UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-CSR
CERTIFIED SHAREHOLDER REPORT OF REGISTERED
MANAGEMENT INVESTMENT COMPANIES
Investment Company Act file number 811- 0560
John Hancock Investment Trust
(Exact name of registrant as specified in charter)
200 Berkeley Street, Boston, Massachusetts
02116
(Address of principal executive offices) (Zip code)
Salvatore Schiavone
Treasurer
200 Berkeley Street
Boston, Massachusetts 02116
(Name and address of agent for service)
Registrant's telephone number, including area code: 617-663-4497
Date of fiscal year end: | March 31 |
Date of reporting period: | March 31, 2020 |
ITEM 1. REPORTS TO STOCKHOLDERS.
John Hancock
Diversified Real Assets Fund
Annual report
3/31/2020
Beginning on January 1, 2021, as permitted by regulations adopted by the Securities and Exchange Commission, paper copies of the fund's shareholder reports like this one will no longer be sent by mail, unless you specifically request paper copies of the reports from the fund or from your financial intermediary. Instead, the reports will be made available on a website, and you will be notified by mail each time a report is posted and provided with a website link to access the report.
If you already elected to receive shareholder reports electronically, you will not be affected by this change, and you do not need to take any action. You may elect to receive shareholder reports and other communications electronically by calling John Hancock Investment Management or by contacting your financial intermediary.
You may elect to receive all reports in paper, free of charge, at any time. You can inform John Hancock Investment Management or your financial intermediary that you wish to continue receiving paper copies of your shareholder reports by following the instructions listed above. Your election to receive reports in paper will apply to all funds held with John Hancock Investment Management or your financial intermediary.
A message to shareholders
Dear shareholder,
Global financial markets were on pace to deliver strong returns during the 12 months ended March 31, 2020, until heightened fears over the coronavirus (COVID-19) sent markets tumbling during the last five weeks of the period.
In response to the sell-off, governments and banks in some of the hardest hit areas throughout the world enacted policies and stimulus efforts designed to reignite their respective economies. While these measures helped lift equity and fixed-income markets in the United States during the final two weeks of March, results were mixed in other areas of the world.
The continued spread of COVID-19, trade disputes, rising unemployment, and other geopolitical tensions may continue to create uncertainty among businesses and investors. Your financial professional can help position your portfolio so that it's sufficiently diversified to seek to meet your long-term objectives and to withstand the inevitable bouts of market volatility along the way.
On behalf of everyone at John Hancock Investment Management, I'd like to take this opportunity to welcome new shareholders and thank existing shareholders for the continued trust you've placed in us.
Sincerely,
Andrew G. Arnott
President and CEO,
John Hancock Investment Management
Head of Wealth and Asset Management,
United States and Europe
This commentary reflects the CEO's views as of this report's period end and are subject to change at any time. Diversification does not guarantee investment returns and does not eliminate risk of loss. All investments entail risks, including the possible loss of principal. For more up-to-date information, you can visit our website at jhinvestments.com.
John Hancock
Diversified Real Assets Fund
Table of contents
2 | Your fund at a glance | |
4 | Manager's discussion of fund performance | |
6 | A look at performance | |
8 | Your expenses | |
10 | Fund's investments | |
18 | Financial statements | |
21 | Financial highlights | |
22 | Notes to financial statements | |
29 | Report of independent registered public accounting firm | |
30 | Tax information | |
31 | Statement regarding liquidity risk management | |
34 | Trustees and Officers | |
38 | More information |
INVESTMENT OBJECTIVE
The fund seeks a long-term total return in excess of inflation.
AVERAGE ANNUAL TOTAL RETURNS AS OF 3/31/2020 (%)
The MSCI World Index is a free float-adjusted market capitalization weighted index that is designed to measure the equity market performance of developed markets.
It is not possible to invest directly in an index. Index figures do not reflect expenses or sales charges, which would result in lower returns.
Figures from Morningstar, Inc. include reinvested distributions and do not take into account sales charges. Actual load-adjusted performance is lower. Since inception returns for the Morningstar fund category average are not available,
The past performance shown here reflects reinvested distributions and the beneficial effect of any expense reductions, and does not guarantee future results. Performance of the other share classes will vary based on the difference in the fees and expenses of those classes. Shares will fluctuate in value and, when redeemed, may be worth more or less than their original cost. Current month-end performance may be lower or higher than the performance cited, and can be found at jhinvestments.com or by calling 800-225-5291. For further information on the fund's objectives, risks, and strategy, see the fund's prospectus. The fund recently experienced negative short-term performance due to market volatility associated with the COVID-19 pandemic.
PERFORMANCE HIGHLIGHTS OVER THE LAST TWELVE MONTHS
The real assets category experienced significant headwinds
The outbreak of COVID-19 weighed heavily on the financial markets in February and March, pressuring returns for the full 12 months.
The fund underperformed its benchmark
Stock selection in energy, together with an overweight in the sector, was the primary cause of the shortfall.
Real estate and infrastructure also posted negative returns
The two categories, while losing ground, held up better than the energy and materials sectors.
SECTOR COMPOSITION AS OF
3/31/2020 (%)
A note about risks
The fund may be subject to various risks as described in the fund's prospectus. A widespread health crisis such as a global pandemic could cause substantial market volatility, exchange-trading suspensions and closures, impact the ability to complete redemptions, and affect fund performance. For example, the novel coronavirus disease (COVID-19) has resulted in significant disruptions to global business activity. The impact of a health crisis and other epidemics and pandemics that may arise in the future could affect the global economy in ways that cannot necessarily be foreseen at the present time. A health crisis may exacerbate other pre-existing political, social, and economic risks. Any such impact could adversely affect the fund's performance, resulting in losses to your investment. For more information, please refer to the "Principal risks" section of the prospectus.
Financial assets experienced a large decline, with all of the downturn occurring in the final two months of the period. Prior to this sell-off, financial assets generally posted gains due to the favorable backdrop of positive economic growth, accommodative policies by world central banks, and progress in the trade dispute between the United States and China. The supportive environment changed abruptly late in the period once it became clear COVID-19 was evolving into a global pandemic. As governments moved to contain the virus through shutdown measures, estimates for economic growth and corporate earnings both fell sharply.
Natural resource stocks were particularly hard hit in the downturn due to their cyclical nature, a steep decline in commodity prices, and worries that some companies may not be able to survive a long period of economic weakness. Real estate investment trusts (REITs), which were hurt by the potential for falling property prices and concerns that many tenants may not be able to make their rent payments, also underperformed. Infrastructure stocks, while losing ground on an absolute basis, held up relatively well by virtue of their long-lived, essential assets and the relative strength of the utilities sector.
What factors affected the fund's performance?
Stock selection in the energy and materials sectors detracted from performance, as did overweight allocations to these areas. We reduced the fund's allocation to the energy portfolio late in the period.
How did each of the fund's managers perform?
The fund consists of five underlying portfolios, each of which invests in a different segment of the real assets category and is managed against a benchmark specific to that category.
Three of the underlying portfolios outperformed their respective benchmarks: global infrastructure, U.S. REITs, and non-U.S. REITs. The infrastructure portfolio benefited from strong stock selection and an overweight in the outperforming utilities sector. Outperformance in the U.S. REIT area stemmed from its underweights in the regional mall and hotel categories, the two worst-performing segments in the sector. In the non-U.S. portfolio, outperformance was driven largely by security selection in Canada, United Kingdom, and Singapore.
The energy and materials sectors underperformed their respective benchmarks. In each case, sector allocation was the primary detractor from results. An overweight in exploration and production stocks was the largest detractor in the energy portfolio, while an underweight in gold producers hurt performance in materials.
MANAGED BY
Diversified Real Assets Fund is managed by a team of portfolio managers across three different asset managers. |
TOTAL RETURNS FOR THE PERIOD ENDED
MARCH 31, 2020
Average annual total returns (%)
with maximum sales charge |
Cumulative total returns (%)
with maximum sales charge |
||||||||
1-year |
Since
inception1 |
Since
inception1 |
|||||||
Class NAV2 | -30.92 | -14.98 | -28.80 | ||||||
Index | -10.39 | -4.80 | -9.78 |
Performance figures assume all distributions have been reinvested.
The expense ratios of the fund, both net (including any fee waivers and/or expense limitations) and gross (excluding any fee waivers and/or expense limitations), are set forth according to the most recent publicly available prospectus for the fund and may differ from those disclosed in the Financial highlights tables in this report. Net expenses reflect contractual expense limitations in effect until July 31, 2021 and are subject to change. Had the contractual fee waivers and expense limitations not been in place, gross expenses would apply. The expense ratios are as follows:
Class NAV | |
Gross (%) | 0.94 |
Net (%) | 0.88 |
Please refer to the most recent prospectus and annual report for more information on expenses and any expense limitation arrangements for each class.
The returns reflect past results and should not be considered indicative of future performance. The return and principal value of an investment will fluctuate so that shares, when redeemed, may be worth more or less than their original cost. Due to market volatility and other factors, the fund's current performance may be higher or lower than the performance shown. For current to the most recent month-end performance data, please call 800-225-5291 or visit the fund's website at jhinvestments.com.
The performance table above and the chart on the next page do not reflect the deduction of taxes that a shareholder would pay on fund distributions or the redemption of fund shares. The fund's performance results reflect any applicable fee waivers or expense reductions, without which the expenses would increase and results would have been less favorable.
| Index is the MSCI World Index. |
See the following page for footnotes.
This chart and table show what happened to a hypothetical $10,000 investment in John Hancock Diversified Real Assets Fund for the share class and the periods indicated, assuming all distributions were reinvested. For comparison, we've shown the same investment in the MSCI World Index.
Start date |
With maximum
sales charge ($) |
Without
sales charge ($) |
Index ($) | |
Class NAV2 | 2-26-18 | 7,120 | 7,120 | 9,022 |
The MSCI World Index is a free float-adjusted market capitalization weighted index that is designed to measure the equity market performance of developed markets.
It is not possible to invest directly in an index. Index figures do not reflect expenses or sales charges, which would result in lower returns.
Footnotes related to performance pages
1 | From 2-26-18. |
2 | For certain types of investors, as described in the fund's prospectus. |
Your expenses |
8 | JOHN HANCOCK DIVERSIFIED REAL ASSETS FUND | ANNUAL REPORT |
Account
value on 10-1-2019 |
Ending
value on 3-31-2020 |
Expenses
paid during period ended 3-31-20201 |
Annualized
expense ratio |
||
Class NAV | Actual expenses/actual returns | $1,000.00 | $ 700.60 | $3.70 | 0.87% |
Hypothetical example | 1,000.00 | 1,020.70 | 4.40 | 0.87% |
1 | Expenses are equal to the annualized expense ratio, multiplied by the average account value over the period, multiplied by 183/366 (to reflect the one-half year period). |
ANNUAL REPORT | JOHN HANCOCK DIVERSIFIED REAL ASSETS FUND | 9 |
Fund’s investments |
Shares | Value | ||||
Common stocks 97.8% | $668,400,409 | ||||
(Cost $988,920,504) | |||||
Communication services 1.6% | 11,109,873 | ||||
Diversified telecommunication services 0.5% | |||||
China Tower Corp., Ltd., H Shares (A) | 14,278,000 | 3,172,584 | |||
Media 0.7% | |||||
Charter Communications, Inc., Class A (B) | 5,202 | 2,269,685 | |||
Comcast Corp., Class A | 75,583 | 2,598,544 | |||
Wireless telecommunication services 0.4% | |||||
KDDI Corp. | 103,900 | 3,069,060 | |||
Consumer discretionary 0.2% | 1,244,059 | ||||
Hotels, restaurants and leisure 0.2% | |||||
Hyatt Hotels Corp., Class A (C) | 25,972 | 1,244,059 | |||
Energy 26.2% | 179,304,167 | ||||
Energy equipment and services 1.3% | |||||
Apergy Corp. (B)(C) | 69,745 | 401,034 | |||
Baker Hughes Company | 134,265 | 1,409,783 | |||
Calfrac Well Services, Ltd. (B)(C) | 264,890 | 45,174 | |||
Halliburton Company | 207,989 | 1,424,725 | |||
Helmerich & Payne, Inc. | 28,680 | 448,842 | |||
National Oilwell Varco, Inc. | 19,428 | 190,977 | |||
Patterson-UTI Energy, Inc. | 350,552 | 823,797 | |||
Precision Drilling Corp. (B)(C) | 872,715 | 272,859 | |||
Schlumberger, Ltd. | 185,360 | 2,500,506 | |||
TechnipFMC PLC | 158,455 | 1,067,987 | |||
Transocean, Ltd. (B) | 258,753 | 300,153 | |||
Trican Well Service, Ltd. (B)(C) | 728,853 | 233,059 | |||
Oil, gas and consumable fuels 24.9% | |||||
Advantage Oil & Gas, Ltd. (B) | 923,011 | 937,899 | |||
Aker BP ASA | 116,073 | 1,455,970 | |||
ARC Resources, Ltd. (C) | 315,228 | 907,179 | |||
BP PLC | 3,384,520 | 13,879,695 | |||
Cabot Oil & Gas Corp. | 235,451 | 4,047,403 | |||
Callon Petroleum Company (B) | 326,866 | 179,090 | |||
Cameco Corp. | 144,598 | 1,102,492 | |||
Canadian Natural Resources, Ltd. | 298,836 | 4,087,681 | |||
Cenovus Energy, Inc. | 910,221 | 1,836,870 | |||
Cheniere Energy, Inc. (B) | 22,606 | 757,301 | |||
Chevron Corp. | 208,162 | 15,083,419 | |||
Cimarex Energy Company | 85,241 | 1,434,606 | |||
Concho Resources, Inc. | 98,432 | 4,217,811 |
10 | JOHN HANCOCK DIVERSIFIED REAL ASSETS FUND | ANNUAL REPORT | SEE NOTES TO FINANCIAL STATEMENTS |
Shares | Value | ||||
Energy (continued) | |||||
Oil, gas and consumable fuels (continued) | |||||
ConocoPhillips | 192,816 | $5,938,733 | |||
Continental Resources, Inc. | 126,492 | 966,399 | |||
Devon Energy Corp. | 238,319 | 1,646,784 | |||
DHT Holdings, Inc. | 22,733 | 174,362 | |||
Diamondback Energy, Inc. | 106,465 | 2,789,383 | |||
Enbridge, Inc. | 70,302 | 2,047,165 | |||
Enbridge, Inc. (New York Stock Exchange) | 12,756 | 371,072 | |||
Enerplus Corp. (C) | 437,895 | 644,101 | |||
EOG Resources, Inc. | 116,122 | 4,171,102 | |||
EQT Corp. | 110,575 | 781,765 | |||
Equinor ASA | 432,748 | 5,394,697 | |||
Exxon Mobil Corp. | 250,425 | 9,508,637 | |||
