Key Dates
Year at a Glance
Board of Directors
Chairman’s Letter
Investment Manager’s Review
Investing with NAOS Asset Management
Our Values
Our Investment Beliefs
Our Investment Process
Our ESG Process
Companies Making a Difference
Our Team
Shareholder Communications
NAOS Giving Back
Corporate Governance Statement

Annual Report 2021

ACN 169 448 837



2021 Annual General Meeting

Thursday 11 November 2021

NAOS Ex-50 Opportunities Company Limited advises that its Annual General Meeting (AGM) will be held at 11.15 am (AEDT) on Thursday 11 November 2021 as a virtual meeting.

Further details relating to the AGM will be advised in the Notice of Meeting to be sent to all shareholders and released to the ASX immediately after dispatch.

In accordance with the ASX Listing Rules, valid nominations for the position of Director are required to be lodged at the registered office of the Company no later than 5.00 pm (AEST) 16 September 2021.

Q1 FY22 Investor Update Webinar

Tuesday 26 October 2021

Please add the NAOS Q1 FY22 quarterly webinar to your calendar, when the investment team will provide you with an update on our Listed Investment Companies (LICs). The discussion will include an insight into our investment philosophy and process, notable market events, and an analysis of some of our core investments and potential catalysts.

We hope you will be able to join us.

Register Now


Tuesday 31 August 2021
Record Date: 
Wednesday 1 September 2021
Last Date for DRP Election:
Thursday 2 September 2021
Payment Date:
Monday 20 September 2021


1 Month
1 Year
3 Years (P.A.)
5 Years (P.A.)
6 Years (P.A.)
Inception (P.A.)
Inception (Total Return)
NAC Investment Portfolio Performance*
S&P/ASX 300 Industrials Accumulation Index
Performance Relative to Benchmark 

* Investment Portfolio Performance is post all operating expenses, before fees, taxes, interest, initial IPO commissions and all subsequent capital raising costs. Performance has not been grossed up for franking credits received by shareholders. Since inception (P.A. and Total Return) includes part performance for the month of November 2014. Returns compounded for periods greater than 12 months.



Independent Chairman
View Biography

SARAH Williams

Independent Director
View Biography


View Biography


View Biography
“The FY21 full-year dividend of 5.75 cents per share represents a 9.5% increase on the prior year.”

David Rickards

Independent Chairman



Independent Chairman

Dear fellow shareholders, 

On behalf of the Board, it is with pleasure I present the NAOS Ex-50 Opportunities Company Limited Annual Report for the financial year ended 30 June 2021. I would like to thank all shareholders for your continued support and welcome all new shareholders who joined the Company during the 2021 financial year.

For the year ending 30 June 2021, the Company achieved a record after-tax profit of $19.37 million. I am pleased to report that for the financial year ended 30 June 2021, the NAC Investment Portfolio returned a record financial year return of +63.36%, significantly outperforming the benchmark S&P/ASX300 Industrials Accumulation Index, which returned +27.93%.

Australia’s economy has rebounded from the 2020 retreat and has now grown to a level larger than January 2020. More recently, US inflation concerns have caused some volatility in financial markets and we expect this may continue over the short term. When markets are volatile, it is important to remember that they move in cycles, and volatility is a natural part of any economic cycle. The Board is confident that through the NAOS investment team maintaining a disciplined approach in line with the NAOS investment philosophy, shareholders can expect further outperformance over the longer term.

One of the objectives of the Company is to deliver a sustainable growing stream of quarterly dividends to shareholders, franked to the maximum extent possible. I am pleased to announce the Board has declared a fully franked final quarterly dividend of 1.55 cents per share for the year ended 30 June 2021. This brings the FY21 full-year dividend to 5.75 cents per share, representing an increase of 9.5% on the prior year. The profit reserve balance at year end was $24.8 million, or 56 cents per share, and since listing, the Company has now declared an aggregate 33.25 cents per share of fully franked dividends.

The pre-tax Net Tangible Asset (NTA) backing per share of the Company increased from $1.06 to $1.59 over the financial year, with positive performance of the investment portfolio increasing NTA per share by 71.79 cents over the year. During the year, 5.40 cents per share was paid to shareholders in fully franked dividends, performance fees and management fees decreased the NTA by 7.16 cents per share and 2.89 cents per share respectively, and interest expense on convertible notes totalled 1.31 cents per share. Corporate tax of 3.14 cents per share was also paid during the year. The franking credits attached to these corporate tax payments are available to be distributed to shareholders through fully franked dividends. As the buyback of shares by the Company at a discount is accretive to NTA per share, this was also a positive contributor to the Company's NTA during the financial year, adding a further 1.85 cents per share.

