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 161 106 510



2021 Annual General Meeting

Thursday 11 November 2021

NAOS Emerging Opportunities Company Limited advises that its Annual General Meeting (AGM) will be held at 10.00 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 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 the core investments and potential catalysts.

We hope you will be able to join us.

Register Now

FY21 Final Dividend Dates

Tuesday 5 October 2021
Record Date: 
Wednesday 6 October 2021
Last Date for DRP Election:
Thursday 7 October 2021
Payment Date:
Monday 25 October 2021


1 Month
1 Year
2 Years (P.A.)
5 Years (P.A.)
7 Years (P.A.)
Inception (P.A.)
(Total Return)
NCC Investment Portfolio Performance*
S&P/ASX Small Ordinaries Accumulation Index 
Performance Relative to Benchmark 

* Investment Portfolio Performance is post all operating expenses, before fees, interest, taxes, 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 February 2013. Returns compounded for periods greater than 12 months.



Independent Chairman
View Biography

SARAH Williams

Independent Director
View Biography


View Biography


View Biography
“The Company has now declared a total of 57.50 cents per share in fully franked dividends since listing in 2013.”


Independent Chairman



Independent Chairman

Dear fellow shareholders, 

On behalf of the Board, it is with pleasure I present the NAOS Emerging 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. It is very pleasing to see our shareholder numbers continue to grow year on year, and I welcome the additional 300 shareholders who joined the register during the financial year.

For the financial year ended 30 June 2021, the Company achieved a record after-tax profit of $20.66 million. One of the objectives of the Company is to deliver a sustainable, growing stream of dividends to shareholders franked to the maximum extent possible. I am pleased to announce the Board has declared a fully franked final dividend of 3.75 cents per share. Together with the fully franked interim dividend of 3.75 cents per share, this brings the fully franked full-year dividend to 7.50 cents per share, which represents a 3.4% increase on the prior year. This represents a 7.25% net yield based on the 30 June 2021 share price and brings total fully franked dividends declared since inception to 57.50 cents per share.

Australia’s economy has rebounded from the retreat last year and has now achieved net growth from January 2020. FY21 was one of the strongest years on record for domestic equities, although towards the end of the financial year, US inflation concerns and rising bond yields did cause some volatility in financial markets. We expect the volatility to continue over the short term. As we move into FY22, the Board believes that the companies held in the NCC portfolio offer appealing long-term, risk-adjusted value and are confident that through the NAOS investment team maintaining a disciplined approach, in line with the NAOS investment philosophy, shareholders can look forward to further outperformance over the longer term.

The NCC Investment Portfolio returned a record financial year return of +48.34%, significantly outperforming the benchmark S&P/ASX Small Ordinaries Accumulation Index, which returned +33.23%.

The pre-tax Net Tangible Asset (NTA) backing per share of the Company increased from $0.90 to $1.23 over the financial year, with positive performance of the investment portfolio increasing NTA per share by 44.83 cents over the year. During the year, 7.25 cents per share was paid to shareholders in fully franked dividends, and management fees and interest expense on the convertible notes decreased the NTA by 1.51 cents per share and 0.34 cents per share respectively. Corporate tax of 0.78 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. The dilutionary impact of the exercise of bonus options by shareholders decreased the NTA by 2.27 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 NCC for FY21 was +39.26%, 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 NCC share price increased from $0.795 to $1.035 over the course of the financial year, 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 dividends, franked to the maximum extent possible, while maintaining an adequate profit reserve balance. The Company has now declared a total of 57.50 cents per share in fully franked dividends since listing in 2013.
  • 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 the shareholders and continued to increase their holdings over the course of the year through both the exercise of their bonus options and participation in the DRP, and now hold a cumulative 5.06 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 all current and prospective shareholders on the database, which totals over 11,000 subscribers.

In March 2021, the Company issued $23.0 million of listed, convertible notes (NCC Notes). The NCC Notes provide investors with a listed exposure to a fixed interest rate yield of 4.50% per annum, and the possibility to benefit from 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 2026. The issue of the convertible notes facilitated an increase in the overall size of the investment portfolio without diluting existing NCC shareholders. The proceeds of the issue were invested by the Investment Manager in a number of opportunities that arose during the year.