Galp Energia SGPS SA | 546,209 | 6,246,552 | |||
Hess Corp. | 91,742 | 3,055,009 | |||
Imperial Oil, Ltd. (C) | 93,591 | 1,058,078 | |||
Kelt Exploration, Ltd. (B)(C) | 594,603 | 464,765 | |||
Keyera Corp. (C) | 131,211 | 1,219,527 | |||
Lundin Petroleum AB | 179,001 | 3,378,927 | |||
Marathon Petroleum Corp. | 133,287 | 3,148,239 | |||
Neste OYJ | 13,496 | 448,710 | |||
NexGen Energy, Ltd. (B) | 180,532 | 138,545 | |||
Noble Energy, Inc. | 209,289 | 1,264,106 | |||
NuVista Energy, Ltd. (B) | 1,017,337 | 350,606 | |||
Occidental Petroleum Corp. (C) | 148,753 | 1,722,560 | |||
Parsley Energy, Inc., Class A | 304,634 | 1,745,553 | |||
Pembina Pipeline Corp. | 85,358 | 1,601,259 | |||
Phillips 66 | 98,673 | 5,293,806 | |||
Pioneer Natural Resources Company | 75,151 | 5,271,843 | |||
Royal Dutch Shell PLC, A Shares | 822,800 | 14,295,031 | |||
Suncor Energy, Inc. | 491,739 | 7,847,977 | |||
TC Energy Corp. | 160,660 | 7,140,825 | |||
The Williams Companies, Inc. | 189,553 | 2,682,175 | |||
Tidewater Midstream and Infrastructure, Ltd. (C) | 1,059,820 | 365,247 | |||
TOTAL SA (C) | 252,672 | 9,520,388 | |||
Valero Energy Corp. | 141,965 | 6,439,532 | |||
WPX Energy, Inc. (B) | 368,654 | 1,124,395 | |||
Financials 0.4% | 2,416,299 | ||||
Capital markets 0.1% | |||||
Tritax EuroBox PLC (A) | 283,834 | 311,194 | |||
Diversified financial services 0.3% | |||||
Berkshire Hathaway, Inc., Class B (B) | 11,514 | 2,105,105 |
SEE NOTES TO FINANCIAL STATEMENTS | ANNUAL REPORT | JOHN HANCOCK DIVERSIFIED REAL ASSETS FUND | 11 |
Shares | Value | ||||
Industrials 1.2% | $8,023,567 | ||||
Construction and engineering 0.4% | |||||
Vinci SA | 32,386 | 2,646,240 | |||
Electrical equipment 0.1% | |||||
Sunrun, Inc. (B) | 26,461 | 267,256 | |||
Vestas Wind Systems A/S | 7,066 | 574,930 | |||
Road and rail 0.4% | |||||
Canadian National Railway Company | 30,675 | 2,398,330 | |||
Transportation infrastructure 0.3% | |||||
Japan Airport Terminal Company, Ltd. | 55,600 | 2,136,811 | |||
Information technology 0.3% | 2,132,360 | ||||
Semiconductors and semiconductor equipment 0.3% | |||||
Enphase Energy, Inc. (B) | 20,962 | 676,863 | |||
First Solar, Inc. (B) | 30,022 | 1,082,593 | |||
Maxim Integrated Products, Inc. | 3,687 | 179,225 | |||
SunPower Corp. (B) | 38,201 | 193,679 | |||
Materials 21.2% | 144,859,154 | ||||
Chemicals 0.5% | |||||
Albemarle Corp. | 5,219 | 294,195 | |||
Dow, Inc. | 11,850 | 346,494 | |||
DuPont de Nemours, Inc. | 13,877 | 473,206 | |||
LyondellBasell Industries NV, Class A | 19,676 | 976,520 | |||
Nutrien, Ltd. | 37,409 | 1,278,865 | |||
Metals and mining 20.4% | |||||
Agnico Eagle Mines, Ltd. | 158,253 | 6,317,525 | |||
Alacer Gold Corp. (B) | 184,849 | 596,329 | |||
Alamos Gold, Inc., Class A | 152,414 | 765,698 | |||
Alcoa Corp. (B) | 94,964 | 584,978 | |||
Altius Minerals Corp. (C) | 88,253 | 444,620 | |||
Anglo American PLC | 66,744 | 1,169,593 | |||
AngloGold Ashanti, Ltd., ADR (C) | 120,221 | 1,999,275 | |||
Antofagasta PLC | 62,165 | 593,702 | |||
B2Gold Corp. | 692,791 | 2,097,129 | |||
Barrick Gold Corp. | 680,116 | 12,497,548 | |||
BHP Group PLC, ADR (C) | 178,826 | 5,425,581 | |||
BHP Group, Ltd., ADR (C) | 262,074 | 9,615,495 | |||
Boliden AB | 53,571 | 961,057 | |||
Capstone Mining Corp. (B) | 2,239,000 | 707,990 | |||
Champion Iron, Ltd. (B) | 1,374,000 | 1,318,056 | |||
Conic Metals Corp. (B) | 363,682 | 45,224 | |||
Eldorado Gold Corp. (B) | 95,000 | 590,670 | |||
Endeavour Mining Corp. (B) | 155,961 | 2,217,565 | |||
Equinox Gold Corp. (B) | 177,000 | 1,182,264 |
12 | JOHN HANCOCK DIVERSIFIED REAL ASSETS FUND | ANNUAL REPORT | SEE NOTES TO FINANCIAL STATEMENTS |
Shares | Value | ||||
Materials (continued) | |||||
Metals and mining (continued) | |||||
ERO Copper Corp. (B) | 334,783 | $2,514,500 | |||
First Quantum Minerals, Ltd. | 529,174 | 2,703,589 | |||
Franco-Nevada Corp. | 72,282 | 7,222,037 | |||
Freeport-McMoRan, Inc. | 825,225 | 5,570,269 | |||
Fresnillo PLC | 20,060 | 164,808 | |||
Glencore PLC (B) | 426,121 | 644,954 | |||
Golden Star Resources, Ltd. (B)(C) | 159,264 | 407,412 | |||
Hudbay Minerals, Inc. (C) | 245,345 | 463,737 | |||
Ivanhoe Mines, Ltd., Class A (B) | 978,557 | 1,627,104 | |||
K92 Mining, Inc. (B)(C) | 580,000 | 1,219,925 | |||
Kinross Gold Corp. (B) | 460,954 | 1,850,629 | |||
Kirkland Lake Gold, Ltd. (C) | 224,464 | 6,611,265 | |||
Lucara Diamond Corp. | 726,570 | 209,096 | |||
Lundin Mining Corp. | 956,163 | 3,594,189 | |||
MAG Silver Corp. (B) | 108,654 | 838,473 | |||
Marathon Gold Corp. (B) | 355,000 | 262,346 | |||
Nevada Copper Corp. (B) | 5,323,500 | 699,813 | |||
New Gold, Inc. (B) | 387,274 | 200,888 | |||
Newcrest Mining, Ltd. | 71,837 | 986,519 | |||
Newmont Corp. | 334,939 | 15,166,038 | |||
Nexa Resources SA | 10,547 | 38,147 | |||
Nucor Corp. | 12,466 | 449,025 | |||
OceanaGold Corp. (B) | 246,822 | 236,772 | |||
Osisko Mining, Inc. (B)(C) | 627,096 | 993,693 | |||
Pan American Silver Corp. | 83,934 | 1,207,748 | |||
Pan American Silver Corp., CVR (B) | 83,300 | 28,322 | |||
Pretium Resources, Inc. (B) | 22,669 | 129,348 | |||
Rio Tinto PLC, ADR | 271,887 | 12,387,172 | |||
Sandstorm Gold, Ltd. (B)(C) | 93,352 | 467,656 | |||
Seabridge Gold, Inc. (B)(C) | 21,072 | 197,023 | |||
SEMAFO, Inc. (B) | 394,113 | 764,534 | |||
SilverCrest Metals, Inc. (B)(C) | 294,230 | 1,540,876 | |||
SolGold PLC (B)(C) | 600,000 | 144,958 | |||
South32, Ltd. | 175,086 | 193,279 | |||
Southern Copper Corp. | 38,464 | 1,083,146 | |||
SSR Mining, Inc. (B) | 147,081 | 1,677,432 | |||
Steel Dynamics, Inc. | 4,353 | 98,117 | |||
Stornoway Diamond Corp. (B)(D) | 3,062,000 | 43,516 | |||
Teck Resources, Ltd., Class B | 422,877 | 3,206,209 | |||
TMAC Resources, Inc. (B)(C) | 54,533 | 17,825 | |||
Trilogy Metals, Inc. (B)(C) | 930,225 | 1,269,120 | |||
Turquoise Hill Resources, Ltd. (B) | 1,400,463 | 547,328 | |||
Vale SA, ADR | 40,998 | 339,873 |
SEE NOTES TO FINANCIAL STATEMENTS | ANNUAL REPORT | JOHN HANCOCK DIVERSIFIED REAL ASSETS FUND | 13 |
Shares | Value | ||||
Materials (continued) | |||||
Metals and mining (continued) | |||||
Warrior Met Coal, Inc. | 45,428 | $482,445 | |||
Wesdome Gold Mines, Ltd. (B) | 245,000 | 1,286,542 | |||
Western Areas, Ltd. | 835,697 | 991,555 | |||
Wheaton Precious Metals Corp. | 230,580 | 6,345,742 | |||
Yamana Gold, Inc. | 508,945 | 1,414,037 | |||
Paper and forest products 0.3% | |||||
Interfor Corp. (B) | 179,770 | 799,659 | |||
West Fraser Timber Company, Ltd. | 53,528 | 1,020,885 | |||
Real estate 40.4% | 276,251,558 | ||||
Equity real estate investment trusts 36.0% | |||||
Activia Properties, Inc. | 709 | 2,301,472 | |||
Aedifica SA | 6,353 | 659,449 | |||
Agree Realty Corp. | 75,045 | 4,645,282 | |||
Alexandria Real Estate Equities, Inc. | 61,279 | 8,398,900 | |||
alstria office REIT-AG | 44,546 | 639,278 | |||
American Homes 4 Rent, Class A | 136,739 | 3,172,345 | |||
American Tower Corp. | 39,328 | 8,563,672 | |||
Apartment Investment & Management Company, A Shares | 117,775 | 4,139,791 | |||
Arima Real Estate SOCIMI SA (B) | 21,925 | 194,950 | |||
Assura PLC | 752,114 | 779,645 | |||
Big Yellow Group PLC | 33,253 | 411,406 | |||
Brixmor Property Group, Inc. | 219,946 | 2,089,487 | |||
Canadian Apartment Properties REIT | 55,562 | 1,681,508 | |||
Cousins Properties, Inc. | 154,677 | 4,527,396 | |||
Crown Castle International Corp. | 24,059 | 3,474,120 | |||
Derwent London PLC | 21,761 | 879,042 | |||
Digital Realty Trust, Inc. | 113,611 | 15,781,704 | |||
EastGroup Properties, Inc. | 35,824 | 3,742,892 | |||
Equinix, Inc. | 31,283 | 19,538,423 | |||
Equity LifeStyle Properties, Inc. | 156,397 | 8,989,700 | |||
Equity Residential | 133,483 | 8,237,236 | |||
Essential Properties Realty Trust, Inc. | 213,861 | 2,793,025 | |||
Essex Property Trust, Inc. | 19,168 | 4,221,560 | |||
Extra Space Storage, Inc. | 81,625 | 7,816,410 | |||
Frontier Real Estate Investment Corp. | 391 | 1,107,699 | |||
Gaming and Leisure Properties, Inc. | 104,614 | 2,898,854 | |||
Gecina SA | 11,537 | 1,518,152 | |||
Global One Real Estate Investment Corp. | 1,631 | 1,375,314 | |||
Goodman Group | 122,009 | 894,286 | |||
Granite Real Estate Investment Trust | 39,093 | 1,614,777 | |||
Great Portland Estates PLC | 102,815 | 866,229 | |||
Healthpeak Properties, Inc. | 224,563 | 5,355,828 |
14 | JOHN HANCOCK DIVERSIFIED REAL ASSETS FUND | ANNUAL REPORT | SEE NOTES TO FINANCIAL STATEMENTS |
Shares | Value | ||||
Real estate (continued) | |||||
Equity real estate investment trusts (continued) | |||||
Highwoods Properties, Inc. | 131,778 | $4,667,577 | |||
Hulic Reit, Inc. | 1,128 | 1,312,366 | |||
InterRent Real Estate Investment Trust (C) | 81,561 | 771,390 | |||
Invitation Homes, Inc. | 310,839 | 6,642,629 | |||
Japan Real Estate Investment Corp. | 89 | 523,168 | |||
Japan Rental Housing Investments, Inc. | 1,411 | 1,194,502 | |||
Kilroy Realty Corp. | 95,214 | 6,065,132 | |||
Kimco Realty Corp. | 296,956 | 2,871,565 | |||
Klepierre SA | 9,897 | 188,653 | |||
Life Storage, Inc. | 66,987 | 6,333,621 | |||
Link REIT | 349,100 | 2,942,382 | |||
Mapletree Industrial Trust | 753,600 | 1,279,737 | |||
Mapletree Logistics Trust | 2,262,900 | 2,506,564 | |||
Medical Properties Trust, Inc. | 352,138 | 6,088,466 | |||
Mid-America Apartment Communities, Inc. | 70,225 | 7,235,282 | |||
Mirvac Group | 698,299 | 887,186 | |||
Mori Hills REIT Investment Corp. | 447 | 597,781 | |||
Mori Trust Hotel REIT, Inc. | 849 | 647,301 | |||
Mori Trust Sogo REIT, Inc. | 805 | 976,413 | |||
Omega Healthcare Investors, Inc. | 67,881 | 1,801,562 | |||
Premier Investment Corp. | 673 | 744,728 | |||
Prologis, Inc. | 232,965 | 18,723,397 | |||
Realty Income Corp. | 158,874 | 7,921,458 | |||
Rexford Industrial Realty, Inc. | 153,051 | 6,276,622 | |||
Ryman Hospitality Properties, Inc. | 61,721 | 2,212,698 | |||
Segro PLC | 167,646 | 1,584,818 | |||
Shopping Centres Australasia Property Group | 526,449 | 730,139 | |||
STORE Capital Corp. | 127,396 | 2,308,416 | |||
Sun Communities, Inc. | 28,048 | 3,501,793 | |||
The British Land Company PLC | 123,974 | 516,994 | |||
The GPT Group | 654,829 | 1,454,806 | |||
The PRS REIT PLC | 325,343 | 308,967 | |||
The UNITE Group PLC | 91,160 | 909,723 | |||
Ventas, Inc. | 100,426 | 2,691,417 | |||
Viva Energy REIT | 190,120 | 267,122 | |||
Warehouses De Pauw CVA | 15,149 | 432,421 | |||
Welltower, Inc. | 140,853 | 6,448,250 | |||
XYMAX REIT Investment Corp. | 582 | 456,560 | |||
Real estate management and development 4.4% | |||||
Aroundtown SA | 198,215 | 992,157 | |||
CapitaLand, Ltd. | 622,000 | 1,246,444 | |||
Castellum AB (C) | 55,618 | 937,744 | |||
City Developments, Ltd. | 62,500 | 316,917 |
SEE NOTES TO FINANCIAL STATEMENTS | ANNUAL REPORT | JOHN HANCOCK DIVERSIFIED REAL ASSETS FUND | 15 |
Shares | Value | ||||
Real estate (continued) | |||||
Real estate management and development (continued) | |||||
Daibiru Corp. | 68,700 | $565,928 | |||
Deutsche Wohnen SE | 66,626 | 2,525,042 | |||
Fabege AB | 112,857 | 1,439,883 | |||
Fastighets AB Balder, B Shares (B) | 23,664 | 855,485 | |||
Grainger PLC | 230,305 | 732,906 | |||
Mitsubishi Estate Company, Ltd. | 175,800 | 2,596,416 | |||
Mitsui Fudosan Company, Ltd. | 97,700 | 1,691,648 | |||
New World Development Company, Ltd. | 3,346,588 | 3,568,388 | |||
PSP Swiss Property AG | 16,145 | 2,018,919 | |||
Sino Land Company, Ltd. | 896,000 | 1,127,669 | |||
Sumitomo Realty & Development Company, Ltd. | 68,900 | 1,682,390 | |||
Swire Properties, Ltd. | 808,000 | 2,257,346 | |||
Swiss Prime Site AG | 499 | 48,568 | |||
Urban & Civic PLC | 113,762 | 291,112 | |||
VGP NV | 3,912 | 401,783 | |||
Vonovia SE | 92,904 | 4,621,375 | |||
Utilities 6.3% | 43,059,372 | ||||
Electric utilities 2.8% | |||||
Avangrid, Inc. | 50,235 | 2,199,288 | |||
CK Infrastructure Holdings, Ltd. | 406,688 | 2,152,961 | |||
Duke Energy Corp. | 30,268 | 2,448,076 | |||
Edison International | 49,169 | 2,693,970 | |||
Enel SpA | 389,983 | 2,690,045 | |||
Exelon Corp. | 69,234 | 2,548,504 | |||
Iberdrola SA | 306,744 | 3,000,269 | |||
NextEra Energy, Inc. | 6,535 | 1,572,452 | |||
Gas utilities 0.8% | |||||
Beijing Enterprises Holdings, Ltd. | 437,513 | 1,596,695 | |||
ENN Energy Holdings, Ltd. | 179,297 | 1,736,894 | |||
Snam SpA | 344,704 | 1,575,402 | |||
UGI Corp. | 34,512 | 920,435 | |||
Independent power and renewable electricity producers 0.8% | |||||
Brookfield Renewable Partners LP | 38,518 | 1,636,630 | |||
China Longyuan Power Group Corp., Ltd., H Shares | 4,650,316 | 2,538,172 | |||
TerraForm Power, Inc., Class A | 62,247 | 981,635 | |||
Multi-utilities 1.5% | |||||
E.ON SE | 265,596 | 2,724,401 | |||
Engie SA | 209,664 | 2,147,057 | |||
National Grid PLC | 264,066 | 3,085,413 | |||
Sempra Energy | 18,002 | 2,034,046 |
16 | JOHN HANCOCK DIVERSIFIED REAL ASSETS FUND | ANNUAL REPORT | SEE NOTES TO FINANCIAL STATEMENTS |
Shares | Value | ||||
Utilities (continued) | |||||
Water utilities 0.4% | |||||
Cia de Saneamento do Parana | 174,768 | $802,182 | |||
Guangdong Investment, Ltd. | 592,578 | 1,137,187 | |||
Severn Trent PLC | 29,592 | 837,658 | |||
Yield (%) | Shares | Value | |||
Short-term funds 5.1% | 34,910,208 | ||||
John Hancock Collateral Trust (E) | 1.1260(F) | 3,491,894 | 34,910,208 |
Par value^ | Value | ||||
Repurchase agreement 0.1% | 600,000 | ||||
Bank of America Corp. Tri-Party Repurchase Agreement dated 3-31-20 at 0.010% to be repurchased at $600,000 on 4-1-20, collateralized by $591,000 U.S. Treasury Notes, 2.000% due 12-31-21 (valued at $612,093) | 600,000 | 600,000 |
Total investments (Cost $1,030,120,328) 103.8% | $709,610,528 | ||||
Other assets and liabilities, net (3.8%) | (25,833,851) | ||||
Total net assets 100.0% | $683,776,677 |
The percentage shown for each investment category is the total value of the category as a percentage of the net assets of the fund. | |
^All par values are denominated in U.S. dollars unless otherwise indicated. | |
Security Abbreviations and Legend | |
ADR | American Depositary Receipt |
CVR | Contingent Value Right |
(A) | These securities are exempt from registration under Rule 144A of the Securities Act of 1933. Such securities may be resold, normally to qualified institutional buyers, in transactions exempt from registration. |
(B) | Non-income producing security. |
(C) | All or a portion of this security is on loan as of 3-31-20. |
(D) | Security is valued using significant unobservable inputs and is classified as Level 3 in the fair value hierarchy. Refer to Note 2 to the financial statements. |
(E) | Investment is an affiliate of the fund, the advisor and/or subadvisor. This security represents the investment of cash collateral received for securities lending. |
(F) | The rate shown is the annualized seven-day yield as of 3-31-20. |
* | Yield represents either the annualized yield at the date of purchase, the stated coupon rate or, for floating rate securities, the rate at period end. |
SEE NOTES TO FINANCIAL STATEMENTS | ANNUAL REPORT | JOHN HANCOCK DIVERSIFIED REAL ASSETS FUND | 17 |
Financial statements |
Assets | |
Unaffiliated investments, at value (Cost $995,219,199) including $35,583,318 of securities loaned | $674,700,320 |
Affiliated investments, at value (Cost $34,901,129) | 34,910,208 |
Total investments, at value (Cost $1,030,120,328) | 709,610,528 |
Cash | 4,340,192 |
Foreign currency, at value (Cost $3,643,230) | 3,648,487 |
Dividends and interest receivable | 3,037,313 |
Receivable for investments sold | 2,226,229 |
Other assets | 4,765 |
Total assets | 722,867,514 |
Liabilities | |
Payable for investments purchased | 3,152,883 |
Payable for fund shares repurchased | 860,629 |
Payable upon return of securities loaned | 34,904,064 |
Payable to affiliates | |
Accounting and legal services fees | 43,952 |
Trustees' fees | 777 |
Other liabilities and accrued expenses | 128,532 |
Total liabilities | 39,090,837 |
Net assets | $683,776,677 |
Net assets consist of | |
Paid-in capital | $1,026,594,211 |
Total distributable earnings (loss) | (342,817,534) |
Net assets | $683,776,677 |
Net asset value per share | |
Based on net asset value and shares outstanding - the fund has an unlimited number of shares authorized with no par value | |