Total Shareholder Return (TSR) measures the change in the share price together with dividends paid over the financial year, assuming dividends are reinvested. The TSR for NAC for FY21 was +57.25%, which was reflective of the strong performance of the investment portfolio. This measure does not include the benefit of franking credits received by shareholders through franked dividends.

While the share price closed the financial year at $1.18, the Board acknowledges the current discount to NTA and remains committed to addressing and closing the discount to NTA through a range of initiatives including:

  • Dividends – The Company will continue to focus on delivering a growing stream of quarterly dividends franked to the maximum extent possible, while maintaining an adequate profit reserve balance. The Company has now declared a total of 33.25 cents per share in fully franked dividends since its inception.
  • On-market share buyback – Over the course of the financial year, 3.62 million shares were bought back and the Company has now bought back 8.97 million shares, or 17.1% of shares on issue since the buyback commenced in June 2019. The Board renewed the on-market buyback facility for a further 12 months in June 2021, as the buyback of shares at a discount is accretive to NTA and thus of benefit to all shareholders and intends to continue an active buyback in FY22 should a significant discount to NTA persist.
  • Dividend Reinvestment Plan (DRP) – For those shareholders who participate in the DRP, it is important to note the Company did not issue shares at a discount to NTA but acquired shares on market to ensure this capital management activity was completed without any potential dilution for existing shareholders.
  • Alignment – The Board has a strong alignment with our shareholders and continued to increase their holdings over the course of the year through both the purchase of shares on market and participation in the DRP, and now hold a cumulative 8.12 million shares.
  • Shareholder communications – The Company maintained a focus on a high standard of marketing and communications so that all current and prospective shareholders have a clear understanding of the NAOS offering. Quarterly investor webinars are delivered to all shareholders along with regular email shareholder updates, which are sent to over 11,000 subscribers.

The Board remains committed to managing the capital base of the Company, using the most appropriate structure for maximising potential shareholder return and scaling the Company to an appropriate size that minimises the expenses and costs for each dollar invested. With this in mind, the Company issued $17.5 million of listed, convertible notes (NAC Notes) in November 2020. The NAC Notes provide investors with a listed exposure to a fixed interest rate of 5.5%, and the possibility to benefit from an appreciation in the price of the Company’s shares above a conversion price of $1.15, through an optional conversion into ordinary shares at any time until 30 September 2025. The issue of the convertible notes provided the ability to increase the overall size of the investment portfolio without diluting existing NAC shareholders, with the proceeds of the issue invested by the Investment Manager in a number of opportunities that arose during the year. The NAC Notes are listed on the ASX under the code ASX: NACGA.

During the financial year, a total of 718,000 of the 1-for-2 NAC bonus options issued in March 2020 were converted to ordinary shares. The NAC bonus options are listed on the ASX under the code ASX: NACOA, with an exercise price of $1.03 and an expiry date of 31 March 2023. The Board believes that along with the NAC Notes, the bonus options are a measured way to allow the Company to grow over the next two years without placing undue pressure on the short-term performance and dividend reserves of the Company.

On behalf of the Board of Directors, I would like to congratulate the Investment Manager on their strong investment performance throughout FY21 and thank them for their continued efforts and dedication throughout the year.

David Rickards OAM
Independent Chairman

19 August 2021

Investment Manager's Review


Managing Director and Chief Investment Officer, NAOS Asset Management Limited

Dear fellow shareholders, 

The NAC Investment Portfolio recorded its strongest year ever, returning +63.36% for the financial year ended 30 June 2021, outperforming the benchmark S&P/ASX 300 Industrials Accumulation Index (XKIAI), which returned +27.93% in one of the strongest financial years on record for domestic equities. This brings Investment Portfolio performance since inception to +17.72% p.a., significantly ahead of the XKIAI return of +8.53% p.a. over the same time period.


I strongly believe that 12 months ago very few investors would have made even the slightest suggestion that the ASX-200 Index would post 11 months of gains in the financial year, with only September 2020 producing the single negative monthly return. I am a firm believer that no matter what edge any successful investor may believe they possess, at certain stages they will simply be the beneficiary of good fortune. In my opinion, FY21 was one of those years when the wind was at many investors’ backs. Even so, I firmly believe that the patience we have shown as an investment team and remaining true to our investment philosophy, has played the most critical part in delivering the strong performance over FY21.

