in the PDS. Phoenix Portfolios Pty Ltd ABN 80 117 850 254 AFSL 300 302 (Phoenix) is the investment manager of the Fund. None of CFM, Phoenix, nor their related entities, directors or officers makes any promise or representation, or gives any guarantee as to the success of the Fund, distributions, the amount you will receive on withdrawal, your income or capital return or the tax consequences of investing.}

_{Please note: Any investment, including an investment in the Fund, is subject to risk. If a risk eventuates, it may result in reduced distributions and/or a loss of some or all of the capital value of your investment. See the PDS for examples of key risks. Past performance is not a reliable indicator of future performance. Forward-looking statements in this notice are provided as a general guide only. Capital growth, distributions and tax consequences cannot be guaranteed. Forward-looking statements and the performance of the Fund are subject to the risks and assumptions set out in the PDS.}

Click here to view the Continuous Disclosure Notice.