Class NAV ($683,776,677 ÷ 103,503,948 shares) | $6.61 |
18 | JOHN HANCOCK Diversified Real Assets Fund | ANNUAL REPORT | SEE NOTES TO FINANCIAL STATEMENTS |
Investment income | |
Dividends | $28,857,171 |
Securities lending | 284,326 |
Interest | 193,897 |
Less foreign taxes withheld | (1,445,708) |
Total investment income | 27,889,686 |
Expenses | |
Investment management fees | 8,120,785 |
Accounting and legal services fees | 181,867 |
Trustees' fees | 18,427 |
Custodian fees | 360,652 |
Printing and postage | 12,826 |
Professional fees | 75,792 |
Other | 89,434 |
Total expenses | 8,859,783 |
Less expense reductions | (548,426) |
Net expenses | 8,311,357 |
Net investment income | 19,578,329 |
Realized and unrealized gain (loss) | |
Net realized gain (loss) on | |
Unaffiliated investments and foreign currency transactions | (2,531,742) |
Affiliated investments | (5,875) |
(2,537,617) | |
Change in net unrealized appreciation (depreciation) of | |
Unaffiliated investments and translation of assets and liabilities in foreign currencies | (313,402,798) |
Affiliated investments | 3,151 |
(313,399,647) | |
Net realized and unrealized loss | (315,937,264) |
Decrease in net assets from operations | $(296,358,935) |
SEE NOTES TO FINANCIAL STATEMENTS | ANNUAL REPORT | JOHN HANCOCK Diversified Real Assets Fund | 19 |
Year
ended
3-31-20 |
Year
ended
3-31-19 |
|
Increase (decrease) in net assets | ||
From operations | ||
Net investment income | $19,578,329 | $20,810,607 |
Net realized gain (loss) | (2,537,617) | 9,292,729 |
Change in net unrealized appreciation (depreciation) | (313,399,647) | (5,644,732) |
Increase (decrease) in net assets resulting from operations | (296,358,935) | 24,458,604 |
Distributions to shareholders | ||
From earnings | ||
Class NAV | (43,232,315) | (27,620,019) |
Total distributions | (43,232,315) | (27,620,019) |
From fund share transactions | 25,009,097 | 63,663,726 |
Total increase (decrease) | (314,582,153) | 60,502,311 |
Net assets | ||
Beginning of year | 998,358,830 | 937,856,519 |
End of year | $683,776,677 | $998,358,830 |
20 | JOHN HANCOCK Diversified Real Assets Fund | ANNUAL REPORT | SEE NOTES TO FINANCIAL STATEMENTS |
Financial highlights |
CLASS NAV SHARES Period ended | 3-31-20 | 3-31-19 | 3-31-18 1 |
Per share operating performance | |||
Net asset value, beginning of period | $10.01 | $10.00 | $10.00 |
Net investment income2 | 0.20 | 0.21 | 0.03 |
Net realized and unrealized gain (loss) on investments | (3.16) | 0.07 | (0.03) |
Total from investment operations | (2.96) | 0.28 | — 3 |
Less distributions | |||
From net investment income | (0.28) | (0.19) | — |
From net realized gain | (0.16) | (0.08) | — |
Total distributions | (0.44) | (0.27) | — |
Net asset value, end of period | $6.61 | $10.01 | $10.00 |
Total return (%)4 | (30.92) | 3.07 | 0.00 5 |
Ratios and supplemental data | |||
Net assets, end of period (in millions) | $684 | $998 | $938 |
Ratios (as a percentage of average net assets): | |||
Expenses before reductions | 0.93 | 0.94 | 0.94 6,7 |
Expenses including reductions | 0.87 | 0.88 | 0.88 6,7 |
Net investment income | 2.05 | 2.07 | 3.84 6 |
Portfolio turnover (%) | 61 | 73 | 40 8 |
1 | Period from 2-26-18 (commencement of operations) to 3-31-18. |
2 | Based on average daily shares outstanding. |
3 | Less than $0.005 per share. |
4 | Total returns would have been lower had certain expenses not been reduced during the applicable periods. |
5 | Not annualized. |
6 | Annualized. |
7 | Certain expenses are presented unannualized due to the short reporting period. |
8 | Excludes in-kind transactions. |
SEE NOTES TO FINANCIAL STATEMENTS | ANNUAL REPORT | JOHN HANCOCK Diversified Real Assets Fund | 21 |
Notes to financial statements |
22 | JOHN HANCOCK Diversified Real Assets Fund | ANNUAL REPORT |
ANNUAL REPORT | JOHN HANCOCK Diversified Real Assets Fund | 23 |
24 | JOHN HANCOCK Diversified Real Assets Fund | ANNUAL REPORT |
ANNUAL REPORT | JOHN HANCOCK Diversified Real Assets Fund | 25 |
March 31, 2020 | March 31, 2019 | |
Ordinary income | $30,921,946 | $26,998,261 |
Long-term capital gains | 12,310,369 | 621,758 |
Total | $43,232,315 | $27,620,019 |
26 | JOHN HANCOCK Diversified Real Assets Fund | ANNUAL REPORT |
Borrower
or Lender |
Weighted
Average
Loan Balance |
Days
Outstanding |
Weighted
Average
Interest Rate |
Interest
Income
(Expense) |
Borrower | $3,072,289 | 7 | 2.079% | ($1,242) |
Year Ended 3-31-20 | Year Ended 3-31-19 | |||
Shares | Amount | Shares | Amount | |
Class NAV shares | ||||
Sold | 12,166,351 | $109,544,162 | 19,904,391 | $205,831,083 |
Distributions reinvested | 4,484,680 | 43,232,315 | 3,041,852 | 27,620,019 |
Repurchased | (12,853,162) | (127,767,380) | (17,029,182) | (169,787,376) |
Net increase | 3,797,869 | $25,009,097 | 5,917,061 | $63,663,726 |
Total net increase | 3,797,869 | $25,009,097 | 5,917,061 | $63,663,726 |
ANNUAL REPORT | JOHN HANCOCK Diversified Real Assets Fund | 27 |
Portfolio | Affiliated Concentration |
John Hancock Funds II Multimanager Lifestyle Growth Portfolio | 31.2% |
John Hancock Funds II Multimanager Lifestyle Balanced Portfolio | 25.7% |
John Hancock Funds II Multimanager Lifestyle Aggressive Portfolio | 12.0% |
John Hancock Funds II Multimanager Lifestyle Moderate Portfolio | 6.2% |
John Hancock Funds II Multimanager 2025 Lifetime Portfolio | 5.6% |
Dividends and distributions | |||||||||
Affiliate |
Ending
share amount |
Beginning
value |
Cost
of
purchases |
Proceeds
from shares sold |
Realized
gain (loss) |
Change
in
unrealized appreciation (depreciation) |
Income
distributions received |
Capital
gain
distributions received |
Ending
value |
John Hancock Collateral Trust* | 3,491,894 | $34,455,595 | $427,781,552 | $(427,324,215) | $(5,875) | $3,151 | $284,326 | — | $34,910,208 |
* | Refer to the Securities lending note within Note 2 for details regarding this investment. |
28 | JOHN HANCOCK Diversified Real Assets Fund | ANNUAL REPORT |
ANNUAL REPORT | JOHN HANCOCK DIVERSIFIED REAL ASSETS FUND | 29 |
Tax information (Unaudited) |
30 | JOHN HANCOCK DIVERSIFIED REAL ASSETS FUND | ANNUAL REPORT |
STATEMENT REGARDING LIQUIDITY RISK MANAGEMENT
Operation of the Liquidity Risk Management Program
This section describes operation and effectiveness of the Liquidity Risk Management Program (LRMP) established in accordance with Rule 22e-4 under the Investment Company Act of 1940, as amended (the Liquidity Rule). The Board of Trustees (the Board) of each Fund in the John Hancock Group of Funds (each a Fund and collectively, the Funds) that is subject to the requirements of the Liquidity Rule has appointed John Hancock Investment Management, LLC and John Hancock Variable Trust Advisers, LLC (together, the Advisor) to serve as Administrator of the LRMP with respect to each of the Funds, including John Hancock Diversified Real Assets Fund, subject to the oversight of the Board. In order to provide a mechanism and process to perform the functions necessary to administer the LRMP, the Advisor established the Liquidity Risk Management Committee (the Committee). The Fund's subadvisors, Manulife Investment Management North America, Deutsche Investment Management Americas Inc. and Wellington Management Company, LLP (each a Subadvisor) execute the day-to-day investment management and security-level activities of the Fund in accordance with the requirements of the LRMP, subject to the supervision of the Advisor and the Board.
The Committee holds monthly meetings to: (1) review the day-to-day operations of the LRMP; (2) review and approve month end liquidity classifications; (3) review quarterly testing and determinations, as applicable; and (4) review other LRMP related material. The Committee also conducts daily, monthly, quarterly, and annual quantitative and qualitative assessments of each subadvisor to a Fund that is subject to the requirements of the Liquidity Rule and is a part of the LRMP to monitor investment performance issues, risks and trends. In addition, the Committee may conduct ad-hoc reviews and meetings with subadvisors as issues and trends are identified, including potential liquidity and valuation issues.
The Committee provided the Board at an in-person meeting held on March 15-18, 2020 with a written report which addressed the Committee's assessment of the adequacy and effectiveness of the implementation and operation of the LRMP and any material changes to the LRMP. The report, which covered the period December 1, 2018 through December 31, 2019, included an assessment of important aspects of the LRMP including, but not limited to:
Operation of the Fund's Redemption-In-Kind Procedures;
Highly Liquid Investment Minimum (HLIM) determination;
Compliance with the 15% limit on illiquid investments;
Reasonably Anticipated Trade Size (RATS) determination;
Security-level liquidity classifications; and
Liquidity risk assessment.
The report also covered material liquidity matters which occurred or were reported during this period applicable to the Fund, if any, and the Committee's actions to address such matters.
Redemption-In-Kind Procedures
Rule 22e-4 requires any fund that engages in or reserves the right to engage in in-kind redemptions to adopt and implement written policies and procedures regarding in-kind redemptions as part of the management of its liquidity risk. These procedures address the process for redeeming in kind, as well as the circumstances under which the Fund would consider redeeming in kind. Anticipated large redemption activity will be evaluated to identify situations where redeeming in securities instead of cash may be appropriate.
As part of its annual assessment of the LRMP, the Committee reviewed the implementation and operation of the Redemption-In-Kind Procedures and determined they are operating in a manner that such procedures are adequate and effective to manage in-kind redemptions on behalf of the Fund as part of the LRMP.
Highly Liquid Investment Minimum determination
The Committee uses an HLIM model to determine a Fund's HLIM. This process incorporates the Fund's investment strategy, historical redemptions, liquidity classification rollup percentages and cash balances, redemption policy, access to funding sources, distribution channels and client concentrations. If the Fund falls below its established HLIM for a period greater than 7 consecutive calendar days, the Committee prepares a report to the Board within one business day following the seventh consecutive calendar day with an explanation of how the Fund plans to restore its HLIM within a reasonable period of time.
Based on the HLIM model, the Committee has determined that the Fund qualifies as a Primarily Highly Liquid Fund (PHLF). It is therefore not required to establish a HLIM. The Fund is tested quarterly to confirm its PHLF status.
As part of its annual assessment of the LRMP, the Committee reviewed the policies and procedures in place with respect to HLIM and PHLF determinations, and determined that such policies and procedures are operating in a manner that is adequate and effective as part of the LRMP.
Compliance with the 15% limit on illiquid investments
Rule 22e-4 sets an aggregate illiquid investment limit of 15% for a fund. Funds are prohibited from acquiring an illiquid investment if this results in greater than 15% of its net assets being classified as illiquid. When applying this limit, the Committee defines "illiquid investment" to mean any investment that the Fund reasonably expects cannot be sold or disposed of in current market conditions in seven calendar days or less without the sale or disposition significantly changing the market value of the investment. If a 15% illiquid investment limit breach occurs for longer than 1 business day, the Fund is required to notify the Board and provide a plan on how to bring illiquid investments within the 15% threshold, and after 7 days confidentially notify the Securities and Exchange Commission (the SEC).
In February 2019, as a result of extended security markets closures in connection with the Chinese New Year in certain countries, the SEC released guidance, and the Committee approved and adopted an Extended Market Holiday Policy to plan for and monitor known Extended Market Holidays (defined as all expected market holiday closures spanning four or more calendar days).
As part of its annual assessment of the LRMP, the Committee reviewed the policies and procedures in place with respect to the 15% illiquid investment limit and determined such policies and procedures are operating in a manner that is adequate and effective as part of the LMRP.
Reasonably Anticipated Trade Size determination
In order to assess the liquidity risk of a Fund, the Committee considers the impact on the Fund that redemptions of a RATS would have under both normal and reasonably foreseeable stressed conditions. Modelling the Fund's RATS requires quantifying cash flow volatility and analyzing distribution channel concentration and redemption risk. The model is designed to estimate the amount of assets that the Fund could reasonably anticipate trading on a given day, during both normal and reasonably foreseeable stressed conditions, to satisfy redemption requests.
As part of its annual assessment of the LRMP, the Committee reviewed the policies and procedures in place with respect to RATS determinations and determined that such policies and procedures are operating in a manner that is adequate and effective at making RATS determinations as part of the LRMP.
Security-level liquidity classifications
When classifying the liquidity of portfolio securities, the Fund adheres to the liquidity classification procedures established by the Advisor. In assigning a liquidity classification to Fund portfolio holdings, the following key inputs, among others, are considered: the Fund's RATS, feedback from the applicable Subadvisor on market-, trading- and investment-specific considerations, an assessment of current market conditions and fund portfolio holdings, and a value impact standard. The Subadvisor also provides position-level data to the Committee for use in monthly classification reconciliation in order to identify any classifications that may need to be changed as a result of the above considerations.
As part of its annual assessment of the LRMP, the Committee reviewed the policies and procedures in place with respect to security-level liquidity classifications and determined that such policies and procedures are operating in a manner that is adequate and effective as part of the LRMP.
Liquidity risk assessment
The Committee periodically reviews and assesses, the Fund's liquidity risk, including its investment strategy and liquidity of portfolio investments during both normal and reasonably foreseeable stressed conditions (including whether the investment strategy is appropriate for an open-end fund, the extent to which the strategy involves a relatively concentrated portfolio or large positions in particular issuers, and the use of borrowings for investment purposes and derivatives), cash flow analysis during both normal and reasonably foreseeable stressed conditions, and holdings of cash and cash equivalents, as well as borrowing arrangements and other funding sources.
The Committee also monitors global events, such as the COVID-19 Coronavirus, that could impact the markets and liquidity of portfolio investments and their classifications.
As part of its annual assessment of the LRMP, the Committee reviewed Fund-Level Liquidity Risk Assessment Reports for each of the Funds and determined that the investment strategy for each Fund continues to be appropriate for an open-ended structure.
Adequacy and Effectiveness
Based on the review and assessment conducted by the Committee, the Committee has determined that the LRMP has been implemented, and is operating in a manner that is adequate and effective at assessing and managing the liquidity risk of each Fund.
This chart provides information about the Trustees and Officers who oversee your John Hancock fund. Officers elected by the Trustees manage the day-to-day operations of the fund and execute policies formulated by the Trustees.