Today, we live in a world where interest rates have never been lower. Across the globe, central banks have flooded markets with liquidity through numerous initiatives, and federal governments have resorted to fiscal stimulus initiatives to drive investment over the short and medium term. This has been very apparent in Australia.

This backdrop has created an excellent environment for asset prices, which includes listed companies. The nuance to the above is that the type of company that the market perceives to benefit over the long term has shifted. As such, we have seen a sharp rebound in valuations for businesses that for the prior 3–4 years have generally been overlooked by many investors. Industries in which these businesses operate include financials, building materials, consumer discretionary and construction/engineering services to name a few.

All NAOS portfolios were a beneficiary to some degree of the events mentioned above in FY21. In saying that, I am a firm believer in the NAOS investment philosophy of investing with a long-term focus in industrial-type businesses that:

  • operate in growing industries;
  • have a clear and increasing moat;
  • are run by proven and aligned leaders;
  • generate excellent free cash flow; and
  • are disciplined and proven allocators of capital.


Objective Corporation (ASX: OCL)

OCL continued its very strong business momentum during FY21, which pleasingly translated into significant share price appreciation. OCL’s share price increased over 65% and saw it reach a market capitalisation of almost $1.40 billion. Interestingly, even with such a market capitalisation we believe that OCL is very much under-owned and under-researched by the wider investment community. A contributing factor to this being the substantial alignment of the founder/CEO, who still owns approximately 70% of the business.

OCL started FY21 with a material announcement of its acquisition of regulatory technology (regtech) software company Itree. Its largest acquisition to date, Itree develops cloud-based software that is used by government agencies and regulators in Australia. The software that Itree provides to its client base aims to solve the key challenges for many governments and regulatory agencies dealing with sensitive data relating to productivity, process management, efficiency and digital transformation.

Itree has a similar target market to the OCL suite of products and in theory the addition of the new products could be used to cross sell to their respective client bases. This is especially true for OCL, which has the much larger and more diverse client base.

As FY21 progressed, it became more apparent that OCL would continue to be a long-term beneficiary of its customer base moving to the digitisation of data and process. Many of the agencies that OCL has within its client base manage an enormous amount of data. As a result of being a government-related and/or regulated entity, this data must be processed, managed and stored in a specific way to maintain its integrity.

COVID-19 has highlighted the shortcomings of existing processes within many organisations and required them to quickly adapt to their employees using new digital technologies, such as Microsoft Teams. The process of change and its associated challenges to overcome these existing shortcomings has been significantly accelerated.

To illustrate this with a commonplace example, let us say a workplace is now using Microsoft Teams. How can they ensure that all files shared and conversations held on this communications platform are appropriately captured for long-term retention or for business intellectual property reasons? How can they ensure that the conversations on a Microsoft Teams meeting are consistent with internal company policies surrounding the privacy of information, and who can view what information and why?

These are just two examples of any number of issues around workflow, process, regulation and information governance for which OCL is able to provide cloud-based solutions. If OCL can continue to solve such issues for its current client base and potentially expand into larger global markets, then its growth prospects should remain healthy for a very long time.

Experience Co. (ASX: EXP)

EXP finished this financial year with a total shareholder return (TSR) of over +140% in a demand environment that could be described as subdued at best. Historically, EXP is a business that has heavily relied upon international tourists to drive both its Australian and New Zealand skydiving operations and its North Queensland cruise businesses. With international borders closed for the entire year, EXP has been completely shut down from an international tourism point of view.

Despite this backdrop we saw EXP benefit from a number of factors, which we believe assisted in driving the re-rating of EXP’s valuation throughout FY21. This has occurred even though the company’s earnings profile is yet to return to anywhere near historical levels.

Firstly, the business has come through COVID-19 to date with a close to net cash balance sheet and was one of very few ASX-listed travel companies not to raise capital throughout the pandemic. Secondly, EXP’s asset base has been rationalised and arguably better suits the company’s strategy going forward.

Furthermore, the business has substantially reduced its reliance on third-party distribution deals, which we believe will lead to significant margin improvement, as many third-party booking platforms can charge fees between 10–30% of the ticket price. Finally, EXP made its first bolt-on acquisition under its new board and management team. EXP acquired two luxury walking businesses in Australia that will form the foundation of a third pillar to their operations, serving domestic travellers in the Premium Adventure markets of Australia and New Zealand.

Notwithstanding the valuation re-rating in FY21, we believe the future is extremely bright for EXP. Coming out of COVID-19, the next two years should hopefully provide evidence of the high-quality nature of the underlying business. There are also numerous organic and inorganic growth opportunities in front of EXP. Organic opportunities such as the construction of the Great Barrier Reef Dreamtime Island pontoon, which is due to be operational in CY22, and inorganic opportunities such as the recent acquisitions, to further develop their Premium Adventure operations.

