March 2016 Enhanced disclosure on costs At Vanguard we believe in being transparent with investors. That means clearly describing everything we do, from fund objectives to the charges you pay. And because costs are one of the few things you can control, we think it’s particularly important for you to be able to make fair comparisons on cost. The United Kingdom’s Investment Association (IA) has recommended what managers of UK-authorised funds should disclose when setting out their charges for investors. We’ve followed the IA’s recommendations to disclose the costs and charges of our UK-authorised funds. We’ve also chosen to provide the same information for a group of our Ireland-domiciled funds that are widely available in the UK. The table overleaf displays all of this data. Pages three and four describe what each column means, so you can understand the cost of each element. Some guidance Apples and apples We expect most providers to comply with the IA’s recommended practice, at least for their UK-authorised funds. This is good news for investors. However, some of these figures can be calculated in a variety of ways, and different firms may legitimately use different methods. We clearly describe how we’ve calculated the figures in the table. If you’re going to make comparisons, we’d recommend that you ask other providers how they’ve calculated their figures to make sure you’re comparing like with like. What about other charges? We’ve included a “pre-set dilution levy / SDRT charge” column in the table. Ask other providers about any dilution levy, stamp duty reserve tax (SDRT) charge or other costs you might pay in addition to what they’ve disclosed in their version of this table. It just doesn’t add up Please don’t try to add the columns to arrive at a “total” because you may be double-counting some of the charges. Costs paid by the Fund Charges paid by investors Portfolio Transaction Costs Fund Entry charge (% of investment1) Pre set dilution levy (% of investment1) Exit charge (% of investment1) Stamp duty Ongoing Broker and other Charges Figure (OCF) commissions transfer taxes (% of (% of average (% of average Net Asset Net Asset average Net Value3) Value3)4 Asset Value3) Estimated dealing spread (% of average Net Asset Value3) Stamp duty reserve tax (% of average Net Asset Value3) IA Sector Domicile Vanguard FTSE U.K. Equity Income Index U.K. Equity Income UK 0.00 0.402 0.00 0.22 0.02 0.43 0.04 0.435 Vanguard FTSE Developed Europe ex-U.K.Equity Index Fund Europe (Excluding U.K) UK 0.00 0.00 0.00 0.12 0.02 0.02 0.04 0.00 Vanguard FTSE Developed World ex-U.K.Equity Index Fund Global Growth UK 0.00 0.00 0.00 0.15 0.01 0.00 0.11 0.00 Vanguard U.S. Equity Index North America UK 0.00 0.00 0.00 0.10 0.00 0.00 0.00 0.00 Vanguard FTSE U.K. All Share Index Unit Trust U.K.All Companies UK 0.00 0.202 0.00 0.08 0.00 0.06 0.05 0.06 Vanguard Global Small-Cap Index Global Growth Ireland 0.00 0.00 0.00 0.38 0.01 0.01 0.27 0.01 Vanguard Japan Stock Index Japan Ireland 0.00 0.00 0.00 0.23 0.01 0.00 0.16 0.00 Vanguard Pacific ex-Japan Stock Index Asia Pacific ex Japan Ireland 0.00 0.00 0.00 0.23 0.01 0.02 0.19 0.00 Vanguard Emerging Markets Stock Index Global Emerging Markets Ireland 0.00 0.00 0.00 0.27 0.02 0.04 0.13 0.00 Vanguard SRI European Stock Fund Europe Inc U.K. Ireland 0.00 0.00 0.00 0.30 0.01 0.05 0.04 0.04 Vanguard SRI Global Stock Fund Fixed Income Global Ireland 0.00 0.00 0.00 0.35 0.01 0.02 0.10 0.01 Vanguard U.K. Inflation Linked Gilt Index U.K. Gilts UK 0.00 0.00 0.00 0.15 0.00 0.00 0.34 0.00 Vanguard U.K. Long Duration Gilt Index U.K. Gilts UK 0.00 0.00 0.00 0.15 0.00 0.00 0.18 0.00 Vanguard U.K. Government Bond Index U.K. Gilts Ireland 0.00 0.00 0.00 0.15 0.00 0.00 0.12 0.00 Vanguard U.K. Investment Grade Bond Index £ Corporate Bond Ireland 0.00 0.50 0.00 0.15 0.00 0.00 0.84 0.00 Vanguard Global Bond Index Global Bonds Ireland 0.00 0.20 0.00 0.15 0.00 0.00 0.24 0.00 Vanguard U.K. Short-Term Investment Grade Bond Index Fund £ Corporate Bond Ireland 0.00 0.30 0.00 0.15 0.00 0.00 0.48 0.00 Euro Government Bond Index Fund Ireland 0.00 0.00 0.00 0.25 0.00 0.00 0.12 0.00 Euro Investment Grade Bond Index Fund Ireland 0.00 0.30 0.00 0.30 0.00 0.00 0.42 0.00 Japan Government Bond Index Fund Ireland 0.00 0.00 0.00 0.25 0.00 0.00 0.10 0.00 US Investment Grade Credit Index Fund Ireland 0.00 0.50 0.00 0.30 0.00 0.00 0.58 0.00 US Government Bond Index Fund Ireland 0.00 0.00 0.00 0.25 0.00 0.00 0.02 0.00 Equity Global Short Term Bond Index Fund Multi Asset Global Bonds Ireland 0.00 0.20 0.00 0.15 0.00 0.00 0.12 0.00 Vanguard LifeStrategy® 20% Equity Fund6 Mixed Investment 0-35% Shares UK 0.00 0.00 0.00 0.24 N/A N/A 0.00 N/A Vanguard LifeStrategy® 40% Equity Fund6 Mixed Investment Shares 40-85% Shares UK 0.00 0.00 0.00 0.24 N/A N/A 0.00 N/A Vanguard LifeStrategy® 60% Equity Fund6 Mixed Investment Shares 40-85% Shares UK 0.00 0.00 0.00 0.24 N/A N/A 0.00 N/A Vanguard LifeStrategy® 80% Equity Fund6 Mixed Investment Shares 40-85% Shares UK 0.00 0.00 0.00 0.24 N/A N/A 0.00 N/A Vanguard LifeStrategy® 100% Equity Fund6 Global UK 0.00 0.00 0.00 0.24 N/A N/A 0.00 N/A 1 We impose a pre-set dilution levy or SDRT charge on some of our funds to make sure investors bear the cost of their own activity in the funds. See overleaf for a fuller description of these charges. 