Independent Trustees
Charles L. Bardelis,2 Born: 1941 | 2012 | 204 |
Trustee
Director, Island Commuter Corp. (marine transport). Trustee of various trusts within the John Hancock Fund Complex (since 1988). |
James R. Boyle, Born: 1959 | 2015 | 204 |
Trustee
Chief Executive Officer, Foresters Financial (since 2018); Chairman and Chief Executive Officer, Zillion Group, Inc. (formerly HealthFleet, Inc.) (healthcare) (2014-2018); Executive Vice President and Chief Executive Officer, U.S. Life Insurance Division of Genworth Financial, Inc. (insurance) (January 2014-July 2014); Senior Executive Vice President, Manulife Financial, President and Chief Executive Officer, John Hancock (1999-2012); Chairman and Director, John Hancock Investment Management LLC, John Hancock Investment Management Distributors LLC, and John Hancock Variable Trust Advisers LLC (2005-2010). Trustee of various trusts within the John Hancock Fund Complex (2005-2014 and since 2015). |
Peter S. Burgess,2 Born: 1942 | 2012 | 204 |
Trustee
Consultant (financial, accounting, and auditing matters) (since 1999); Certified Public Accountant; Partner, Arthur Andersen (independent public accounting firm) (prior to 1999); Director, Lincoln Educational Services Corporation (since 2004); Director, Symetra Financial Corporation (2010-2016); Director, PMA Capital Corporation (2004-2010). Trustee of various trusts within the John Hancock Fund Complex (since 2005). |
William H. Cunningham, Born: 1944 | 2006 | 204 |
Trustee
Professor, University of Texas, Austin, Texas (since 1971); former Chancellor, University of Texas System and former President of the University of Texas, Austin, Texas; Chairman (since 2009) and Director (since 2006), Lincoln National Corporation (insurance); Director, Southwest Airlines (since 2000); former Director, LIN Television (2009-2014). Trustee of various trusts within the John Hancock Fund Complex (since 1986). |
Grace K. Fey, Born: 1946 | 2012 | 204 |
Trustee
Chief Executive Officer, Grace Fey Advisors (since 2007); Director and Executive Vice President, Frontier Capital Management Company (1988-2007); Director, Fiduciary Trust (since 2009). Trustee of various trusts within the John Hancock Fund Complex (since 2008). |
Independent Trustees (continued)
Name, year of birth
Position(s) held with Trust Principal occupation(s) and other directorships during past 5 years |
Trustee
of the Trust since1 |
Number of John
Hancock funds overseen by Trustee |
Deborah C. Jackson, Born: 1952 | 2008 | 204 |
Trustee
President, Cambridge College, Cambridge, Massachusetts (since 2011); Board of Directors, Massachusetts Women's Forum (since 2018); Board of Directors, National Association of Corporate Directors/New England (since 2015); Board of Directors, Association of Independent Colleges and Universities of Massachusetts (2014-2017); Chief Executive Officer, American Red Cross of Massachusetts Bay (2002-2011); Board of Directors of Eastern Bank Corporation (since 2001); Board of Directors of Eastern Bank Charitable Foundation (since 2001); Board of Directors of American Student Assistance Corporation (1996-2009); Board of Directors of Boston Stock Exchange (2002-2008); Board of Directors of Harvard Pilgrim Healthcare (health benefits company) (2007-2011). Trustee of various trusts within the John Hancock Fund Complex (since 2008). |
James M. Oates,2 Born: 1946 | 2012 | 204 |
Trustee
Managing Director, Wydown Group (financial consulting firm) (since 1994); Chairman and Director, Emerson Investment Management, Inc. (2000-2015); Independent Chairman, Hudson Castle Group, Inc. (formerly IBEX Capital Markets, Inc.) (financial services company) (1997-2011); Director, Stifel Financial (since 1996); Director, Investor Financial Services Corporation (1995-2007); Director, Connecticut River Bancorp (1998-2014); Director/Trustee, Virtus Funds (since 1988). Trustee (since 2004) and Chairperson of the Board (2005-2016) of various trusts within the John Hancock Fund Complex. |
Steven R. Pruchansky, Born: 1944 | 2006 | 204 |
Trustee and Vice Chairperson of the Board
Managing Director, Pru Realty (since 2017); Chairman and Chief Executive Officer, Greenscapes of Southwest Florida, Inc. (since 2014); Director and President, Greenscapes of Southwest Florida, Inc. (until 2000); Member, Board of Advisors, First American Bank (until 2010); Managing Director, Jon James, LLC (real estate) (since 2000); Partner, Right Funding, LLC (2014-2017); Director, First Signature Bank & Trust Company (until 1991); Director, Mast Realty Trust (until 1994); President, Maxwell Building Corp. (until 1991). Trustee (since 1992), Chairperson of the Board (2011-2012), and Vice Chairperson of the Board (since 2012) of various trusts within the John Hancock Fund Complex. |
Gregory A. Russo, Born: 1949 | 2008 | 204 |
Trustee
Director and Audit Committee Chairman (since 2012), and Member, Audit Committee and Finance Committee (since 2011), NCH Healthcare System, Inc. (holding company for multi-entity healthcare system); Director and Member (2012-2018) and Finance Committee Chairman (2014-2018), The Moorings, Inc. (nonprofit continuing care community); Vice Chairman, Risk & Regulatory Matters, KPMG LLP (KPMG) (2002-2006); Vice Chairman, Industrial Markets, KPMG (1998-2002); Chairman and Treasurer, Westchester County, New York, Chamber of Commerce (1986-1992); Director, Treasurer, and Chairman of Audit and Finance Committees, Putnam Hospital Center (1989-1995); Director and Chairman of Fundraising Campaign, United Way of Westchester and Putnam Counties, New York (1990-1995). Trustee of various trusts within the John Hancock Fund Complex (since 2008). |
Non-Independent Trustees3
Name, year of birth
Position(s) held with Trust Principal occupation(s) and other directorships during past 5 years |
Trustee
of the Trust since1 |
Number of John
Hancock funds overseen by Trustee |
Andrew G. Arnott, Born: 1971 | 2017 | 204 |
President and Non-Independent Trustee
Head of Wealth and Asset Management, United States and Europe, for John Hancock and Manulife (since 2018); Executive Vice President, John Hancock Financial Services (since 2009, including prior positions); Director and Executive Vice President, John Hancock Investment Management LLC (since 2005, including prior positions); Director and Executive Vice President, John Hancock Variable Trust Advisers LLC (since 2006, including prior positions); President, John Hancock Investment Management Distributors LLC (since 2004, including prior positions); President of various trusts within the John Hancock Fund Complex (since 2007, including prior positions). Trustee of various trusts within the John Hancock Fund Complex (since 2017). |
Marianne Harrison, Born: 1963 | 2018 | 204 |
Non-Independent Trustee
President and CEO, John Hancock (since 2017); President and CEO, Manulife Canadian Division (2013-2017); Member, Board of Directors, CAE Inc. (since 2019); Member, Board of Directors, MA Competitive Partnership Board (since 2018); Member, Board of Directors, American Council of Life Insurers (ACLI) (since 2018); Member, Board of Directors, Communitech, an industry-led innovation center that fosters technology companies in Canada (2017-2019); Member, Board of Directors, Manulife Assurance Canada (2015-2017); Board Member, St. Mary's General Hospital Foundation (2014-2017); Member, Board of Directors, Manulife Bank of Canada (2013-2017); Member, Standing Committee of the Canadian Life & Health Assurance Association (2013-2017); Member, Board of Directors, John Hancock USA, John Hancock Life & Health, John Hancock New York (2012-2013). Trustee of various trusts within the John Hancock Fund Complex (since 2018). |
Principal officers who are not Trustees
Charles A. Rizzo, Born: 1957 | 2007 |
Chief Financial Officer
Vice President, John Hancock Financial Services (since 2008); Senior Vice President, John Hancock Investment Management LLC and John Hancock Variable Trust Advisers LLC (since 2008); Chief Financial Officer of various trusts within the John Hancock Fund Complex (since 2007). |
Salvatore Schiavone, Born: 1965 | 2010 |
Treasurer
Assistant Vice President, John Hancock Financial Services (since 2007); Vice President, John Hancock Investment Management LLC and John Hancock Variable Trust Advisers LLC (since 2007); Treasurer of various trusts within the John Hancock Fund Complex (since 2007, including prior positions). |
Principal officers who are not Trustees (continued)
Name, year of birth
Position(s) held with Trust Principal occupation(s) during past 5 years |
Officer
of the Trust since |
Christopher (Kit) Sechler, Born: 1973 | 2018 |
Chief Legal Officer and Secretary
Vice President and Deputy Chief Counsel, John Hancock Investments (since 2015); Assistant Vice President and Senior Counsel (2009-2015), John Hancock Investment Management; Chief Legal Officer and Secretary of various trusts within the John Hancock Fund Complex (since 2018); Assistant Secretary of John Hancock Investment Management LLC and John Hancock Variable Trust Advisers LLC (since 2009). |
The business address for all Trustees and Officers is 200 Berkeley Street, Boston, Massachusetts 02116-5023.
The Statement of Additional Information of the fund includes additional information about members of the Board of Trustees of the Trust and is available without charge, upon request, by calling 800-225-5291.
1 | Each Trustee holds office until his or her successor is elected and qualified, or until the Trustee's death, retirement, resignation, or removal. Mr. Boyle has served as Trustee at various times prior to the date listed in the table. |
2 | Member of the Audit Committee. |
3 | The Trustee is a Non-Independent Trustee due to current or former positions with the Advisor and certain affiliates. |
Trustees
Hassell H. McClellan, Chairperson
Officers
Andrew G. Arnott
Francis V. Knox, Jr.
Charles A. Rizzo
Salvatore Schiavone
Christopher (Kit) Sechler
|
Investment advisor
John Hancock Investment Management LLC
Subadvisors
DWS Investment Management Americas, Inc. (DIMA)
Portfolio Managers
The Investment Management Teams at RREEF, Manulife IM (NA) and Wellington
Principal distributor
John Hancock Investment Management Distributors LLC
Custodian
Citibank, N.A.
Legal counsel
K&L Gates LLP
Independent registered public accounting firm
PricewaterhouseCoopers LLP
|
* Member of the Audit Committee
Non-Independent Trustee
The fund's proxy voting policies and procedures, as well as the fund proxy voting record for the most recent twelve-month period ended June 30, are available free of charge on the Securities and Exchange Commission (SEC) website at sec.gov or on our website.
All of the fund's holdings as of the end of the third month of every fiscal quarter are filed with the SEC on Form N-PORT within 60 days of the end of the fiscal quarter. The fund's Form N-PORT filings are available on our website and the SEC's website, sec.gov.
We make this information on your fund, as well as monthly portfolio holdings, and other fund details available on our website at jhinvestments.com or by calling 800-225-5291.
You can also contact us: | |||
800-225-5291
jhinvestments.com |
Regular mail:
John Hancock Signature Services, Inc.
|
Express mail:
John Hancock Signature Services, Inc.
|
John Hancock family of funds
DOMESTIC EQUITY FUNDS
Blue Chip Growth
Classic Value
Disciplined Value
Disciplined Value Mid Cap
Equity Income
Financial Industries
Fundamental All Cap Core
Fundamental Large Cap Core
New Opportunities
Regional Bank
Small Cap Core
Small Cap Growth
Small Cap Value
U.S. Global Leaders Growth
U.S. Quality Growth
GLOBAL AND INTERNATIONAL EQUITY FUNDS
Disciplined Value International
Emerging Markets
Emerging Markets Equity
Fundamental Global Franchise
Global Equity
Global Shareholder Yield
Global Thematic Opportunities
International Dynamic Growth
International Growth
International Small Company
|
INCOME FUNDS
Bond
California Tax-Free Income
Emerging Markets Debt
Floating Rate Income
Government Income
High Yield
High Yield Municipal Bond
Income
Investment Grade Bond
Money Market
Short Duration Bond
Short Duration Credit Opportunities
Strategic Income Opportunities
Tax-Free Bond
ALTERNATIVE AND SPECIALTY FUNDS
Absolute Return Currency
Alternative Asset Allocation
Alternative Risk Premia
Diversified Macro
Infrastructure
Multi-Asset Absolute Return
Seaport Long/Short
|
A fund's investment objectives, risks, charges, and expenses should be considered carefully before investing. The prospectus contains this and other important information about the fund. To obtain a prospectus, contact your financial professional, call John Hancock Investment Management at 800-225-5291, or visit our website at jhinvestments.com. Please read the prospectus carefully before investing or sending money.
ASSET ALLOCATION
Balanced
Multi-Asset High Income
Multi-Index Lifetime Portfolios
Multi-Index Preservation Portfolios
Multimanager Lifestyle Portfolios
Multimanager Lifetime Portfolios
Retirement Income 2040
EXCHANGE-TRADED FUNDS
John Hancock Multifactor Consumer Discretionary ETF
John Hancock Multifactor Consumer Staples ETF
John Hancock Multifactor Developed International ETF
John Hancock Multifactor Emerging Markets ETF
John Hancock Multifactor Energy ETF
John Hancock Multifactor Financials ETF
John Hancock Multifactor Healthcare ETF
John Hancock Multifactor Industrials ETF
John Hancock Multifactor Large Cap ETF
John Hancock Multifactor Materials ETF
John Hancock Multifactor Media and
John Hancock Multifactor Mid Cap ETF
John Hancock Multifactor Small Cap ETF
John Hancock Multifactor Technology ETF
John Hancock Multifactor Utilities ETF
|
ENVIRONMENTAL, SOCIAL, AND
ESG All Cap Core
ESG Core Bond
ESG International Equity
ESG Large Cap Core
CLOSED-END FUNDS
Financial Opportunities
Hedged Equity & Income
Income Securities Trust
Investors Trust
Preferred Income
Preferred Income II
Preferred Income III
Premium Dividend
Tax-Advantaged Dividend Income
Tax-Advantaged Global Shareholder Yield
|
John Hancock Multifactor ETF shares are bought and sold at market
price (not NAV), and are not individually redeemed
from the fund. Brokerage commissions will reduce returns.
John Hancock ETFs are distributed by Foreside Fund Services, LLC, and
are subadvised by Dimensional Fund Advisors LP.
Foreside is not affiliated with John Hancock Investment Management
Distributors LLC or Dimensional Fund Advisors LP.
Dimensional Fund Advisors LP receives compensation from John Hancock
in connection with licensing rights to the
John Hancock Dimensional indexes. Dimensional Fund Advisors LP does
not sponsor, endorse, or sell, and makes no
representation as to the advisability of investing in, John Hancock
Multifactor ETFs.
John Hancock Investment Management
A trusted brand
John Hancock Investment Management is a premier asset manager
representing one of America's most trusted brands, with a heritage of
financial stewardship dating back to 1862. Helping our shareholders
pursue their financial goals is at the core of everything we do. It's why
we support the role of professional financial advice and operate with
the highest standards of conduct and integrity.
A better way to invest
We serve investors globally through a unique multimanager approach:
We search the world to find proven portfolio teams with specialized
expertise for every strategy we offer, then we apply robust investment
oversight to ensure they continue to meet our uncompromising
standards and serve the best interests of our shareholders.
Results for investors
Our unique approach to asset management enables us to provide
a diverse set of investments backed by some of the world's best
managers, along with strong risk-adjusted returns across asset classes.
John Hancock Investment Management Distributors LLC
n Member FINRA, SIPC
200 Berkeley Street
n Boston, MA 02116-5010
n 800-225-5291
n jhinvestments.com
This report is for the information of the shareholders of John Hancock Diversified Real Assets Fund. It is not authorized for distribution to prospective investors unless preceded or accompanied by a prospectus.
MF802044 |
DRAA 3/20
5/2020 |
ITEM 2. CODE OF ETHICS.
As of the end of the year, March 31, 2020, the registrant has adopted a code of ethics, as defined in Item 2 of Form N-CSR, that applies to its Chief Executive Officer, Chief Financial Officer and Treasurer (respectively, the principal executive officer, the principal financial officer and the principal accounting officer, the “Senior Financial Officers”). A copy of the code of ethics is filed as an exhibit to this Form N-CSR.
ITEM 3. AUDIT COMMITTEE FINANCIAL EXPERT.
Peter S. Burgess is the audit committee financial expert and is “independent”, pursuant to general instructions on Form N-CSR Item 3.
ITEM 4. PRINCIPAL ACCOUNTANT FEES AND SERVICES.
(a) Audit Fees
The aggregate fees billed for professional services rendered by the principal accountant(s) for the audit of the registrant’s annual financial statements or services that are normally provided by the accountant(s) in connection with statutory and regulatory filings or engagements amounted to $50,787 for the fiscal year ended March 31, 2020, and $49,125 for the fiscal year ended March 31, 2019 for John Hancock Diversified Real Assets Fund. These fees were billed to the registrant and were approved by the registrant’s audit committee.
(b) Audit-Related Services
Audit-related service fees for the fiscal year ended March 31, 2020 amounted to $612 and $571 for the fiscal year ended March 31, 2019 for John Hancock Diversified Real Assets Fund billed to the registrant or to the registrant's investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the registrant ("control affiliates"). The nature of the services provided was affiliated service provider internal controls reviews. In addition, amounts billed to control affiliates for service provider internal controls reviews were $116,467 for the fiscal year ended March 31, 2020 and $113,000 for the fiscal year ended March 31, 2019.
(c) Tax Fees
The aggregate fees billed for professional services rendered by the principal accountant(s) for the tax compliance, tax advice and tax planning (“tax fees”) amounted to $3,837 for the fiscal year ended March 31, 2020 and $3,725 for the fiscal year ended March 31, 2019 for John Hancock Diversified Real Assets Fund. The nature of the services comprising the tax fees was the review of the registrant’s tax returns and tax distribution requirements. These fees were billed to the registrant and were approved by the registrant’s audit committee.
(d) All Other Fees
Other fees for the fiscal year ended March 31, 2020 amounted to $91 and $102 for the fiscal year ended March 31, 2019 for John Hancock Diversified Real Assets Fund billed to the registrant or to the control affiliates.
(e)(1) Audit Committee Pre-Approval Policies and Procedures:
The trust’s Audit Committee must pre-approve all audit and non-audit services provided by the independent registered public accounting firm (the “Auditor”) relating to the operations or financial reporting of the funds. Prior to the commencement of any audit or non-audit services to a fund, the Audit Committee reviews the services to determine whether they are appropriate and permissible under applicable law.
The trust’s Audit Committee has adopted policies and procedures to, among other purposes, provide a framework for the Committee’s consideration of audit-related and non-audit services by the Auditor. The policies and procedures require that any audit-related and non-audit service provided by the Auditor and any non-audit service provided by the Auditor to a fund service provider that relates directly to the operations and financial reporting of a fund are subject to approval by the Audit Committee before such service is provided. Audit-related services provided by the Auditor that are expected to exceed $25,000 per instance/per fund are subject to specific pre-approval by the Audit Committee. Tax services provided by the Auditor that are expected to exceed $30,000 per instance/per fund are subject to specific pre-approval by the Audit Committee.
All audit services, as well as the audit-related and non-audit services that are expected to exceed the amounts stated above, must be approved in advance of provision of the service by formal resolution of the Audit Committee. At the regularly scheduled Audit Committee meetings, the Committee reviews a report summarizing the services, including fees, provided by the Auditor.
(e)(2) Services approved pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X:
Audit-Related Fees, Tax Fees and All Other Fees:
There were no amounts that were approved by the Audit Committee pursuant to the de minimis exception under Rule 2-01 of Regulation S-X.
(f) According to the registrant’s principal accountant, for the fiscal year ended March 31, 2020, the percentage of hours spent on the audit of the registrant's financial statements for the most recent fiscal year that were attributed to work performed by persons who were not full-time, permanent employees of principal accountant was less than 50%.
(g) The aggregate non-audit fees billed by the registrant's accountant(s) for services rendered to the registrant and rendered to the registrant's control affiliates of the registrant was $1,085,911 for the fiscal year ended March 31, 2020 and $889,301 for the fiscal year ended March 31, 2019.
(h) The audit committee of the registrant has considered the non-audit services provided by the registrant’s principal accountant(s) to the control affiliates and has determined that the services that were not pre-approved are compatible with maintaining the principal accountant(s)' independence.
ITEM 5. AUDIT COMMITTEE OF LISTED REGISTRANTS.
The registrant has a separately-designated standing audit committee comprised of independent trustees. The members of the audit committee are as follows:
Peter S. Burgess - Chairman
Charles L. Bardelis
Theron S. Hoffman
ITEM 6. SCHEDULE OF INVESTMENTS.
(a) Not applicable.
(b) Not applicable.
ITEM 7. DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES.
Not applicable.
ITEM 8. PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES.
Not applicable.
ITEM 9. PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND AFFILIATED PURCHASERS.
Not applicable.
ITEM 10. SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS.
There were no material changes to previously disclosed John Hancock Funds – Governance Committee Charter.
ITEM 11. CONTROLS AND PROCEDURES.
(a) Based upon their evaluation of the registrant's disclosure controls and procedures as conducted within 90 days of the filing date of this Form N-CSR, the registrant's principal executive officer and principal financial officer have concluded that those disclosure controls and procedures provide reasonable assurance that the material information required to be disclosed by the registrant on this report is recorded, processed, summarized and reported within the time periods specified in the Securities and Exchange Commission's rules and forms.