Source: FactSet

Eureka Group (ASX: EGH)

EGH has been somewhat of an unassuming investment within the NAC Investment Portfolio when mentioned to current or potential NAC shareholders. However, when reviewing its FY21 performance, the EGH share price increased by over 90% before accounting for dividends. This resulted in EGH contributing >9% to NAC’s Investment Portfolio performance for the year.

We would argue that without a doubt EGH operates the simplest business model across all NAOS investment portfolios. Despite this, it continues to be a business that is poorly understood by the market and owned by just a few major investors. FY21 was not an overly eventful year for EGH but in our view, this predictability and simplicity is part of the reason its share price has continued to re-rate throughout the year.

FY21 has hopefully marked the end of the rationalisation of the business under its current management team. This is evidenced by the fact that the majority of the remaining non-core assets on the EGH balance sheet have now been divested. These sale proceeds have been recycled into the core business to acquire three existing villages and the purchase of land. This land purchase will become the company’s second greenfield development project and is scheduled to occur after their first development project, the expansion of their Wynnum asset, is completed.

Looking ahead, we believe the market is anticipating that EGH may become a capital-hungry business as it seeks to grow rapidly via acquisition. While this may prove to be correct, it may also not be the case. We believe the potential for EGH to become a self-funding business that can grow organically at 10–20% p.a. without the need for additional outside equity, is also very real. This model has proven to be very successful for Lifestyle Communities (ASX: LIC) (albeit LIC also has a deferred management fee component to its model), which has seen its share price rise from circa $3 to over $15 in the space of just five years.

The demand for EGH’s products has never been stronger. In our view, COVID-19 has highlighted how the seniors population will want to defer entering an aged-care facility for as long as possible while also remaining part of a community. The independent seniors industry remains highly fragmented, with little competition from pure rental offerings. If EGH can continue to execute in a predictable manner that drives moderate earnings growth over time, then EGH’s current capitalisation rate used to value its tangible assets of >10% is likely to decline significantly. This capitalisation rate could well move towards a 5–6% level, which is where comparable property asset verticals (being child care and self-storage units) are currently valued. If this were to occur, it would result in a significant uplift to EGH’s NTA.


MNF Group (ASX: MNF)

MNF Group has been a core investment for NAC for a number of years and at times one of the largest holdings in the investment portfolio. Over the course of the latter part of FY21, we made the decision to significantly reduce our holding due to a number of factors that we felt did not fit with our investment philosophy, including the following:

  • In our opinion there has been a history of poor capital allocation, which has included significant investments in new business segments such as Pennytel (~$3 million EBITDA p.a. investment) and acquisitions such as Conference Call International. One of these was sold for a nominal amount and the other is now part of an ongoing strategic review.
  • A $50-million placement was also completed approximately two years ago. In our view, these placement funds have not been used to execute on any significant growth strategy to date.
  • The potential for significant investment in further expansion into South-East Asia, which may depress earnings for ~24 months. There has been little clarity provided on what the expected return would be on this investment.
  • The potential for further competition in the very lucrative Australian market, which we believe has seen very little in the form of quality competition for the last 3–5 years. The Australian market has been MNF’s cash engine.

MNF remains a very high-quality business with an excellent customer base and global growth potential. With a share price that has largely been flat over the last approximately four years, in our view, the level of investment that MNF has made has not generated a sufficient return. The fifth year may well be the year that this changes and we hope it does so, as MNF has the potential to be a market leader over time.

360 Capital REIT (ASX: TOT)

TOT made a return to the portfolio after being a larger holding approximately 24 months ago. In today’s low-rate environment, it is difficult to get exposure to hard assets at a discount to their value and even more difficult to get exposure to quality property assets at a discount to their value. With TOT we believe we have gained this exposure.

The last released Net Tangible Asset backing per security (NTA) of TOT was circa $1.14, which was generally made up of property and property-related investments. Over the past 12 months, the TOT management team has made a clear and defined effort to return TOT to its original roots of a ‘pure play’ trust. The core focus of the trust is on property investments that can generate a strong total return over time. We firmly believe that as this strategy gains traction and if the returns are in line with expectation, this will lead to a significant closing of the TOT discount to NTA as well as more predictable distributions.

The other key part of our investment thesis is the strategic holding that TOT has acquired in Irongate Property (ASX: IAP), which we believe may represent >60% of TOT’s NTA. IAP has two property portfolios, the first of which is focused on metro office assets and the second of which is focused on quasi-metro industrial assets.