2 This is an SDRT charge. There is no pre-set dilution levy for this fund. 3 Net Asset Value (NAV) is the total value of the fund’s assets less its accrued liabilities. 4 Unless stated in footnote 5, this column shows the stamp duty and other transfer taxes incurred by each fund as a result of purchases of securities because of: (a) subscriptions into the funds; and (b) day-to-day fund management activity. 5This is the figure for SDRT attributable to day-to-day fund management. It has been calculated from the total SDRT paid by the fund using the ratio of the total positive net cash flow into the relevant fund over the past three years (or period since launch if shorter) as a proportion of total underlying share purchases in the funds. 6 Vanguard LifeStrategy ® funds charges are 0.00. However, the underlying funds will incur costs / charges, which is disclosed for the respective funds elsewhere in the table. Charges explained An entry charge may be imposed by a fund provider when you enter a fund. Vanguard funds don’t have entry charges as defined by the IA. However, we do impose what we call a “pre-set dilution levy” (PDL) for some funds. For other funds we impose a UK stamp duty reserve tax (SDRT) charge. For very large investments, we may also charge an “anti-dilution levy”(ADL). This is because we believe that all investors should bear the cost of their own activity in the funds. Our PDLs and ADLs aim to ensure that existing fund holders don’t pay the costs involved in investing incoming monies. These charges are paid into the relevant funds; they’re not retained by Vanguard. PDLs vary from fund to fund and tend to reduce as a fund grows. We impose an SDRT charge for all subscriptions into UK-authorised funds investing in UK shares. The purpose of this charge is to reimburse the funds for the SDRT they pay in investing new monies in UK shares. To ensure transparency, we’ve shown our PDLs/SDRT charges as a separate column in the table. Please note that many companies charge levies in addition to their entry charges, but they’re not always clearly visible. We keep our PDLs and SDRT charges under review and look to lower them whenever we can. A PDL, ADL or SDRT charge is the only Vanguard charge you pay when you buy Vanguard funds. You might, of course, also separately pay fees to your adviser for the service he or she provides; and to a platform for administering your investment. Exit charges are typically designed to cover the cost of selling your investments when you leave a fund. We don’t impose exit charges. Ongoing charges cover the actual day-to-day costs of running a fund. In the past, the fund industry used the term “annual management charge” (AMC). However, the AMC doesn’t always give you a true picture of what you’re paying – there are sometimes other charges not included in the AMC that aren’t immediately obvious: custodian, audit and legal fees, for example. This is one reason why AMC was gradually superseded by “total expense ratio” (TER) of a fund, which usually included the AMC and those additional charges mentioned above. But even so, the definitions of AMC and TER can be vague. In some cases, the total expense ratio has turned out not to be as “total” as it seemed. For this reason, regulators are now suggesting fund providers publish an “ongoing charges” figure (OCF) to provide the most complete picture possible of all of the running costs of a fund. At Vanguard, this change is relatively straightforward because AMC = TER = ongoing charges figure. We’ve honed our systems and processes over the years in a bid to maximise efficiency. This means that our ongoing charges are lower than the industry norm. Moreover, we’re always looking for ways to operate more efficiently, and we’ll look to reduce our ongoing charges further wherever we can. Some funds charge performance fees based on their achievement of certain pre-defined performance targets. The calculations behind these fees can be complex and we believe that they can lead to a lack of transparency. That’s one reason why Vanguard funds don’t have performance fees. Portfolio transaction costs are the costs we incur in buying and selling securities in a fund. Comparing portfolio transaction costs between funds can be misleading because they don’t always reduce returns. For example, if a manager incurred transaction costs in buying shares that subsequently performed strongly, the net impact of the dealing could be positive. Moreover, transaction costs also vary over time, from country to country and depending on the types of assets in which a fund invests. We’ve split portfolio transaction costs into three parts in the table: (1) broker commission, (2) estimated dealing spread, (3) stamp duty and other transfer taxes. How is it calculated? Ongoing charges figure We’ve shown the ongoing charges figure from the latest Key Investor Information Document of the relevant fund. This is based on the actual fund expenses for the latest financial year of the relevant fund, unless the fund doesn’t have a full financial year’s trading history. It