(b) There were no changes in the registrant's internal control over financial reporting that occurred during the period covered by this report that have materially affected, or are reasonably likely to materially affect, the registrant's internal control over financial reporting.
ITEM 12. DISCLOSURE OF SECURITIES LENDING ACTIVITIES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES.
Not applicable.
ITEM 13. EXHIBITS.
(a)(1) Code of Ethics for Senior Financial Officers is attached.
(a)(2) Separate certifications for the registrant's principal executive officer and principal financial officer, as required by Section 302 of the Sarbanes-Oxley Act of 2002 and Rule 30a-2(a) under the Investment Company Act of 1940, are attached.
(b) Separate certifications for the registrant's principal executive officer and principal financial officer, as required by 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, and Rule 30a-2(b) under the Investment Company Act of 1940, are attached. The certifications furnished pursuant to this paragraph are not deemed to be "filed" for purposes of Section 18 of the Securities Exchange Act of 1934, or otherwise subject to the liability of that section. Such certifications are not deemed to be incorporated by reference into any filing under the Securities Act of 1933 or the Securities Exchange Act of 1934, except to the extent that the Registrant specifically incorporates them by reference.
(c)(1) Submission of Matters to a Vote of Security Holders is attached. See attached “John Hancock Funds – Governance Committee Charter”.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
John Hancock Investment Trust
By:
/s/ Andrew Arnott
___________________________
Andrew Arnott
President
Date: May 12, 2020
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.
By:
/s/ Andrew Arnott
___________________________
Andrew Arnott
President
Date: May 12, 2020
By:
/s/ Charles A. Rizzo
___________________________
Charles A. Rizzo
Chief Financial Officer
Date: May 12, 2020
John Hancock Code of Ethics
January 1, 2008
(Revised November 7, 2019)
This is the Code of Ethics for the following:
John Hancock Investment Management, LLC and
John Hancock Variable Trust Advisers, LLC, LLC
(each, a “John Hancock Adviser”)
and
John Hancock Investment Management
Distributors, LLC
John Hancock Distributors, LLC,
each open-end fund, closed-end fund, and exchange traded
fund advised by a John Hancock Adviser
(the “John Hancock Affiliated Funds”),
(together, called “John Hancock”)
Table of Contents | ||
Introduction | 4 | |
Standards of Business Conduct | 5 | |
Applicability and Scope | 5 | |
Access Levels | 6 | |
Access Level 1 | 6 | |
Access Level 2 | 7 | |
Access Level 3 | 7 | |
Overview of Rules for All Access Persons | 7 | |
Brokerage Account Disclosure | 7 | |
Brokerage Account Examples (non-exclusive list) | 8 | |
Employee Compensation Instruments (non-exclusive list) | 8 | |
College Savings Plans - 529s | 8 | |
401(k) and John Hancock Variable Products: John Hancock Affiliated Funds Reporting | 9 | |
Managed Accounts | 9 | |
Preferred Brokerage Account Requirements | 9 | |
Opening/Closing Accounts | 10 | |
Statements and Duplicate Confirmations of Trades | 10 | |
Personal Trading | 10 | |
Personal Trading Restrictions for all Access Persons | 11 | |
Reporting and Pre-clearance | 11 | |
Level 1 Access Persons: Additional Personal Trading Restrictions and Disclosures | 12 | |
Level 2 Access Persons: Additional Personal Trading Restrictions and Disclosures | 14 | |
Level 3 Access Persons: Additional Personal Trading Restrictions and Disclosures | 16 | |
Pre-clearance Process | 17 | |
Reporting and Certification Requirements | 17 | |
Reporting | 17 | |
Reporting Upon Designation | 17 | |
Quarterly Reporting | 18 | |
Annual Reporting | 18 | |
Ad Hoc Reporting | 19 |
2
Administration and Enforcement | 19 | |
Administration of the Code | 19 | |
Subadviser Compliance | 19 | |
Adoption and Approval | 19 | |
Subadviser Reporting & Recordkeeping Requirements | 20 | |
Reporting to the Board | 20 | |
Reporting Violations | 20 | |
Exemptions & Appeals | 21 | |
Exemptions: | 21 | |
Appeals | 21 | |
Interpretation and Enforcement | 21 | |
Education of Employees | 23 | |
Recordkeeping | 23 | |
Other Important Policies | 23 | |
MFC Code of Business Conduct & Ethics (All Covered Employees) | 23 | |
John Hancock Conflicts of Interest Policy (All Covered Employees) | 24 | |
John Hancock Gift & Entertainment Policy (All Covered Employees) | 24 | |
John Hancock Insider Trading Policy (All Covered Employees) | 24 | |
John Hancock Pay to Play Rule on Political Contributions (All Covered Associates) | 25 | |
John Hancock Whistleblower Policy (All Covered Employees) | 25 | |
Policy and Procedures Regarding Disclosure of Portfolio Holdings (All Covered Employees) | 26 | |
Additional Policies Outside the Code (All Covered Employees) | 26 | |
Appendix | 27 | |
Definitions | 27 | |
Preferred Brokers List | 31 | |
Compliance Contacts | 32 |
3
Introduction
John Hancock is required by law to adopt a Code of Ethics. The purpose of a Code of Ethics is to ensure that companies and their Covered Persons comply with all applicable laws and to prevent abuses in the investment advisory business that can arise when conflicts of interest exist between the employees of an investment advisor and its clients. By adopting and enforcing a Code of Ethics, we strengthen the trust and confidence entrusted in us by demonstrating that at John Hancock, client interests come first.
The Code of Ethics (the Code) that follows represents a balancing of important interests. On the one hand, as registered investment advisers, the John Hancock Advisers owe a duty of undivided loyalty to their clients and must avoid even the appearance of a conflict that might be perceived as abusing the trust they have placed in John Hancock. On the other hand, the John Hancock Advisers do not want to prevent conscientious professionals from investing for their own accounts where conflicts do not exist or that are immaterial to investment decisions affecting the John Hancock Advisers’ clients.
When conflicting interests cannot be reconciled, the Code makes clear that, first and foremost, Covered Persons owe a fiduciary duty to John Hancock clients. In most cases, this means that the affected employee will be required to forego conflicting personal securities transactions. In some cases, personal investments will be permitted, but only in a manner, which, because of the circumstances and applicable controls, cannot reasonably be perceived as adversely affecting John Hancock client portfolios or taking unfair advantage of the relationship John Hancock employees have to John Hancock clients.
The Code contains specific rules prohibiting defined types of conflicts. Since every potential conflict cannot be anticipated by the Code, it also contains general provisions prohibiting conflict situations. In view of these general provisions, it is critical that any Covered Person who is in doubt about the applicability of the Code in a given situation seek a determination from Chief Compliance Officer (CCO), designee, or the Code of Ethics Administration Group about the propriety of the conduct in advance.
It is critical that the Code be strictly observed. Not only will adherence to the Code ensure that John Hancock renders the best possible service to its clients, it will help to ensure that no individual is liable for violations of law.
It should be emphasized that adherence to this policy is a fundamental condition of employment at John Hancock. Every Covered Person is expected to adhere to the requirements of the Code despite any inconvenience that may be involved. Any Covered Person failing to do so may be subject to disciplinary action, including financial penalties and termination of employment as determined by the CCO, designee, or Ethics Oversight Committee.
4
Standards of Business Conduct
Each Covered Person within the John Hancock organization is responsible for maintaining the very highest ethical standards when conducting our business.
This means that you must at all times:
● |
Place the interests of clients first. You have a fiduciary duty at all times to place the interests of our clients and fund investors first. |
● |
Conduct all personal trading in full compliance with this Code. All of your personal securities transactions must be conducted consistent with the provisions of the Code that apply to you and in such a manner as to avoid any actual or potential conflict of interest or other abuse of your position of trust and responsibility. |
● |
Avoid taking inappropriate advantage of your position at John Hancock. You should not take inappropriate advantage of your position or engage in any fraudulent or manipulative practice (such as front-running or manipulative market timing) with respect to our clients’ accounts or fund investors. |
● |
Maintain confidentiality of our clients and John Hancock. You must treat as confidential any information concerning the identity of security holdings and financial circumstances of clients or fund investors. |
● |
Comply with applicable Federal Securities Laws. You must comply with all applicable federal Securities Laws. |
● |
Report any violation of the Code. You must promptly report any violation of the Code that comes to your attention to the CCO (or designee) of your company. |
It is essential that you understand and comply with the general principles, noted above, in letter and in spirit as no set of rules can anticipate every possible problem or conflict situation. Failure to comply with the general principles and the provisions of the Code may result in disciplinary action, including termination of employment.
Applicability and Scope
Individuals subject to this policy will be notified by the CCO, designee, or the Code of Ethics Administration Group. Generally, if you meet the requirements listed below, you are deemed an Access Person1 and this Code applies to you2:
● |
a director, officer or other Supervised Person of a John Hancock Adviser; |
● |
an interested director, officer or Access Person of John Hancock Investment Management Distributors, LLC, John Hancock Distributors, LLC, or a John Hancock open-end or closed-end fund registered under the 1940 Act and are advised by a John Hancock Adviser;3 |
● |
an employee of Manulife Financial Corporation (MFC) or its subsidiaries who participates in making recommendations for, or receives information about, portfolio trades or holdings of the John Hancock Affiliated Funds.4 |
1 See the Definitions section and contact a member of the Office of the CCO with any questions.
2 Access Persons of John Hancock GA Mortgage Trust that are personnel of John Hancock Investment Management, LLC are covered by this Code.
3 Disinterested Trustees of John Hancock open-end and closed-end funds registered under the 1940 Act and advised by a John Hancock Adviser are subject to a separate Code of Ethics adopted by the Board of Trustees.
5
Access Levels
The requirements of this policy will differ depending on your Access Level category. There are three categories for persons covered by the Code, taking into account position, duties and access to information regarding fund portfolio trades.5 You will receive notification as to your particular category, based on the Code of Ethics Administration Group’s understanding of your current role in coordination with the Office of the CCO. If you have a level of investment access beyond your assigned category, or if you are promoted or change duties and as a result should more appropriately be included in a different category, it is your responsibility to notify the CCO, designee, or the Code of Ethics Administration Group.
Please note: If a specific Code provision (examples: personal investing restriction or limitations, pre-clearance obligation, or reporting obligation, etc.) applies to the Access Person, it also applies to all Securities and Brokerage Accounts over which the Access Person has Beneficial Ownership.
Access Level 1
A person who, in connection with his/her regular functions or duties, makes or participates in making recommendations regarding the purchase or sale of securities by the Fund or account.
Examples (may include but are not limited to):
● |
Portfolio Managers |
● |
Analysts |
● |
Traders |
4 The preceding excludes John Hancock Asset Management (U.S.) and John Hancock Asset Management (N.A.) each of whom have adopted their own Code of Ethics in accordance with Rule 204A-1 under the Advisers Act.
5 The Code of Ethics Administration Group, CCO (or designee) may modify the requirements of this Code for those John Hancock Associates whose covered status is expected not to exceed 90 days (for instance contractors, co-ops and interns) or in instances where a person is subject to another Code of Ethics or fiduciary duty and where the modification is not otherwise specifically prohibited by law. In reliance on an SEC no-action letter, the Code of Ethics Administration Group or CCO (or designee) may include in the definition of “John Hancock Associate” any person of a John Hancock Affiliate who is engaged, directly or indirectly in John Hancock’s investment advisory activities.
6
Access Level 2
A person who, in connection with his/her regular functions or duties, has regular access to nonpublic information regarding any clients' purchase or sale of securities, nonpublic information regarding the portfolio holdings of any John Hancock Affiliated Fund(s), is involved in making securities recommendations to clients, or has regular access to such recommendations that are nonpublic.
Examples (may include but are not limited to):
● |
Office of the CCO |
● |
Fund Administration |
● |
Investment Management Services |
● |
Technology Resources Personnel (as designated) |
● |
Legal Staff |
● |
Marketing (as designated) |
Access Level 3
A person who, in connection with his/her regular functions or duties, has periodic access to nonpublic information regarding any clients' purchase or sale of securities or nonpublic information regarding the portfolio holdings of any John Hancock Affiliated Funds.
Examples (may include but are not limited to):
● |
Marketing (as designated) |
● |
Product Development |
● |
E-Commerce |
● |
Corporate Publishing |
● |
Technology Resources Personnel (as designated) |
Overview of Rules for All Access Persons
This policy contains rules regarding your obligations to comply with federal Securities Laws and John Hancock’s standards of conduct. Access Persons are responsible for complying with the personal trading restrictions and obligations of their access designation level including: Brokerage Account disclosure, personal trading restrictions, pre-clearance requirements, disclosure requirements, and various reporting and certification requirements.
Brokerage Account Disclosure
You must use the Personal Trading Control Center (PTCC), the automated compliance system, to disclose all Brokerage Accounts that have the capability to hold Reportable Securities including all Brokerage Accounts:
● |
of your own; regardless of what is currently held in the account, |
● |
of your spouse, Significant Other, minor children or family members sharing the same household (Household Family Member), |
● |
over which you have discretion or give advice or information, and/or |
● |
in which your Household Family Member have Beneficial Ownership, or the opportunity to directly or indirectly profit or share in any profit derived from a Reportable Securities transaction. |
7
Brokerage Account Examples (non-exclusive list)
You need to report:
● |
Brokerage Accounts |
● |
John Hancock 401(k) accounts |
● |
MFC Global Share Ownership Plan (GSOP) |
● |
Solium accounts (some if they hold reportable securities including options on MFC securities) |
● |
Self-directed IRA accounts |
● |
Custodial accounts |
● |
Mutual fund accounts* |
● |
College investment plans 529s* |
● |
401(k)/403(b) accounts* |
● |
Dividend reinvestment program or dividend reinvestment plan (DRIP) |
● |
Registered Retirement Savings Plan (RRSP/RESP/TFSA) |
● |
Stock Purchase accounts |
*if they have the capability to hold John Hancock Affiliated Funds
Employee Compensation Instruments (non-exclusive list)
You need to report:
● |
John Hancock 401(k) |
● |
MFC Global Share Ownership Plan (GSOP) |
● |
Options acquired from MFC (only MFC Solium account options that are granted) |
● |
Public company employer as part of employee compensation |
● |
Sole discretion accounts |
● |
Accounts holding John Hancock Affiliated Funds |
● |
Certain Manulife Pension Plans (RPS, RRSP) |
You are not responsible for reporting:
● |
MFC Restricted Share Units (RSU) |
● |
Deferred Share Units (DSU) |
● |
Performance Share Units (PSU) |
● |
US John Hancock Pension Plans |
● |
Employer phantom stock/phantom option interest (granted as compensation to employee, only employer can redeem interest and interest is non-transferrable) |
To prevent any potential violations of the Code, you are strongly encouraged to request clarification for accounts that are in question from the Code of Ethics Administration Group INVDIVCodeofEthics@manulife.com.
College Savings Plans - 529s
You must report John Hancock affiliated 529 plans including both the Freedom 529 plan and any other 529 plans that can hold John Hancock Affiliated Funds. You are not required to report transactions or holdings in 529 Plans for which the Adviser or a control affiliate does not manage, distribute, market or underwrite the 529 Plan or the investments and strategies underlying the 529 Plan. If you have any questions about this requirement, please contact the Code of Ethics Administration Group or a member of the Office of the CCO.
8
401(k) and John Hancock Variable Products: John Hancock Affiliated Funds Reporting
You must report your holdings and trades in a John Hancock Affiliated Funds. This includes voluntary trades in your John Hancock affiliated accounts such as your 401(k) and any external Brokerage Account.
To comply with this requirement, if you purchase a John Hancock variable product you must provide your contract or policy number to the Code of Ethics Administration Group and if you have a John Hancock 401(k), you must you must enter the Brokerage Account on PTCC.
Managed Accounts
Managed Accounts are considered fully managed if neither Access Person nor Household Family Member has no direct influence or control. Prior to the execution of Reportable Securities transactions in the Managed Account, you must obtain approval from the CCO (or designee). Once the Brokerage Account is approved as a Managed Account, in writing from the CCO (or designee) of the Adviser/Trust, the transactions do not need to be pre-cleared. Exemption requests which pose a conflict of interest for the CCO (or designee) will be escalated to the Ethics Oversight Committee for review and consideration.
You may request approval by disclosing the Brokerage Account in the automated compliance system, marking it as a Managed Account and by providing the appropriate evidence as described below. You are required to provide evidence that you or your Household Family Member has no direct or indirect influence or control including not being able to:
1) | Suggest that the trustee or third-party discretionary manager make any particular purchases or sales of Reportable Securities; |
2) | Direct the trustee or third-party discretionary manager to make any particular purchases or sales of Reportable Securities; and |
3) | Consult with the trustee or third-party discretionary manager as to the particular allocation of investments to be made in your account. |
You may also be asked to periodically attest to the status of the Managed Account(s) and provide electronic feeds or duplicate statements.
Preferred Brokerage Account Requirements
You must maintain your Brokerage Accounts at one of the preferred brokers approved by John Hancock. Upon designation as an Access Person, you have 45 calendar days to (i) qualify any non-compliant Brokerage Account as an exempt account or (ii) transfer all assets to a preferred broker and close the non-compliant account. Please note that you are not required to move 401(k) accounts. Exceptions may be granted with the approval from the CCO, its designee, or the Code of Ethics Administration Group. Requests for exceptions to this policy must be submitted in writing to the Code of Ethics Administration Group. A list of the Preferred Brokers can be found in the Appendix.