At IAP’s last released valuation, the office assets were valued using a capitalisation rate of 6.12% and the industrial assets were valued using a capitalisation rate of 5.83%. Over the past 6–12 months, we have seen significant demand for industrial assets, with large portfolios transacting on capitalisation rates of well below 4%. The office assets are potentially harder to argue as undervalued; however, with a solid rental base and demand for metro office assets potentially increasing in a post-COVID-19 environment, an argument can be made for a moderate decrease in the capitalisation rate. Taking these factors into account, it is not hard to envisage a potential valuation for IAP that is significantly higher than the last released NTA of $1.43.


It is impossible to provide an accurate prediction as to how a portfolio of investments will perform over a 12-month period. Even so, I believe it is important to provide a general outlook to our fellow shareholders, detailing our level of comfort with the current NAC investments, their potential, and any catalysts that may occur in FY22.

We believe the current portfolio has a significant amount of unrealised value and the current trajectory for a clear majority of these businesses is where it needs to be. Even with the recent share price performance, some of the most notable NAC investments may well be entering a year that could define their business for the next 3–5 years at least.

Such examples include EXP with regards to how they can scale their business and how efficient their business is coming out of the COVID-19 environment. OCL would be another clear example as it has done a remarkable job within the Australian and even New Zealand markets, but whether it can repeat this at scale in other major markets remains unanswered. A further example is Limited (ASX: UBN), which has finally started to build a business that has a clear competitive advantage. Its software now solves customers’ clearly understood and defined needs, but whether Urbanise can do this profitably and at the required scale following the implementation of its deal with PEXA remains to be seen.

FY21 was an excellent year from a pure return point of view, but we are under no illusions and believe that you are only as good as your next year’s returns. We believe the NAC Investment Portfolio has a compelling balance between risk management (protection against permanent capital loss) and long-term returns, despite its highly concentrated portfolio.

As always, the entire team at NAOS would like to thank all our fellow shareholders for continuing to be shareholders in NAC. We also welcome all new shareholders who joined the register in FY21.

If you have any queries, do not hesitate to speak directly with me or any member of the team.

We look forward to continuing to provide you with regular updates throughout FY22.

Kind Regards,

Sebastian Evans
Managing Director and Chief Investment Officer
NAOS Asset Management Limited 

“Even with the recent share price performance, some of the most notable NAC investments may well be entering a year that could define their business for the next 3–5 years at least.”


Managing Director and Chief Investment Officer, NAOS Asset Management Limited


NAOS Asset Management is a specialist fund manager providing genuine long-term, concentrated exposure to Australian undervalued emerging companies with an industrial focus.

With a proven performance track record, NAOS seeks to protect investor capital whilst providing a sustainable growing stream of dividends franked to the maximum extent possible, and long-term investment performance above the relative benchmark index.

NAOS launched its first LIC in 2013 with 400 shareholders. Today, NAOS manages approximately $400 million across three Listed Investment Company vehicles for close to 8,000 shareholders.


Encourage independent thinking

Rather than follow the crowd, we prefer to pave the way with innovation and provide a better outcome for our stakeholders. We have a disciplined investment process and do not get caught up in the hype and noise of the market.

Do one thing and do it really, really well

At NAOS we focus on providing genuine long-term, concentrated exposure to emerging Australian industrial companies – and we strive to be the best at this.

Tell it like it is

At NAOS, we are honest and transparent. We continue to exist due to the earned trust of our shareholders.

Have the right people in the right environment

Each NAOS employee has been specifically chosen for their unique ability, proven experience and willingness to learn. At NAOS, we have created an inclusive work culture and one that supports all our employees.

Be invested and aligned

As NAOS Directors and employees, we have a significant interest in NAOS’ investment strategies. This means we are invested alongside our shareholders, creating a strong alignment of interests. In addition, NAOS Asset Management Limited is majority owned by employees and Directors.

Have a long-term perspective

We believe in investing in businesses where the earnings today are not a fair reflection of what the same business may earn over the longer term. Prior to investing in a business, we ask ourselves: do we want to own this business forever?

Act responsibly

We are responsible for investing our fellow shareholders’ funds and we do not take this responsibility lightly. NAOS seeks to always act responsibly and diligently in all matters – from our investment choices through to our shareholder communications.

Be an owner

NAOS employees strive to make NAOS a success by taking ownership of their tasks and responsibilities. Most employees are also owners of NAOS.