The 1-for-4 NCC bonus options that were issued in June 2019 expired on 29 June 2021. During this period, 12.56 million options, or 84% of the total bonus options issued, were converted into ordinary shares at an exercise price of $1.02, raising $12.8 million of additional capital. The Board of Directors were delighted with the large number of shareholders who supported the Company by choosing to exercise their bonus options. Along with the NCC Convertible Notes, the bonus options were a considered way to allow the Company to grow without placing undue pressure on the short-term performance and dividend reserves of the Company.

The Board remains committed to managing the capital base of the Company, using the most appropriate structure for maximising potential shareholder return. The Board believes that growing the size of the Company to between $125 million and $150 million is optimal. This size not only allows the Investment Manager to maximise performance by accessing meaningful positions in quality companies, but also scales the Company to an appropriate size that lowers the total expenses and costs for all shareholders.

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 NCC Investment Portfolio recorded its strongest year ever, returning +48.34% for the financial year ended 30 June 2021, outperforming the benchmark S&P/ASX Small Ordinaries Accumulation Index (XSOAI), which returned +33.23% in one of the strongest financial years on record for domestic equities. This brings Investment Portfolio performance since inception to +13.44% p.a., significantly ahead of the XSOAI return of +7.58% p.a. over the past 8 years and 5 months. 


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.


Experience Co. (ASX: EXP)

EXP finished this financial year with a total shareholder return 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, to date the business has come through COVID-19 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 its 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

Contango Asset Management (ASX: CGA)

CGA, a business that has spent the past few years transitioning, showed some positive momentum in its third year as a distribution business, which led to its share price increasing by over +240% in FY21. CGA is the sole distributor of the WCM Investment Management (WCM) products to retail investors in Australia. As a group, WCM has >$100 billion in Funds Under Management (FUM), which is of a similar scale to the hugely successful Magellan Financial Group (ASX: MFG).

Over the past two years, CGA has been laying the foundations to ensure that the WCM investment product suite has the best chance of success and the ability to reach a point of scale within the Australian market. At the start of FY21, CGA had close to $500 million in FUM associated with WCM products. Over the past 12 months, this has grown to just under $1 billion. Driving this growth has been unique products, such as the WCMQ Exchange Traded Product (ETP) and the WCM Global Small Cap offering.

As many investors would know, the global equity product landscape within the Australian funds management industry has largely been dominated by two groups: Magellan Financial Group (ASX: MFG) and Platinum Asset Management (ASX: PTM). Over the next few years, we expect to see a continued diversification of retail portfolios away from domestic equities and property, with increased weightings towards international equities. This should be a tailwind for CGA.

The WCM investment philosophy is centred around a company’s culture and the trajectory of a company’s competitive moat. This strategy has proven successful, with WCM’s historical performance across its various strategies comparable (and in some cases superior) to its Australian-based global equity peers.

Along with its investment philosophy and the industry tailwind, in our view, another advantage CGA has is that WCM is a large, globally recognised business that offers very little in the way of business risk compared to boutique competitors. We believe that CGA has a realistic opportunity of growing the level of its WCM-managed FUM to $2–3 billion in the short term.

Wingara AG (ASX: WNR)

From time to time, emerging company investments are made with the best of intentions but due to circumstances beyond our control (or belief), the investment thesis does not play out as anticipated.

FY21 was a year to forget for WNR. WNR’s share price finished the year down by approximately –50%, which in our view was the result of various factors, including poor management, lack of quality and accuracy with information provided to the market, risk and governance issues, and finally, macro factors that exacerbated all the above.

Looking back at our investment thesis and the mistakes we made, we believe the reliance we had on the alignment of the founder/managing director, who initially owned ~20% of WNR, was too great to offset the other risks surrounding the business.

Throughout FY21, WNR conducted a highly dilutive equity raise where funds were not used on the stated strategic items. In addition, the founder/managing director left the business and sold his entire shareholding. More recently a thorough review of the business was completed, which uncovered further shortcomings and led to events such as a significant writedown of inventory.

In the case of WNR, we believe the commonly used saying “never waste a good crisis” applies in varying degrees. A new board of directors has joined the company, with potentially further changes to come. A new managing director has been appointed who, pleasingly, possesses sound agricultural experience both from a supplier and a buyer standpoint. In addition, the company strategy has been simplified to focus on the hay-processing business, which has also resulted in an upskill of certain key staff.

In the case of WNR, we are pleased FY21 is behind us but are of the opinion that WNR is exiting FY21 in a much-improved state. We do not know what the future holds for WNR but we firmly believe that with the sound, hard asset backing and a niche position in the supply of oaten hay products both domestically and internationally, there is a solid base that can be capitalised upon by the right board and management team.