9
Opening/Closing Accounts
You are required to report each transaction in any Reportable Security to the Code of Ethics Administration Group. To comply with this requirement, you:
● |
Are required to notify the Code of Ethics Administration team within 10 days of opening or closing a Brokerage Account. In the case of a new Brokerage Account in which you have a beneficial interest, you must notify the Code of Ethics Administration Group before any trades are placed. |
● |
Are required by this Code and by the Insider Trading Policy to inform your broker-dealer that you are employed by a financial institution. Your broker-dealer is subject to certain rules designed to prevent favoritism toward your Brokerage Accounts. You may not accept negotiated commission rates that you believe may be more favorable than the broker grants to accounts with similar characteristics. |
● |
Must notify the broker-dealer if you are registered with the Financial Industry Regulatory Authority or are employed by John Hancock Investment Management Distributors, LLC or John Hancock Distributors, LLC. |
Statements and Duplicate Confirmations of Trades
The Code of Ethics Administration Group may rely on information submitted by your broker as part of your reporting requirements under the Code. Upon notification of your Brokerage Account, the Code of Ethics Administration Group will notify the broker-dealer to have duplicate confirmations of any trade, as well as statements or other information concerning the Brokerage Account, sent to:
John Hancock Financial Services
Attention: General Funds Compliance
197 Clarendon Street, C-03-13
Boston, MA 02116
Personal Trading
Personal Trading is a privilege and must always come second to the fiduciary duty you owe to our clients. Below is a list of personal trading restrictions for all Access Persons.
All Access Persons must:
● |
Disclose holdings in Reportable Securities (including John Hancock Affiliated Funds and John Hancock Variable Products) |
● |
Disclose Brokerage Accounts |
● |
Pre-clear applicable Reportable Securities transactions |
10
Personal Trading Restrictions for all Access Persons
All Access Persons are prohibited from:
● |
Profiting from the purchase and sale of a John Hancock Affiliated Fund within 30 calendar days. |
● |
Engaging in speculative transactions involving MFC securities including: options, hedging or short sales involving securities issues by Manulife. |
● |
Transacting in securities that appear on the confidential John Hancock Restricted list (pre-clearance requests will be denied). |
● |
Transacting in Initial Public Offerings (IPOs), Private Placements, and Limited Offerings without obtaining proper pre-clearance approval.6 |
● |
Transacting in securities while in possession of material nonpublic information including but not limited to: fund events, due diligence visits etc. |
An Access Person who either directs 45 or more trades in a quarter or redeems shares of a John Hancock Affiliated Fund within 30 days of purchase, should expect additional scrutiny of his or her trades and he or she may be subject to limitations on the number of trades allowed during a given period.
Reporting and Pre-clearance
As an Access Person, you are required to report to the Code of Ethics Administration Group each transaction in any Reportable Security. You must ensure that all transactions (unless it is an Involuntary Issuer Transaction) and holdings in Reportable Securities are properly reflected in the requisite initial, quarterly and annual reporting certifications. To facilitate the reporting process, please ensure that you have properly disclosed your correct Brokerage Account information to the Code of Ethics Administration Group in the automated compliance system, including the disclosure of participation in the John Hancock 401(k) and Manulife GSOP.
The transaction and holding reporting requirement does not include John Hancock money market funds or any dividend reinvestment, payroll deduction, systematic investment/withdrawal and/or other program trades. Please note that different requirements apply to shares of John Hancock Affiliated Funds, including a 30-day holding period requirement.
As an Access Person, in addition to your reporting obligations, you have pre-clearance obligations for certain securities, depending on your Access Level group. Please see the appropriate access level below, for more detailed information.
6 Please note, Level 1 Access Persons and Registered Representatives are prohibited from purchasing IPOs.
11
Level 1 Access Persons: Additional Personal Trading Restrictions and Disclosures
Please note, there are additional restrictions that apply to all Access Persons listed in the section entitled, “Personal Trading Restrictions for All Access Persons”.
Level 1 Access Persons
● |
Pre-clear MFC Securities: You must pre-clear all transactions in MFC securities including stock, company issued options, securities such as debt, and sell transactions in the MFC Global Share Ownership Plan. |
● |
Pre-clear all of the following securities: You must pre-clear and receive approval prior to transactions in the following securities: |
• |
Stocks; including sell transactions of MFC Shares held in your Global Share Ownership Plan |
• |
Bonds; |
• |
Government securities that are not direct obligations of the U.S. government, such as Fannie Mae, or municipal securities, in each case that mature in more than one year; |
• |
John Hancock Affiliated Funds;7 |
• |
Closed-end funds (including John Hancock affiliated closed-end funds) |
• |
Options on securities, on indexes, and on currencies; |
• |
Swaps on securities, on indexes, and on currencies; |
• |
Limited partnerships; |
• |
Exchange traded funds and notes; |
• |
Domestic unit investment trusts; |
• |
Non-US unit investment trusts and Non-US mutual funds; |
• |
Private investment funds and hedge funds; and |
• |
Futures, investment contracts or any other instrument that is considered a “security” under the Securities Act of 1933; |
• |
Private Placements, limited offerings8. |
● |
Ban on IPOs: You may not acquire securities in an IPO. You may not purchase any newly-issued Reportable Security until it is listed on a public exchange. |
● |
Seven Day Blackout: You are prohibited from buying or selling a Reportable Security within 7 calendar days before or after that Reportable Security is traded for a fund that the Person manages or for a John Hancock Affiliated Fund unless no conflict of interest exists in relation to that Reportable Security as determined by the Code of Ethics Administration Group. |
● |
Gifting Reportable Securities: If you gift or donate shares of a Reportable Security it is considered a sale and you must receive pre-clearance approval. |
● |
Inheriting Reportable Securities: If you inherit shares of a Reportable Security you must notify the Code of Ethics Administration Group within 10 days. |
7 John Hancock Affiliated open ended mutual funds do not require pre-clearance, only reporting. However, there are certain holding period requirements. A list of John Hancock Affiliated Funds can be found on PTCC.
8 Level 1 Access Persons are banned from participation in IPOs.
12
● |
30 Day Hold John Hancock Affiliated Funds: You cannot profit from the purchase and sale of a John Hancock Affiliated Funds within 30 calendar days. |
● |
60 Day Hold: You may not profit from the purchase and sale (or sale and purchase) of the same (or equivalent) Reportable Security (see note on John Hancock Affiliated Funds) within 60 calendar days, also known as a “Ban on Short Term Profits”. |
○ |
Exclusion: pre-clearance requests in a Reportable Security with a market capitalization of $5 billion or more would, in most cases, not be subject to the 60 day hold and would be approved if they are appropriately pre-cleared. |
● |
Ownership Ban: Securities of Sub-advisers: you are prohibited from owning securities of any sub-adviser of a John Hancock Affiliated Fund.9 |
● |
Must promptly disclose: |
○ |
Ownership of Securities Under Consideration for John Hancock Affiliated Fund: Any direct or indirect beneficial interest in a Reportable Security that is under consideration for purchase or sale in a John Hancock Affiliated Fund. |
○ |
Private Placement Conflicts: You must disclose holdings of any Reportable Securities purchased in a private placement when you participate in a decision to purchase or sell that same issuer’s securities for a John Hancock Affiliated Fund. |
● |
Restriction on Securities Under Active Consideration: You are prohibited from buying or selling a Reportable Security if the Reportable Security is being actively traded by a John Hancock Affiliated Fund. |
○ |
Exceptions: |
■ |
De Minimis Trading: pre-clearance requests for 500 shares or less of a particular Reportable Security within a market value of $25K or less, aggregated daily, would, in most cases, not be subject to the 7- day blackout period restrictions and the restriction on actively traded securities. |
■ |
Market Cap Securities: pre-clearance requests in a Reportable Security with a market capitalization of $5B or more would not be subject to the blackout period restrictions and the restriction on actively traded securities. |
● |
Pre-clearance of Exchange Traded Funds/Exchange Traded Notes (ETF/ETN) and Options on Reportable Securities: you are required to pre-clear ETFs, ETNs and Options on Reportable Securities. |
○ |
Exceptions to the pre-clearance requirement for ETF/ETN or options on Reportable Securities (provided it is not a John Hancock Affiliated Fund): |
○ |
has an average market capitalization of $5 billion or more; |
○ |
is based on a non-covered security; |
○ |
or is based on a Broad-Based Index. |
9 MFC securities are excluded from Level 1 & Level 2 sub-adviser ownership prohibition. The list of securities of sub-advisers can be found on the automated compliance system or upon request from the CCO.
13
● |
Prohibition on Investment Clubs, Good Until Canceled Orders, or Limit Orders: You may not participate in: |
○ |
investment clubs, |
○ |
“good until cancelled orders”, or |
○ |
“limit orders” unless the limit orders are day orders that automatically expire at the end of the trading day and cancel any orders that have not been executed. |
Investment Professionals Only
Level 1 Access Persons who are “Investment Professionals” (Analysts and Portfolio Managers) must disclose the following:
○ |
Ownership of 5% or Greater: 5% or greater interest in a company, John Hancock Affiliated Funds and its affiliates may not make any investment in that company; |
○ |
Ownership of 1% or greater 1% or greater interest in a company, you cannot participate in any decision by John Hancock Funds and its affiliates to buy or sell that company’s securities; |
○ |
ANY other interest in a company, you cannot recommend or participate in a decision by John Hancock Affiliated Funds, and its affiliates to buy or sell that company’s securities unless your personal interest is fully disclosed at all stages of the investment decision. |
In such instances, you must initially disclose that beneficial interest orally to the primary portfolio manager (or other appropriate analyst) of the Affiliated Fund(s) or account or the appropriate Chief Investment Officer. Following the oral disclosure, you must send a written acknowledgement to the primary portfolio manager with a copy to the Code of Ethics Administration Group.
Level 2 Access Persons: Additional Personal Trading Restrictions and Disclosures
Please note, there are additional restrictions that apply to all Access Persons listed in the section entitled, “Personal Trading Restrictions for All Access Persons”.
Level 2 Access Persons:
● |
Pre-clear MFC Securities: You must pre-clear all transactions in MFC securities including stock, company issued options, sell transactions in the MFC Global Share Ownership Plan, and any other securities such as debt. |
● |
Pre-clear the following securities: You must pre-clear and receive approval prior to transactions in the following securities: |
• |
Stocks; including sell transactions of MFC Shares held in your Global Share Ownership Plan |
• |
Bonds; |
• |
Government securities that are not direct obligations of the U.S. government, such as Fannie Mae, or municipal securities, in each case that mature in more than one year; |
14
• |
John Hancock Affiliated Funds;10 |
• |
Closed-end funds (including John Hancock affiliated closed-end funds) |
• |
Options on securities, on indexes, and on currencies; |
• |
Swaps on securities, on indexes, and on currencies; |
• |
Limited partnerships; |
• |
Exchange traded funds and notes; |
• |
Domestic unit investment trusts; |
• |
Non-US unit investment trusts and Non-US mutual funds; |
• |
Private investment funds and hedge funds; and |
• |
Futures, investment contracts or any other instrument that is considered a “security” under the Securities Act of 1933; |
• |
IPOs11, Private Placements, limited offerings. |
● |
Three Day Blackout Period: You are prohibited from knowingly buying or selling a Reportable Security within three calendar days before and after that Reportable Security is traded for a John Hancock Affiliated Fund unless no conflict of interest exists in relation to that Reportable Security as determined by the Code of Ethics Administration Group. |
● |
Gifting Reportable Securities: If you gift or donate shares of a Reportable Security the transaction is considered a sale and you must receive pre-clearance approval. |
● |
Inheriting Reportable Securities: If you inherit shares of a Reportable Security you must notify the Code of Ethics Administration Group within 10 days. |
● |
30 Day Hold John Hancock Affiliated Funds: You cannot profit from the purchase and sale of a John Hancock Affiliated Funds within 30 calendar days. |
● |
60 Day Hold: You may not profit from the purchase and sale (or sale and purchase) of the same (or equivalent) Reportable Security within 60 calendar days, also known as a “Ban on Short Term Profits”. |
○ |
Exclusion: pre-clearance requests in a Reportable Security with a market capitalization of $5 billion or more would, in most cases, not be subject to the Ban on Short Term Profits, and would be approved if they are appropriately pre-cleared. |
● |
Ownership Ban: Securities of Sub-advisers: you are prohibited from owning securities of any sub-adviser of a John Hancock Affiliated Fund.12 |
● |
Restriction on Securities Under Active Consideration: You are prohibited from buying or selling a Reportable Security if the security is being actively traded by a John Hancock Affiliated Fund. |
○ |
Exceptions: |
■ |
De Minimis Trading: pre-clearance requests for 500 shares or less of a particular Reportable Security within a market value of $25K or less, aggregated daily, would, in most cases, not be subject to the 7- day blackout period restrictions and the restriction on actively traded securities. |
10 John Hancock Affiliated open ended mutual funds do not require pre-clearance, only reporting. However, there are certain holding period requirements.
11 Level 1 Access Persons are banned from participation in IPOs.
12 MFC securities are excluded from Level 1 &Level 2 sub-adviser ownership prohibition. The list of securities of sub-advisers can be found on the automated compliance system or upon request from the CCO.
15
■ |
Market Cap Securities: pre-clearance requests in a Reportable Security with a market capitalization of $5B or more would not be subject to the blackout period restrictions and the restriction on actively traded securities. |
● |
Pre-clearance of Exchange Traded Funds/Exchange Traded Notes (ETF/ETN) and Options on Reportable Securities: you are required to pre-clear ETFs, ETNs and Options on Reportable Securities. |
○ |
Exceptions to the pre-clearance requirement for ETF/ETN or options on Reportable Securities (provided it is not a John Hancock Affiliated Fund): |
■ |
has an average market capitalization of $5 billion or more; |
■ |
is based on a non-covered security; |
■ |
or is based on a Broad-Based Index. |
● |
Prohibition on Investment Clubs, Good Until Canceled Orders, or Limit Orders: You may not participate in: |
○ |
investment clubs, |
○ |
“good until cancelled orders”, or |
○ |
“limit orders” unless the limit orders are day orders that automatically expire at the end of the trading day and cancel any orders that have not been executed. |
Level 3 Access Persons: Additional Personal Trading Restrictions and Disclosures
Please note, there are additional restrictions that apply to all Access Persons listed in the section entitled, “Personal Trading Restrictions for All Access Persons”.
Level 3 Access Persons:
● |
Pre-clear transactions in: |
○ |
closed-end funds and exchange traded funds advised by a John Hancock Adviser |
○ |
transactions in IPOs |
○ |
private placements and limited offerings. |
● |
Gift or Donation of Reportable Securities: You must obtain pre-clearance approval prior to gifting or donating any Reportable Securities transactions that would require pre-clearance. |
● |
Inheritance of Reportable Securities: If you inherit shares of a Reportable Security you must notify the Code of Ethics Administration Group within 10 days. |
● |
30 Day Hold John Hancock Affiliated Funds: You cannot profit from the purchase and sale of a John Hancock Affiliated Funds within 30 calendar days. |
16
An Access level 3 Person is not required to pre-clear other trades. However, please keep in mind that an Access level 3 Person is required to report Reportable Securities transactions after every trade (even those that are not required to be pre-cleared) by requiring your broker to submit duplicate confirmation statements or electronic feeds to the Code of Ethics Administration Group. You must also ensure that all transactions in Reportable Securities are properly reported on your quarterly transaction/annual holdings certification.
Pre-clearance Process
You may request a trade pre-clearance through the automated compliance system, PTCC.
Please note that:
● | You may not trade until clearance approval is received. |
● | Clearance approval is valid only for the date granted (i.e. the pre-clearance requested date and the trade date should be the same). |
● | A separate procedure should be followed for requesting pre-clearance of an IPO, a private placement, or a limited offering in PTCC. |
Certain transactions in securities that would normally require pre-clearance are exempt from the pre-clearance requirement in the following situations: (1) shares are being purchased as part of an Automatic Investment Plan; (2) shares are being purchased as part of a dividend reinvestment plan; or (3) transactions are being made in a Managed/discretionary account, an account over which you have designated a third party as having sole discretion to trade (you must have approval from the CCO (or designee) to establish a discretionary account).
Reporting and Certification Requirements
Reporting
All Access Persons, regardless of their level, must complete and submit reports and certifications to compliance using PTCC, the automated compliance system, in an accurate and timely manner as described below.
Reporting Upon Designation
Within 10 calendar days after designation as an Access Person, you must complete and submit to compliance using PTCC:
● | Initial Holdings Report: A report of all Brokerage Accounts (please see the definition section) that hold or have the ability to hold any Reportable Securities and all Reportable Securities holdings current as of the date you became an Access Person. |
● | Initial Certification of Compliance: Certify to your understanding of the Code of Ethics. |
● | Initial Training: Certify that you have attended a training on the Code of Ethics Policy. |
17
Quarterly Reporting
Within 30 calendar days after the end of each calendar quarter, you must complete and submit to compliance using PTCC:
● | Quarterly Certification: a report of all Brokerage Accounts and all transactions in Reportable Securities (including transactions in John Hancock Affiliated Funds, including sell transactions in your Global Share Ownership Plan (GSOP) and voluntary transactions, such as fund exchanges, in your John Hancock 401(k)). |
● | Managed Account Certification: A certification of related to your Managed Accounts (only if applicable). |
Additional transaction notes:
● | All transactions in John Hancock Affiliated Funds and Variable Products must be reported. |
● | Only sell transactions of MFC stock in your Global Share Ownership Plan (GSOP) need to be reported. |
● | Only voluntary transactions, such as fund exchanges, need to be reported for transactions in your John Hancock 401(k) Savings account. |
For each Brokerage Account you must certify that the following information is captured accurately:
● | Account number |
● | Brokerage Firm |
For each transaction required to be reported you must certify the following information was captured accurately:
● | the date of the transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and principal amount of each Reportable Security involved; |
● | the nature of the transaction (i.e. purchase, sale or any other type of acquisition or disposition); |
● | the price at which the transaction was effected; |
● | the name of the broker, dealer or bank with or through which the transaction was effected. |
Annual Reporting
At a date designated by the Code of Ethics Administration Group, at least annually (or additionally when the Code has been materially changed), you must complete and submit to compliance:
● | Annual Holdings Report: disclosing all of your Brokerage Accounts that hold or can hold any Reportable Securities and all holdings in Reportable Securities, current as of a date not more than 45 days before the report is submitted. |
18
○ | John Hancock Affiliated Funds & Variable Products holdings must be reported, regardless of where they are held. |
○ | Global Share Ownership holdings of Manulife Financial Corporation, Inc. (MFC) stock must be reported. |
● | Annual (or additionally when the Code has been materially changed) Certification of Code of Ethics: acknowledging that you have received, read, and complied with the requirements of the Code of Ethics. |
Ad Hoc Reporting
Throughout the year you must complete and submit to compliance:
● | Brokerage Account Changes: You are required to promptly notify (within 10 days) Compliance of any applicable account changes. |
● | Changes to the Code of Ethics: You are required to complete an additional certification of compliance stating that you read, received and understood material changes to the Code of Ethics. |
Administration and Enforcement
Administration of the Code
Sub-adviser Compliance
A sub-adviser to a John Hancock Affiliated Fund has a number of Code of Ethics responsibilities:
● | The sub-adviser must have adopted their own code of ethics in accordance with Rule 204A-1(b) under the Advisers Act which has been approved by the Board of Trustees; |
● | On a quarterly basis, each sub-adviser certifies compliance with their Code of Ethics or reports material violations if such have occurred; and |
● | Each sub-advisor must report quarterly to the CCO (or designee), any material changes to its Code of Ethics. |
Adoption and Approval
The Board of a John Hancock Affiliated Fund, including a majority of the Fund’s Independent Board Members, must approve the Code of Ethics of the Fund’s adviser, sub-adviser or principal underwriter (if an affiliate of the underwriter serves as a Board member or officer of the Fund or the adviser) before initially retaining its services.