Give back

As a company, we have committed to the Pledge 1% global movement; that is, to pledge 1% of our revenue, time and knowledge to movements and missions that matter. We want to make a difference and aim to contribute to economic, social and environmental change.

Our Investment Beliefs


We believe in investing in businesses where the earnings today are not a fair reflection of what the same business will earn over the longer term. Ultimately, this earnings growth can be driven by many factors including revenue growth, margin growth, cost cutting, acquisitions and even share buybacks. The end result is earnings growth over a long-term investment horizon, even if the business was perceived to be a value-type business at the time of the initial investment.


Excessive diversification, or holding too many investments, may be detrimental to overall portfolio performance. We believe it is better to approach each investment decision with conviction. In our view, to balance risk and performance most favourably, the ideal number of quality companies in each portfolio would generally be 0 to 20.


As investors who are willing to maintain perspective by taking a patient and disciplined approach, we believe we will be rewarded over the long term. If our investment thesis holds true, we persist. Many of our core investments have been held for three or more years, where management execution has been consistent and the value proposition is still apparent.


We believe in backing people who are proven and aligned with their shareholders. One of the most fundamental factors consistent across the majority of company success stories in our investment universe is a high-quality, proven management team with ‘skin in the game’. NAOS Directors and employees are significant holders of shares on issue across our strategies, so the interests of our shareholders are well aligned with our own.


This means we are not forced holders of stocks with large index weightings that we are not convinced are attractive investment propositions. We actively manage each investment to ensure the best outcome for our shareholders and only invest in companies that we believe will provide excellent, sustainable long-term returns.


With the big four banks making up a large proportion of total domestic equity holdings for the SMSF investor group, many Australian investors are at risk of being overexposed to one sector and may be missing out on opportunities to invest in quality companies in industries such as media, advertising, agriculture or building materials. Australian listed industrial companies outside the ASX 50 are our core focus and we believe the LICs we manage provide pure access to these companies, which may be lesser known by the broader investment community.


We believe in taking advantage of inefficient markets. The perceived risk associated with low liquidity (or difficulty buying or selling large positions) combined with investor short-termism presents an opportunity to act based purely on the long-term value proposition where the majority may lose patience and move on. Illiquidity is often caused by aligned founders or management having significant holdings in a company. NAOS benefits from a closed-end LIC structure, which means we do not suffer ‘redemption risk’ and we can focus on finding quality, undervalued businesses regardless of their liquidity profile.


As an investment manager, NAOS recognises and accepts its duty to act responsibly and in the best interests of shareholders. We believe that a high standard of business conduct and a responsible approach to environmental, social and governance (ESG) factors is associated with a sustainable business model over the longer term that benefits not only shareholders but also the broader economy. NAOS is a signatory to the UN-supported Principles for Responsible Investment (PRI) and is guided by these principles in incorporating ESG into its investment practices.


NAOS are not activist investors; due to our investment approach it is common for NAOS to establish a substantial shareholding in a company with a long-term (5 years+) investment horizon.

This approach allows us to supportively engage with the boards and/or management teams of our portfolio holdings.

Examples of constructive engagement where the NAOS investment team look to add value:

  • Growth capital if/when required
  • Messaging and communications
  • Capital management decisions
  • Company strategy
  • Board composition

Our Investment Process



Objective Corporation Limited (ASX: OCL)

OCL is an Australian developer and provider of software and related IT services to regulated industries.

OCL completed the NAOS ESG questionnaire during FY21.

6+ years

NAOS first invested


OCL’s market capitalisation
as at 30 June 2021

How Is OCL Making a Difference?

The following examples were provided by Objective Corporation.


  • Objective Corporation has implemented a Formal Environmental Policy, advising employees, clients and suppliers of their legal obligations regarding energy and water use, emissions and waste reduction.
  • All Objective Corporation’s primary offices have programs in place that monitor and report on energy use for each premises.
  • Objective Corporation has implemented a waste management policy with >50% generated waste being recycled. 


  • Objective Corporation has achieved Great Place to Work (GPTW) recognition through independent assessment of company policies, practices and programs that contribute to workplace culture. Objective Corporation offers professional development and leadership courses to all staff as well as making free counselling services available through its Objective Cares program to foster staff wellbeing.
  • Objective Corporation participates in initiatives to celebrate equality and/ or raise awareness of important issues, such as International Women’s Day and Men’s Health Week.
  • Community participation and sponsorship, such as the support for women in sport at the Eastlake Football Club and support for vulnerable children and families at the Manawatū Jets basketball team in New Zealand.