Enero Group (ASX: EGG)

EGG has been one of our most successful investments, not only for NCC but for the NAOS group as a whole. Since the NCC initial public offering in February 2013, EGG has been a position within the portfolio. At that time EGG was a holding company for a number of advertising and public relations businesses based in Australia, the UK, and to a lesser extent, North America. The business had approximately $100 million in revenue and was just break-even, albeit with a reasonable net cash balance sheet.

Today EGG has grown its revenue base to approximately $150 million, but most importantly, the EBITDA margins have grown to approximately 30%. From a valuation perspective you could reasonably argue that EGG shares remain undervalued based on today’s earnings. We would agree with this assertion but this, of course, is based on the assumption that the current level of earnings will be maintained.

We may well be cautious given our long-term understanding of the company but it is fair to say that historically, the level of variability of earnings in each of the business units has been significant. As with many services businesses, their biggest competitive advantage is based around company culture and people. When successful, this drives the momentum that brings new customer wins, which in turn drives growth.

Over the past 12 months at EGG we have seen the appointment of a new CEO, CFO, Head of Strategy, Head of Hotwire PR and a new chair. Change can be healthy for a business, but such a level of change can also present a significant risk that can often be difficult to mitigate. EGG itself went through this experience many years ago.

When you consider the above alongside potential headwinds, such as moving to a higher tax rate next year as tax losses are exhausted, the end of earnouts for Hotwire PR and Orchard Communications, and a hyper-competitive industry backdrop, we believe the risk could outweigh the potential returns and as such, we have exited the majority of our holding in EGG. We hope that EGG can continue to grow as it has done so successfully over the past five years, but we fear that the margin for error is small.

Source: FactSet

Gentrack Group Limited (ASX: GTK)

Technology-type companies have been some of the best-performing companies since COVID-19 as many of them have been benefactors of the expedited transition to a more digital world. With the recent rotation out of higher growth, technology-type investments into more value-type investments, NCC has invested in a new core investment in what we believe to be a value-type software company called Gentrack Group Ltd (ASX: GTK).

GTK is a technology services provider to utilities and airport operators and was established in the 1980s when New Zealand deregulated its power markets. Today, GTK has approximately 50 core customers across three main geographies: New Zealand, Australia and the UK, who are supported by over 300 internal engineering staff at GTK.

More recently GTK has undergone significant change, with a completely new executive team from the CEO down, as well as a new chair. From an earnings standpoint, the business has also experienced a significant amount of change due to internal execution issues, as well as external issues – such as regulation change in the UK for utilities providers – which has affected some of their customer base.

The reasons we are attracted to the GTK business are relatively simple. It is a business we have followed for over five years as it has a high-quality customer base. Over 75% of its revenue base is recurring in nature and, in theory, is growing. Many of the new executive team have worked together previously and have a good track record in running technology-focused businesses that solve the problems of very large organisations through innovative solutions.

Under the new team, GTK has reintroduced a move to fully expensing all research and development spend, which we view very favourably, the cash-flow generation has largely been sound, and its balance sheet stands in a healthy net cash position.

As is the case with a majority of our long-term investments, this particular investment will likely not be a smooth ride and does carry a degree of risk. Even so, we believe the risk is more than outweighed by the potential return. The returns will come if management can continue to grow the sticky revenue base, consistently grow margins, and reinvest the subsequent increased free cash flows into further improving their software, as well as inorganic opportunities that fit the strategy. If this can be achieved, the valuation multiple uplift applied to GTK could potentially be significant.


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 NCC 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. Some are benefiting from strong short- to medium-term industry trends, e.g. Big River Industries (ASX: BRI) and Saunders International (ASX: SND), while others, e.g. BSA Limited (ASX: BSA), need to capitalise on potential opportunities and increase their scale in a realistic timeframe, both organically and via acquisitions.

For NCC, there could be numerous catalysts that may have a material effect on the portfolio return in FY22. The key and most realistic catalysts in our view would be large contract wins for Saunders International (SND), BSA Limited (BSA) executing on plan to significantly increase its businesses’ scale, and COG Financial Services (COG) providing greater transparency around the potential of the group to grow its insurance-broking earnings and the current trajectory of this earnings stream, which in our view would command a higher valuation multiple.

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 NCC 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 NCC. 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 

“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.”


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 $400m 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 Emerging 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.