Each material change to a Code of Ethics of a sub-adviser to a fund must be approved by the Board of the John Hancock Affiliated Fund, including a majority of the Fund’s Independent Board Members, no later than six months after adoption of the material change.
19
The Board may only approve the Code if they determine that the Code:
● | Contains provisions reasonably necessary to prevent the subadviser’s Access Persons (as defined in Rule 17j-1 under the 1940 Act and Rule 204A-1 under the Advisers Act) from engaging in any conduct prohibited by Rule 17j-1 and 204A-1; |
● | Requires the sub-adviser’s Access Persons to make reports to at least the extent required in Rule 17j-1(d) and Rule 204A-1(b); |
● | Requires the sub-adviser to institute appropriate procedures for review of these reports by management or compliance personnel (as contemplated by Rule 17j-1(d)(3) and Rule 204 A-1(a)(3)); |
● | Provides for notification of the sub-adviser’s Access Persons in accordance with Rule 17j-1(d)(4) and Rule 204A-1(a)(5); |
● | Requires the sub-adviser’s Access Persons who are Investment Personnel to obtain the pre- clearances required by Rule 17j-1(e); and |
● | Requires the sub-adviser’s Access Persons to obtain the pre-clearances required by Rule 204A- 1(c). |
The CCO of the John Hancock Affiliated Funds oversees each of the fund’s sub-adviser to ensure compliance with each of the provisions included in this section.
Sub-adviser Reporting & Recordkeeping Requirements
Each sub-adviser must complete an annual Code of Ethics questionnaire and certification as
to their compliance under Rule 17j-1 and summary of any violation to the relevant John
Hancock Adviser, whom present summaries to the Board of Trustees annually during their 2nd
quarter meeting (which is typically held in June).
Reporting to the Board
No less frequently than annually, the Office of the CCO will furnish to the Board of Trustees a written report that:
● | describes issues that arose during the previous year under the Code of Ethics or the related procedures, including, but not limited to, information about material Code or procedure violations, as well as any sanctions imposed in response to the material violations, and |
● | certifies that each entity, including the sub-advisers have adopted procedures reasonably necessary to prevent its Access Persons from violating its Code of Ethics, |
● | Any material changes to the Code are presented to the Trustees within six months for their approval. |
The CCO of the John Hancock Affiliated Funds oversees each of the fund’s sub-adviser to ensure compliance with each of the provisions included in this section.
Reporting Violations
If you know of any violation of the Code, you have a responsibility to promptly report it to the CCO of your company. You should also report any deviations from the controls and procedures that safeguard John Hancock and the assets of our clients.
20
Since we cannot anticipate every situation that will arise, it is important that we have a way to approach questions and concerns. Always ask first, act later. If you are unsure of what to do in any situation, seek guidance before you act.
Speak to your manager, a member of the Human Resources Department or Legal Department or your divisional compliance officer if you have:
● | a doubt about a particular situation; |
● | a question or concern about a business practice; or |
● | a question about potential conflicts of interest |
You may report suspected or potential illegal or unethical behavior without fear of retaliation. John Hancock does not permit retaliation of any kind for good faith reports of illegal or unethical behavior. Concerns about potential or suspected illegal or unethical behavior should be referred to a member of the Human Resources or Legal Department. John Hancock relies on the Manulife Code of Business Conduct which advises that unethical, unprofessional, illegal, fraudulent or other questionable behavior may also be reported by calling a confidential toll-free Ethics Hotline at 1-866-294-9534 or at www.ManulifeEthics.com.
Exemptions & Appeals
Exemptions: to the Code may be granted by the CCO (or designee) where supported by
applicable facts and circumstances. If you believe that you have a situation that warrants an
exemption to any of the rules and restrictions of this Code you need to submit a written request
to the CCO (or designee). All requests will be reviewed on a case by case basis. The CCO (or
designee) will provide a written response detailing its decision once the review has been
completed.
Exemption requests which pose a conflict of interest for the CCO will be escalated to the Ethics Oversight Committee for review and consideration.
Appeals: If you believe that your request has been incorrectly denied or that an action is not warranted, you may appeal the decision. To make an appeal, you need to give the CCO (or designee) of the Adviser/Trust a written explanation of your reasons for appeal within 30 days of the date that you were informed of the decision. Be sure to include any extenuating circumstances or other factors not previously considered. During the review process, you may, at your own expense, engage an attorney to represent you. The Code of Ethics Administration Group may arrange for Ethics Oversight Committee or other parties to be part of the review process.
Interpretation and Enforcement
The Code cannot anticipate every situation in which personal interests may be in conflict with the interests of our clients and fund investors. You should be responsive to the spirit and intent of the Code as well as its specific provisions.
21
When any doubt exists regarding any Code provision or whether a conflict of interest with clients or fund investors might exist, you should discuss the situation in advance with the CCO (or designee) of your company. The Code is designed to detect and prevent fraud against clients and fund investors, and to avoid the appearance of impropriety.
The CCO has general administrative responsibility for the Code as it applies to the covered employees; an appropriate member of the Code of Ethics Administration Group will administer procedures to review personal trading activity. The Code of Ethics Administration Group also regularly reviews the forms and reports it receives. If these reviews uncover information that is incomplete, questionable, or potentially in violation of the rules in this document, the Code of Ethics Administration Group will investigate the matter and may contact you.
The Board of the John Hancock Affiliated Funds approve material amendments to the Code and authorize sanctions imposed on Access Persons of the Funds. Accordingly, the Code of Ethics Administration Group will refer violations to the CCO of the Trust/Adviser (or designee) for further review and action, including determination if the matter should be presented to the Ethics Oversight Committee and/or the Board of Trustees for recommended action.
The following factors will be considered when determining a fine or other disciplinary action:
● | the person's position and function (senior personnel may be held to a higher standard); |
● | the amount of the trade; |
● | whether the John Hancock Affiliated Funds hold the security and were trading the same day; |
● | whether the violation was by a family member; |
● | whether the person has had a prior violation and which policy was involved; and |
● | whether the employee self-reported the violation. |
John Hancock takes all rule violations seriously and, at least once a year, provides the Board of the John Hancock Affiliated Funds with a summary of all material violations and sanctions, significant conflicts of interest and other related issues for their review. Sanctions for violations could include (but are not limited to) fines, disgorgement, limitations on personal trading activity, suspension or termination of the Covered Person's position with John Hancock and/or a report to the appropriate regulatory authority.
You should be aware that other Securities Laws and regulations not addressed by the Code may also apply to you, depending on your role at John Hancock.
22
The CCO of the Adviser/Trust (or designee) and the Ethics Oversight Committee retain the discretion to interpret the Code’s provisions and to decide how they apply to any given situation.
Education of Employees
This Code constitutes the Code of Ethics required by Rule 17j-1 under the Investment
Company Act of 1940 and by Rule 204A-1 under the Investment Advisers Act of 1940. The
Code of Ethics Administration Group will provide a copy of the Code (and any amendments)
to each person subject to the Code. The Code of Ethics Administration Group in
coordination with the CCO or designee will also administer initial and annual training to
employees on the principles and procedures of the Code and other related policies.
Recordkeeping
The Code of Ethics Administration Group will maintain a:
● | Copy of the current Code for John Hancock and a copy of each Code of Ethics in effect at any time within the past five years. |
● | Record of any violation of the Code, and of any action taken as a result of the violation, for six years. |
● | Copy of each report made by an Access Person under the Code, for six years (the first two years in a readily accessible place). |
● | Record of all persons, currently or within the past five years, who are or were, required to make reports under the Code. This record will also indicate who was responsible for reviewing these reports. |
● | Record of any decision, and the reasons supporting the decision, to approve the acquisition by an Access Level I Persons of IPOs or private placement securities, for six years. |
● | Record of any decision, and the reasons supporting the decision, to approve the acquisition by an Access Person of the John Hancock Advisers IPOs or private placement securities, for six years. |
Other Important Policies
The John Hancock Affiliated Funds have additional policies or may rely on certain MFC policies. Summary excerpts of such policies are listed below please review each full policy for additional details.
MFC Code of Business Conduct & Ethics (All Covered Employees)
The MFC Code of Business Conduct and Ethics (the MFC Code) provides standards for ethical behavior when representing the Company and when dealing with employees, field representatives, customers, investors, external suppliers, competitors, government authorities and the public.
The MFC Code applies to directors, officers and employees of MFC, its subsidiaries and controlled affiliates. Sales representatives and third-party business associates are also expected to abide by all applicable provisions of the MFC Code and adhere to the principles and values set out in the MFC Code when representing Manulife to the public or performing services for, or on behalf of, Manulife.
23
Other important issues in the MFC Code include:
● | MFC values; |
● | Ethics in workplace; |
● | Ethics in business relationships; |
● | Conflicts of Interest; |
● | Handling information; |
● | Receiving or giving of gifts, entertainment or favors; |
● | Misuse or misrepresentation of your corporate position; |
● | Disclosure of confidential or proprietary information; |
● | Disclosure of outside business activities; |
● | Antitrust activities; and |
● | Political campaign contributions and expenditures relating to public officials. |
John Hancock Conflicts of Interest Policy (All Covered Employees)
Conflicts of Interest are both inherent to the investment advisory business and also exist as a result of our unique organizational structure. The Conflicts of Interest Policy governs organizational/Adviser conflicts, rather than personal conflicts (such as outside business activities or gifts and entertainment). Our fiduciary obligation as an adviser to the Funds requires us to effectively disclose and/or manage these conflicts, which we do today through various documents and controls, and ultimately to act in the best interest of our clients and the Fund shareholders.
John Hancock Gift & Entertainment Policy (All Covered Employees)
You are subject to the Gift and Entertainment Policy for the John Hancock Advisers which is designed to prevent the appearance of an impropriety, potential conflict of interest or improper payment.
The Gift & Entertainment Policy covers many issues relating to giving and accepting of gifts and entertainment when dealing with business partners, such as:
● | Gift & Business Entertainment Limits |
● | Restrictions on Gifts & Entertainment |
● | Reporting of Gifts & Entertainment |
John Hancock Insider Trading Policy (All Covered Employees)
The antifraud provisions of the federal Securities Laws generally prohibit persons with material nonpublic information from trading on or communicating the information to others. Sanctions for violations can include civil injunctions, permanent bars from the securities industry, civil penalties up to three times the profits made or losses avoided, criminal fines and jail sentences. While Access Level I Persons are most likely to come in contact with material nonpublic information, the rules (and sanctions) in this area apply to all persons
covered under this code and extend to activities both related and unrelated to your job duties.
The John Hancock Insider Trading Policy (the Insider Trading Policy) covers a number of important issues, such as:
● |
Possession, misuse and access to material nonpublic information |
24
John Hancock Pay to Play Rule on Political Contributions (All Covered Associates)
The Pay to Play rule restricts Investment Advisers and certain employees who fall within the definition of Covered Associates from making contributions to elected officials (including incumbents, candidates, or successful candidates for an elective office of a government entity) who may be able to influence the selection of the investment adviser to manage the assets of government entities (any state or political subdivision of a state). The rule has three primary elements:
● |
A two-year prohibition on an adviser’s providing compensated investment advisory services to a government entity after a contribution has been made by the adviser or one of its covered associates; |
● |
A prohibition on the use of third-party solicitors who are not themselves regulated persons subject to pay-to-play restrictions on political contributions; and |
● |
A prohibition on bundling and other efforts by advisers to solicit political contributions to certain officials of a government entity to which the adviser is seeking to provide services. |
Sanctions for violating the rule include a prohibition from receiving compensation for providing advisory services to a fund in which such government entity’s participant-directed plan or program invests for two years thereafter, otherwise known as a “time-out” period.
John Hancock Whistleblower Policy (All Covered Employees)
The Committees of the mutual funds’ Board of Trustees investigate improprieties or suspected improprieties in the operations of the Funds and has established procedures for the confidential, anonymous submission by employees of John Hancock Investment Management, LLC and John Hancock Variable Trust Advisers, LLC. (collectively the “Advisers”) or any other provider of services to the Funds or Advisers of complaints regarding accounting, internal accounting controls, auditing matters or violations of the Securities Laws. The objective of this policy is to provide a mechanism by which complaints and concerns regarding accounting, internal accounting controls, auditing matters or violations of Securities Laws may be raised and addressed without the fear or threat of retaliation. The funds desire and expect that the employees and officers of the Advisers, or any other service provider to the funds will report any complaints or concerns they may have regarding accounting, internal accounting controls or auditing matters.
Persons may submit complaints or concerns to the attention of funds’ CCO (or designee) by sending a letter or other writing to the funds’ principal executive offices, by telephone call to or an email to the Ethics Hotline, Ethics Hotline can be reached at 1-866-294-9534, or through the Ethicspoint website at www.manulifeethics.com. The Ethics Hotline and Ethicspoint website are operated by an independent third party, which maintains the anonymity of all complaints.
25
Complaints and concerns may be made anonymously to the funds’ CCO (or designee) or the respective Committee’s Chairperson. Furthermore, nothing in this policy prohibits reporting possible violations of applicable law or regulation to any governmental agency or entity, including but not limited to the Department of Justice, the Securities and Exchange Commission, the Congress, and any agency Inspector General, or making other disclosures that are protected under the whistleblower provisions of applicable law or regulation.
Policy and Procedures Regarding Disclosure of Portfolio Holdings (All Covered Employees)
It is our policy not to disclose nonpublic information regarding Fund portfolio holdings except in the limited circumstances noted in this Policy. You can only provide nonpublic information regarding portfolio holdings to any person, including affiliated persons, on a “need to know” basis (i.e., the person receiving the information must have a legitimate business purpose for obtaining the information prior to it being publicly available and you must have a legitimate business purpose for disclosing the information in this manner). We consider nonpublic information regarding Fund portfolio holdings to be confidential and the intent of the policy and procedures is to guard against selective disclosure of such information in a manner that would not be in the best interest of Fund shareholders.
Additional Policies Outside the Code (All Covered Employees)
● |
Policy Regarding Dissemination of Mutual Fund Portfolio Information |
● |
Manulife Financial Corporation Anti-Fraud Policy |
● |
John Hancock Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) Program |
● |
Conflict of Interest Rules for Directors and Officers |
● |
John Hancock Non-Cash Compensation Policy |
26
Appendix
Definitions
Access Person:
You are an “Access Person” if you are a “Supervised Person” who has access to nonpublic information regarding any client’s purchase or sale of securities, or nonpublic information regarding the portfolio holdings of any John Hancock Affiliated Fund, or who is involved in making securities recommendations to clients, or who has access to such recommendations that are nonpublic.
Automatic Investment Plan:
Means a program in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation. An Automatic Investment Plan includes a dividend reinvestment plan.
Beneficial Ownership:
Means the opportunity, directly or indirectly, to profit or share in any profit (for loss) derived from a Reportable Securities transaction. This includes Reportable Securities held by an Access Person’s Household Family Member and Covered Securities held through certain family trusts, family custodial accounts, entities controlled by the Access Person, portfolios from which the Supervised Person may receive a performance fee, and other circumstances in which the Access Person may profit, directly or indirectly through any contract, arrangement, understanding, relationship, or otherwise, from transactions in the respective Reportable Securities, as defined further in Rule 16a-1 (a) (2) of the Securities Exchange Act of 1934.
Broad-Based Index:
For the purposed of this Code a Broad-Based Index will include the following:
● |
the S&P 100, S&P Midcap 400, S&P 500, FTSE 100, and Nikkei 225; |
● |
Direct obligations of the U. S. Government (e.g., treasury securities) |
● |
Indirect obligations of the U.S. Government with a maturity of less than 1 year (GNMA) |
● |
Commodities; |
● |
Foreign currency |
Brokerage Account:
Any of your accounts:
● |
Which have the capability to hold Reportable Securities; |
● |
Accounts of your spouse, Significant Other, minor children or family members sharing your household (together, “Household Members”); |
27
● |
Accounts in which you or your Household Members have a Beneficial Ownership; |
● |
Accounts over which you have discretion, give advice or information or have Power of Attorney (POA). |
Covered Person:
Includes all “Access Persons” as defined under Securities and Exchange Commission (SEC) Rule 17j-1 under the Investment Company Act of 1940, as amended (the “1940 Act”), and “Supervised Persons” as defined under SEC Rule 204A-1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”).
Household Family Member:
An Access Person’s spouse, Significant Other, minor children, or other family member who also shares the same household as the Access Person.
Investment Professionals:
Means a Supervised Person who are either Portfolio Managers, Analysts, and Traders.
Involuntary Issuer Transaction:
Transaction where the account owner has not determined the timing as to when the purchase or sale transaction will occur or the amount of shares purchased or sold, i.e. making changes to existing positions or asset allocations within the John Hancock retirement plans, buying or selling shares of a Reportable Security, etc.
Involuntary Issuer Transactions include:
● |
transactions which result from a corporate action applicable to all similar security holders (such as splits, tender offers, mergers, stock dividends, etc.); or |
● |
automatic dividend reinvestment and stock purchase plan acquisitions. |
Please note: any transaction that overrides the pre-set schedule or allocations must be included in a quarterly transaction report.