includes charges for investment management, custody, fund accounting, audit, compliance, transfer agency, trustee and tax reporting. Broker commissions, stamp duty and other transfer taxes These figures show the three-year average of the commissions and taxes paid as a proportion of the relevant fund’s average NAV (unless the fund does not have three years’ trading history, in which case we’ve used a since-launch figure). Because the funds have grown during this period, most of the current figures are lower than the three-year averages. Estimated dealing spread For all funds other than the Japan Government Bond Index Fund, the estimated dealing spread figures in the table are based on current market data gathered from independent sources at the end of April 2014. The figure for the Japan Government Bond Index Fund is based on internal estimates by the Vanguard portfolio management team responsible for the management of the fund. Broker commissions are the fees paid to brokers when we buy or sell shares on behalf of the funds. As such, they’re driven partly by cash flows into and out of the funds. Commissions tend to be higher for active equity funds that deal frequently in pursuit of outperformance. Because our funds are passively managed to track an index, their broker commissions tend to be very low. Estimated dealing spread is the difference between the quoted market prices for buying and selling the securities held in the funds. For bonds, the spread also incorporates any broker commissions paid, while for equities these commissions are paid separately. The scale of the Vanguard Group, Inc., the volume of deals that it generates globally and the efficiency of our processes mean that most of our funds’ dealing spreads are insignificant. The stamp duty and other transfer taxes column shows the taxes incurred by the funds as we buy and sell securities to keep them in line with their benchmarks. An example is SDRT which is paid to the UK government on purchases of UK shares. Similar taxes are paid in relation to investments in other markets. For most of the funds, this column shows stamp duty and other transfer taxes incurred by each fund as a result of the purchase of underlying securities because of: (a) subscriptions into the funds; and (b) day-to-day fund management activity. However, for those funds where we impose an SDRT charge, this column only shows SDRT incurred as a result of day-to-day fund management activities. For these funds, the SDRT charge has been designed to cover all the SDRT incurred as a result of both: (a) the purchase of UK shares following subscriptions into the fund; and (b) the sale of UK shares following investor redemptions. SDRT on the sale of UK shares was removed from 1 April 2014, however as these figures are historic, SDRT on the sale of shares is included up until this date. We will update this document annually, or more frequently in the case of any significant changes. You can find out more general information about fund charges and costs on the IA’s website at: http://www.theinvestmentassociation.org/investmentindustry-information/fund-charges-and-costs/ Please be aware that Vanguard Asset Management, Limited only gives information on our products. We cannot give advice based on individual circumstances. This is where the advice of a qualified financial adviser can be crucial. If you have any questions related to your investment decision or the suitability or appropriateness for you of the products or services described in this document, please contact your financial adviser. Important information This document is designed only for use by, and is directed only at investors resident in the UK. The information on this document does not constitute legal, tax, or investment advice. You must not, therefore, rely on the content of this document when making investment decisions. The material contained in this document is not to be regarded as an offer to buy or sell or the solicitation of any offer to buy or sell securities in any jurisdiction where such an offer or solicitation is against the law, or to anyone to whom it is unlawful to make such an offer or solicitation, or if the person making the offer or solicitation is not qualified to do so. The value of investments, and the income from them, may fall or rise and investors may get back less than they invested. Past performance is not a reliable indicator of future results. The Manager of Vanguard Investment Series plc is Vanguard Group (Ireland) Limited. Vanguard Asset Management, Limited is a distributor of Vanguard Investment Series plc. Vanguard Investment Series plc has been authorised by the Central Bank of Ireland as a UCITS and has been registered for public distribution in certain EU countries. The Authorised Corporate Director for Vanguard Lifestrategy Funds ICVC is Vanguard Investments UK, Limited. Vanguard Asset Management, Limited is a distributor of Vanguard Lifestrategy Funds ICVC. The Authorised Corporate Director for Vanguard Investment Funds ICVC is Vanguard Investments UK, Limited. Vanguard Asset Management, Limited is a distributor of Vanguard Investment Funds ICVC. 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