  • Should a Board vacancy or consideration for a new Board member exist, the Board will apply skills-based selection criteria to Board appointments. Diversity and complementarity of skillsets are considered. The Board will seek advice from an external consultant where necessary. 
  • All new Directors will take part in an induction program to educate new Directors on the Company’s business. Directors are given access to opportunities to update and enhance their skills and knowledge. 
  • The CEO and CFO are significant stockholders in Objective Corporation.
  • Objective Corporation has a Balance and Belonging Employee Policy, with the goal to avoid mono-cultural teams. Objective is committed to avoiding discrimination and hiring strictly based on skills.
  • Women now represent 28.6% of the workforce and 18.8% of management positions. Objective Corporation is firmly committed to Equal Employment Opportunities (EEO) in all aspects of its people management practices, policies and procedures.

Areas for improvement:

  • Implement a community engagement or development programs.
  • Ensure future inclusion of female participation on the Objective Corporation Board.
  • Include ESG factors in the formal business Mission Statement.
“Our values guide how we treat ourselves, each other, and our customers. We respect each other. We do as we say. We do the right thing.” 

(Excerpt from Objective Corporation’s stated company values)

“As an outdoor adventure and tourism company, the Group is committed to protecting and minimising the impact on the environment, promoting environmental best practice operations and to achieving maximum sustainability.” 

(Excerpt from Experience Co.’s Corporate Governance Statement)

Experience Co. (ASX: EXP) 

EXP is an adventure tourism company.

Experience Co. completed the NAOS ESG questionnaire during FY21.


NAOS Core Investment


EXP market capitalisation
as at 30 June 2021

How Is EXP Making a Difference?

The following examples were provided by Experience Co.


  • The group has established procedures whereby compliance with environmental regulations is managed.
  • The group is accredited with several environmental organisations, such as the Australian-based Planet Safe Partnership and Advanced Ecotourism via Ecotourism Australia.
  • Company-wide initiatives have been implemented to reduce the Group’s environmental impact, e.g. aircraft fleet upgrades focusing on minimisation of noise and carbon emissions.
  • The group plans to have more of its boats powered by renewables.
  • All USBs and plastic bags have been removed from skydiving drop zones.
  • Specialised pilot training is being delivered to ensure flight plans include fuel efficiency and noise reduction measures.
  • All official branded merchandise is created by AS Colour, a company that takes pride in its Responsible Sourcing Program. 


  • Initiatives for social value include the CEO Skydive for mental health, which raises funds for Black Dog Institute.
  • A skydiving partnership has been established with Stellar Experiences to provide experiences and outings for young people living with disability.
  • EXP is working with the Mars Family Foundation with a focus on reef regeneration.
  • Dreamtime cruise boats are now supporting indigenous rangers and local Indigenous communities.
  • EXP is currently building a new pontoon on the Great Barrier Reef, which will be powered by renewable energy.


A formal governance statement is in place and is adhered to.

  • Diversity is encouraged and the group recognises the value of diverse perspectives.
  • Female board participation is 20%.
  • Alignment of the board is ~ 33%.
  • The EXP Board is majority independent.
  • The board has a remuneration and nomination committee that identifies suitable candidates with appropriate skills, experience, expertise and diversity to ensure the board is able to discharge its mandate effectively.

Areas for improvement:

  • Implement a waste management policy.
  • Offer carbon offset to customers for Skydive Australia to be implemented in the future.
  • Provide disability access for all businesses. 

Our Team

Sebastian Evans

Chief Investment Officer and Managing Director

Sebastian is a Director of NAOS Emerging Opportunities Company Limited (ASX: NCC), NAOS Small Cap Opportunities Company Limited (ASX: NSC), NAOS Ex-50 Opportunities Company Limited (ASX: NAC) and has held the positions of Chief Investment Officer (CIO) and Managing Director of NAOS Asset Management Limited, the Investment Manager, since 2010. Sebastian is the CIO across all investment strategies. 

Sebastian holds a Master of Applied Finance (MAppFin) majoring in investment management as well as a Bachelor of Commerce majoring in finance and international business, a Graduate Diploma in Management from the Australian Graduate School of Management (AGSM) and a Diploma in Financial Services.

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Sebastian Evans

Chief Investment Officer and Managing Director

Robert Miller

Portfolio Manager

Robert joined NAOS in September 2009 as an investment analyst. Robert has been a portfolio manager since November 2014 and is currently Portfolio Manager across all NAOS LICs: NAOS Emerging Opportunities Company Limited (ASX: NCC), NAOS Small Cap Opportunities Company Limited (ASX: NSC) and NAOS Ex-50 Opportunities Company Limited (ASX: NAC).