John Hancock Affiliated Fund:
For the purposes of this Code, a John Hancock Affiliated Fund shall include both:
● |
a “John Hancock Mutual Fund” (i.e., a 1940 Act mutual fund that is advised or subadvised by a John Hancock Adviser or by another Manulife entity); or |
● |
“John Hancock Variable Product” (i.e., contracts funded by insurance company separate accounts that use one or more portfolios of John Hancock Variable Insurance Trust). |
● |
Any other financial product or security advised or sub-advised by a John Hancock Adviser or John Hancock Insurance or another Manulife entity. |
The definition for John Hancock Affiliated Fund does not include John Hancock money market funds. A list of John Hancock Affiliated Funds can be found on PTCC.
28
John Hancock Variable Products:
Contracts funded by insurance company separate accounts that use one or more portfolios of John Hancock Variable Insurance Trust.
Managed Account:
Any account over which neither you nor a Household Family Member has direct or indirect influence or control and cannot a) suggest purchases or sales of investments to the trustee or third-party discretionary manager; b) direct purchases or sales of investments; or c) consult with the trustee or third-party discretionary manager as to the particular allocation of investments to be made in the account.
Private Placements:
Securities exempt from SEC registration under section 4(2), section 4(6) and/or rules 504–506 under the Securities Act.
Reportable Securities:
Means any note, stock, treasury stock, security future, bond, debenture, evidence of indebtedness, certificate of interest or participation in any profit-sharing agreement, collateral-trust certificate, preorganization certificate or subscription, transferable share, investment contract, voting-trust certificate, certificate of deposit for a security, fractional undivided interest in oil, gas, or other mineral rights, any put, call, straddle, option, or privilege on any security (including a certificate of deposit) or on any group or index of securities (including any interest therein or based on the value thereof), or any put, call, straddle, option, or privilege entered into on a national securities exchange relating to foreign currency, or, in general, any interest or instrument commonly known as a “security”, or any certificate of interest or participation in, temporary or interim certificate for, receipt for, guaranty of, or warrant or right to subscribe to or purchase any of the foregoing, except it should not include:
(i) Direct obligations of the Government of the United States;
(ii) Bankers' acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements;
(iii) Shares issued by money market funds;
(iv) Shares issued by open-end funds other than reportable funds; and
(v) Shares issued by unit investment trusts that are invested exclusively in one or more open-end funds, none of which are reportable funds.
29
Please note: Reportable Securities includes both John Hancock Affiliated Funds and John Hancock Variable Products.
Securities Laws:
Means the Securities Act of 1933, as amended (the “Securities Act”), the Securities Exchange Act of 1934, the Sarbanes-Oxley Act of 2002, the Investment Company Act of 1940, the Investment Advisers Act of 1940, Title V of the Gramm-Leach-Bliley Act, any rules adopted by the SEC under any of these statutes, the Bank Secrecy Act as it applies to funds and investment advisers, and any rules adopted there under by the SEC or the Department of the Treasury.
Significant Others:
Two people who (1) share the same primary residence; (2) share living expenses; and (3) are in a committed relationship and intend to remain in the relationship indefinitely.
Supervised Person:
Is defined by the Advisers Act to mean a partner, officer, director (or other person occupying a similar status or performing similar functions) or employee, as well as any other person who provides advice on behalf of the adviser and is subject to the adviser’s supervision and control. However, in reliance on the Prudential no-action letter, John Hancock does not treat as a “Supervised Employee” any of its “non-advisory personnel”, as defined below.
In reliance on the Prudential no-action letter, John Hancock treats as an “Advisory Person” any “Supervised Employee” who is involved, directly, or indirectly, in John Hancock Financial Services investment advisory activities, as well as any “Supervised Employee” who is an Access Person. John Hancock treats as “non-advisory personnel”, and does not treat as a Supervised Person, those individuals who have no involvement, directly or indirectly, in John Hancock investment advisory activities, and who are not Access Persons.
30
Preferred Brokers List
Preferred Brokers List While employed by John Hancock, you must maintain your Brokerage Accounts at one of the preferred brokers approved by John Hancock. The following are the preferred brokers:
Ameriprise | Sanders Morris Harris | |
Bank of Oklahoma | Scottrade | |
Bank of Texas | Stifel | |
Barclays Wealth Management | TD Ameritrade | |
Brave Warrior Advisors | T. Rowe Price | |
Charles Schwab | Thompson Davis & Co. | |
Chase Investment Services | UBS | |
Citigroup | US Trust | |
Constellation Wealth Management | Vanguard | |
Credit Suisse | Robert W. Baird & Co. | |
DB Alex Brown | ||
Edward Jones | ||
E*Trade | ||
Fidelity | ||
First Republic | ||
Goldman Sachs Wealth Management | ||
HSBC Private Bank | ||
Interactive Brokers | ||
JB Were | ||
JP Morgan Private Bank | ||
JP Morgan Securities | ||
Lincoln Financial | ||
Merrill Lynch & Bank of America | ||
Morgan Stanley Private Wealth | ||
Morgan Stanley Smith Barney | ||
Northern Trust | ||
Northern Trust Institutional | ||
Oppenheimer & Co. | ||
OptionsXpress | ||
Pershing Advisor Solutions | ||
Piper Jaffray | ||
Raymond James | ||
Revolution Capital |
31
Compliance Contacts
Entity | Chief Compliance Officer |
John Hancock Investment Management, LLC | Frank Knox – 617-663-2430 |
John Hancock Variable Trust Advisers, LLC | Frank Knox |
Each open-end and closed-end fund advised by a John Hancock Adviser | Frank Knox |
John Hancock Investment Management Distributors, LLC | Michael Mahoney - 617-663-3021 |
John Hancock Distributors, LLC | Michael Mahoney |
Code of Ethics Contacts | |
Code of Ethics Administration Group | INVDIVCodeofEthics@manulife. com |
32
CERTIFICATION
I, Andrew Arnott, certify that:
1. I have reviewed this report on Form N-CSR of the John Hancock Investment Trust (the “registrant”);
2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;
3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;
4. The registrant's other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:
(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;
(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;
(c) Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and
(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and
5. The registrant's other certifying officer and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing the equivalent functions):
(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and
(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting.
Date: May 12, 2020
/s/ Andrew Arnott
__________________________
Andrew Arnott
President
CERTIFICATION
I, Charles A. Rizzo, certify that:
1. I have reviewed this report on Form N-CSR of the John Hancock Investment Trust (the “registrant”);
2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;
3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;
4. The registrant's other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:
(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;
(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;
(c) Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and
(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and
5. The registrant's other certifying officer and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing the equivalent functions):
(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and
(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting.
Date: May 12, 2020
/s/ Charles A. Rizzo
__________________________
Charles A. Rizzo
Chief Financial Officer
Certification Pursuant to 18 U.S.C. Section 1350, as Adopted Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002
In connection with the attached Report of John Hancock Investment Trust (the “registrant”) on Form N-CSR to be filed with the Securities and Exchange Commission (the "Report"), each of the undersigned officers of the registrant does hereby certify that, to the best of such officer's knowledge:
1. The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and
2. The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the registrant as of, and for, the periods presented in the Report.
/s/ Andrew Arnott
_______________________
Andrew Arnott
President
Dated: May 12, 2020
/s/ Charles A. Rizzo
_______________________
Charles A. Rizzo
Chief Financial Officer
Dated: May 12, 2020
A signed original of this written statement, required by Section 906, has been provided to the registrant and will be retained by the registrant and furnished to the Securities and Exchange Commission or its staff upon request.
JOHN HANCOCK FUNDS1
NOMINATING AND GOVERNANCE COMMITTEE CHARTER
Overall Role and Responsibility
The Nominating and Governance Committee (the “Committee”) of each of the Trusts shall (1) make determinations and recommendations to the Board of Trustees (the “Board”) regarding issues related to (a) the composition of the Board and (b) corporate governance matters applicable to the Trustees who are not “interested persons” as defined in the Investment Company Act of 1940, as amended (the “1940 Act”), of any of the Trusts, or of any Fund’s investment adviser, subadviser or principal underwriter and who are “independent” as defined in the rules of the New York Stock Exchange (“NYSE”) (the “Independent Trustees”) and (2) discharge such additional duties, responsibilities and functions as are delegated to it from time to time.
Membership
The Nominating and Governance Committee (the “Committee”) shall be composed of all of the Independent Trustees of the Board. One member of the Committee shall be appointed by the Board as Chair of the Committee. The chair shall be responsible for leadership of the Committee, including scheduling meetings or reviewing and approving the schedule for them, preparing agendas or reviewing and approving them before meetings, presiding over meetings of the Committee and making reports to the full Board, as appropriate.
Structure, Operations and Governance
Meetings and Actions by Written Consent. The Committee shall meet as often as required or as the Committee deems appropriate, with or without management present. Meetings may be called and notice given by the Committee chair or a majority of the members of the Committee. Members may attend meetings in person or by telephone. The Committee may act by written consent to the extent permitted by law and the Funds’ governing documents. The Committee shall report to the Board on any significant action it takes not later than the next following Board meeting.
Required Vote and Quorum. The affirmative vote of a majority of the members of the Committee participating in any meeting of the Committee at which a quorum is present is necessary for the adoption of any resolution. At least a majority of the Committee members present at the meeting in person or by telephone shall constitute a quorum for the transaction of business.
1 “John Hancock Funds” includes each trust and series as may be amended from time to time (each individually, a “Trust,” and collectively, the “Trusts,” and each series thereof, a “Portfolio” or “Fund,” and collectively, the “Portfolios” or “Funds”).
1
Delegation to Subcommittees. The Committee may delegate any portion of its authority to a subcommittee of one or more members.
Appropriate Resources and Authority. The Committee shall have the resources and authority appropriate to discharge its responsibilities, including the authority to retain special counsel and other advisers, experts or consultants, at the Funds’ expense, as it determines necessary or appropriate to carry out its duties and responsibilities. In addition, the Committee shall have direct access to such officers of and service providers to the Funds as it deems desirable.
Review of Charter. The Committee Charter shall be approved by at least a majority of the Independent Trustees of the Trust. The Committee shall review and assess the adequacy of this Charter periodically and, where necessary or as it deems desirable, will recommend changes to the Board for its approval. The Board may amend this Charter at any time in response to recommendations from the Committee or on its own motion.
Executive Sessions. The Committee may meet privately and may invite non-members to attend such meetings. The Committee may meet with representatives of the Investment Management Services department of the Funds’ advisers, internal legal counsel of the Funds’ advisers, members of the John Hancock Funds Risk & Investment Operations Committee (the “RIO Committee”) and with representatives of the Funds’ service providers, including the subadvisers, to discuss matters that relate to the areas for which the Committee has responsibility.
Specific Duties and Responsibilities
The Committee shall have the following duties and powers, to be exercised at such times and in such manner as the Committee shall determine:
1. | Except where a Trust is legally required to nominate individuals recommended by another, to identify individuals qualified to serve as Independent Trustees of the Trusts, and to consider and recommend to the full Board nominations of individuals to serve as Trustees. | |
2. | To consider, as it deems necessary or appropriate, the criteria for persons to fill existing or newly created Trustee vacancies. The Committee shall use the criteria and principles set forth in Annex A to guide its Trustee selection process. | |
3. | To consider and recommend changes to the Board regarding the size, structure, and composition of the Board. | |
4. | To evaluate, from time to time, and determine changes to the retirement policies for the Independent Trustees, as appropriate. | |
5. | To periodically review the Board’s committee structure and, in collaboration with the Chairs of the various Committees, the charters of the Board’s committees, and recommend to the Board of Trustees changes to the committee structure and charters as it deems appropriate. |
2
6. | To retain and terminate any firm(s) to be used to identify or evaluate or assist in identifying or evaluating potential Independent Board nominees, subject to the Board’s sole authority to approve the firm’s fees and other retention terms. | |
7. | To consider and determine the amount of compensation to be paid by the Trusts to the Independent Trustees, including the compensation of the Chair of the Board or any Vice-Chair of the Board and of Committee Chairs, and to address compensation-related matters. The Chair of the Board has been granted the authority to approve special compensation to Independent Trustees in recognition of any significant amount of additional time and service to the Trusts provided by them, subject to ratification of any such special compensation by the Committee at the next regular meeting of the Committee. | |
8. | To coordinate and administer an annual self-evaluation of the Board, which will include, at a minimum, a review of its effectiveness in overseeing the number of Funds in the Fund complex and the effectiveness of its committee structure. | |
9. | To review the Board Governance Procedures and recommend to the Board of Trustees changes to the Procedures as the Committee deems appropriate. | |
10. | To report its activities to the full Board and to make such recommendations with respect to the matters described above and other matters as the Committee may deem necessary or appropriate. |
Additional Responsibilities
The Committee will also perform other tasks assigned to it from time to time by the Chair of the Board or by the Board, and will report findings and recommendations to the Board, as appropriate.
Last revised:
3
ANNEX A
The Committee may take into account a wide variety of factors in considering Trustee candidates, including (but not limited to) the criteria set forth below. The Committee may determine that a candidate who does not satisfy these criteria in one or more respects should nevertheless be considered as a nominee if the Committee finds that the criteria satisfied by the candidate and the candidate’s other qualifications demonstrate the appropriate level of fitness to serve.
General Criteria
1. | Nominees should have a reputation for integrity, honesty and adherence to high ethical standards, and such other personal characteristics as a capacity for leadership and the ability to work well with others. |
2. | Nominees should have business, professional, academic, financial, accounting or other experience and qualifications which demonstrate that they will make a valuable contribution as Trustees. |
3. | Nominees should have a commitment to understand the Funds, and the responsibilities of a trustee/director of an investment company and to regularly attend and participate in meetings of the Board and its committees. |
4. | Nominees should have the ability to understand the sometimes conflicting interests of the various constituencies of the Funds, including shareholders and the investment adviser, and to act in the interests of all shareholders. |
5. | Nominees should not have, nor appear to have, a conflict of interest that would impair their ability to represent the interests of all the shareholders and to fulfill the responsibilities of a trustee. |
6. | Nominees should have experience on corporate or other institutional bodies having oversight responsibilities. |
It is the intent of the Committee that at least one Independent Trustee be an “audit committee financial expert” as that term is defined in Item 3 of Form N-CSR.
Application of Criteria to Current Trustees
The re-nomination of current Trustees should not be viewed as automatic, but should be based on continuing qualification under the criteria set forth above based on, among other things, the current Trustee’s contribution to the Board and any committee on which he or she serves.
Review of Nominations
1. | The Committee believes that it is in the best interests of each Trust and its shareholders to obtain highly-qualified candidates to serve as members of the Board. |
2. | In nominating candidates who would be Independent Trustees, the Committee believes that no particular qualities or skills nor any specific minimum qualifications or disqualifications are controlling or paramount. The Committee shall take into consideration any such factors as it deems appropriate; however, the appropriate mix of skills, expertise and attributes needed to maintain an effective board are sought in the applicant pool as part of every search the Board undertakes for new trustees, including but not limited to the diversity of thought, as well as of gender, race, ethnic background and geographic origin. These factors may also include (but are not limited to) the person’s character, integrity, judgment, skill and experience with investment companies and other organizations of comparable purpose, complexity and size and subject to similar legal restrictions and oversight; the interplay of the candidate’s experience with the experience of other Board members; and the extent to which the candidate would be a desirable addition to the Board and any Committees thereof. Other factors that the Committee may take into consideration include a person’s availability and commitment to attend meetings and perform his or her responsibilities; whether or not the person has or had any relationships that might impair or appear to impair his or her independence, such as any business, financial or family relationships with Fund management, the investment adviser and/or any subadviser of the Funds, as applicable, Fund service providers, or their affiliates or with Fund shareholders. The Committee will strive to achieve a group that reflects a diversity of experiences in respect of industries, professions and other experiences, and that is diversified as to thought, gender, race, ethnic background and geographic origin. |
3. | While the Committee is solely responsible for the selection and recommendation to the Board of Independent Trustee candidates, the Committee may consider nominees recommended by any source, including shareholders, management, legal counsel and Board members, as it deems appropriate. The Committee may retain a professional search firm or a consultant to assist the Committee in a search for a qualified candidate. Any recommendations from shareholders shall be directed to the Secretary of the relevant Trust at such address as is set forth in the Trust’s disclosure documents. Recommendations from management may be submitted to the Committee Chair. All recommendations shall include all information relating to such person that is required to be disclosed in solicitations of proxies for the election of Board members and as specified in the relevant Trust’s By-Laws, and must be accompanied by a written consent of the proposed candidate to stand for election if nominated for the Board and to serve if elected by shareholders. |
4. | Any shareholder nomination must be submitted in compliance with all of the pertinent provisions of Rule 14a-8 under the Securities Exchange Act of 1934 in order to be considered by the Committee. In evaluating a nominee recommended by a shareholder, the Committee, in addition to the criteria discussed above, may consider the objectives of the shareholder in submitting that nomination and whether such objectives are consistent with the interests of all shareholders. If the Board determines to include a shareholder’s candidate among the slate of its designated nominees, the candidate’s name will be placed on the Trust’s proxy card. If the Board determines not to include such candidate among its designated nominees, and the shareholder has satisfied the requirements of Rule 14a-8, the shareholder’s candidate will be treated as a nominee of the shareholder who originally nominated the candidate. In that case, the candidate will not be named on the proxy card distributed with the Trust’s proxy statement. |
5. | As long as a current Independent Trustee continues, in the opinion of the Committee, to satisfy the criteria listed above, the Committee generally would favor the re-nomination of a current Trustee rather than a new candidate. Consequently, while the Committee will consider nominees recommended by shareholders to serve as trustees, the Committee may only act upon such recommendations if there is a vacancy on the Board, or the Committee determines that the selection of a new or additional Trustee is in the best interests of the relevant Trust. In the event that a vacancy arises or a change in Board membership is determined to be advisable, the Committee will, in addition to any shareholder recommendations, consider candidates identified by other means as discussed in this Annex A. |
6. | With respect to candidates for Independent Trustee, a biography of each candidate shall be acquired and shall be reviewed by counsel to the Independent Trustees and counsel to the Trust to determine the candidate’s eligibility to serve as an Independent Trustee. |
7. | The Committee may from time to time establish specific requirements and/or additional factors to be considered for Independent Trustee candidates as it deems necessary or appropriate. |
8. | After its consideration of relevant factors, the Committee shall present its recommendation(s) to the full Board for its consideration. |