Robert holds a Bachelor of Business from the University of Technology, Sydney. Robert also holds a Master of Applied Finance from the Financial Services Institute of Australasia/Kaplan.

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Robert Miller

Portfolio Manager

Brendan York

Portfolio Manager

Brendan joined NAOS in July 2021 as a Portfolio Manager. Brendan has over 19 years’ finance, accounting and M&A experience. Most recently Brendan had a 15-year career with ASX-listed marketing services business Enero Group Limited in finance roles and ultimately as CFO and Company Secretary for a 9-year period. Prior to that, Brendan spent four years at KPMG.

Brendan is a chartered accountant and holds a Bachelor of Business Administration and a Bachelor of Commerce from Macquarie University.

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Brendan York

Portfolio Manager

Jared Tilley

Senior Investment Analyst

Jared joined NAOS in April 2021 as a Senior Investment Analyst. Jared has over 14 years’ financial services experience. Most recently Jared was an investment analyst at Contact Asset Management and prior to that spent nine years at Colonial First State.

Jared holds a Bachelor of Commerce majoring in accounting and finance, from the University of Notre Dame, Sydney, and is a CFA Charterholder.

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Jared Tilley

Senior Investment Analyst

Nelson de Mestre

Associate Analyst

Nelson joined NAOS as an associate analyst in July 2020. He has a Bachelor of Commerce from the University of Sydney and is in the process of completing an honours program.

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Nelson de Mestre

Associate Analyst

Julie Coventry

ESG Officer

Julie joined NAOS in November 2012 as Compliance Officer and in January 2021, commenced the role of ESG Officer. 

Prior to joining NAOS, Julie worked within the compliance and performance teams at BZW Investment Management, Commonwealth Bank, Colonial First State and QBE. 

Julie holds a Bachelor of Business majoring in finance and economics from the University of Technology, Sydney, and she also holds a Graduate Diploma in Applied Finance and Investment from the Securities Institute of Australia.

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Julie Coventry

ESG Officer

Richard Preedy

Chief Financial and Operating Officer

Richard joined NAOS in October 2015 as Chief Financial and Operating Officer. Richard has over 14 years’ financial services experience in the UK and Australia, beginning his career in London with Deloitte & Touche before relocating to Sydney in 2013.

Richard holds a BA (Hons) in Business Management from the University of Sheffield, is a fully qualified Chartered Accountant and is a member of the Governance Institute of Australia.

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Richard Preedy

Chief Financial and Operating Officer

Rajiv Sharma

Head of Legal & Compliance

Rajiv is Head of Legal and Compliance at NAOS and holds a Bachelor of Laws (First Class Honours), a Bachelor of Business (accounting major) and a Graduate Diploma in Legal Practice from the University of Technology, Sydney. 

Rajiv has over 11 years’ experience, having most recently held senior legal roles at Custom Fleet, part of Element Fleet Management Group (TSX: EFN) and Magellan Financial Group (ASX: MFG). He has also previously worked at law firms Johnson Winter & Slattery and Clayton Utz. 

Rajiv is a member of the Law Society of New South Wales, an Associate of the Governance Institute of Australia and is admitted to the Supreme Court of New South Wales and the High Court of Australia.

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Rajiv Sharma

Head of Legal & Compliance

Angela Zammit

Marketing & Communications Manager

Angela joined NAOS in May 2020 in the capacity of Marketing and Communications Manager.

Prior to joining NAOS, Angela held marketing roles for companies in both Australia and the UK, including SAI Global, American Express, Citibank, and Arete Marketing.

Angela holds a Bachelor of Communications majoring in advertising and marketing from the University of Canberra.

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Angela Zammit

Marketing & Communications Manager

Shareholder Communications

NAOS Asset Management is committed to keeping all shareholders up to date. We endeavour to produce timely updates and relevant communications throughout the financial year. We also welcome shareholder feedback, so please email any feedback or suggestions to

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NAOS Giving Back

To be caretakers of the next generation we must actively support positive change. Supporting our commitment to ESG issues, NAOS Asset Management (the management company) donates 1% of recurring revenue to the community and the environment.


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Corporate Governance Statement

The Board of NAOS Ex-50 Opportunities Company Limited is committed to achieving and demonstrating the highest standards of corporate governance. As such, the Company has adopted what it believes to be appropriate corporate governance policies and practices having regard to its size and the nature of its activities.

The Board has adopted the ASX Corporate Governance Principles and Recommendations, which are complemented by the Company’s core principles of honesty and integrity. The corporate governance policies and practices adopted by the Board are outlined in the Corporate Governance Section.