protecting lost super Product Disclosure Statement Date of Preparation: 18 May 2018

Transcription

1 protecting lost super Product Disclosure Statement Date of Preparation: 18 May 2018

2 Super Safeguard Product Disclosure Statement Date of Preparation: May June Things you should know: This PDS is a summary of significant information and contains a number of references to important information - called the Incorporated Information Booklet - which forms part of the PDS; You should consider both the information in this PDS and the Incorporated Information Booklet before making a decision about the product; This PDS and the Incorporated Information Booklet can be obtained from or on request by phoning The information provided in this PDS is general information only and does not take into account your personal financial situation or needs; and You should obtain financial advice tailored to your personal circumstances. Contents Section 1: Section 2: Section 3: Section 4: Section 5: Section 6: Section 7: Section 8: About Super Safeguard How super works Benefits of investing with Super Safeguard Risks of super How we invest your money Fees and costs How super is taxed How to open an account? The provisions of ASIC Class Order 14/1252 (as amended by the ASIC Corporations (Amendment) Instrument 2016/1224 and the ASIC Corporations (Amendment and Repeal) Instrument 2015/876) apply to this Product Disclosure Statement. Issued by The Issued Trust by Company Diversa (Superannuation) Trustees Limited Limited (ABN 49 (ABN , 421 AFSL 638, ) AFSL ) as trustee as trustee of the of Super the Super Safeguard Fund, Fund, ABN (Fund). Effective from 1 July 2016 the ABN Trustee will 747 be renamed 013 (Fund). to Diversa Trustees Limited. The Fund s contact details are: Telephone Facsimile enquiries@supersafeguard.com.au Postal Address Super Safeguard GPO Box 3426 Melbourne VIC 3001 Delivery Super Safeguard Level 1, 333 Collins Street Melbourne VIC 3000 It assists the Administrator if you have your member number handy when you contact them. The Administrator s business hours are 8.30am to 5.00pm Melbourne time on business days. 2 super safeguard

3 Section 1: About Super Safeguard Super Safeguard is a Product available from the Super Safeguard Fund, an authorised Eligible Rollover Fund (ERF) in accordance with the Superannuation Industry (Supervision) Act 1993 (SIS). The Product is designed to accept superannuation benefits from regulated superannuation funds or other arrangements as permitted by law. Super Safeguard cannot accept personal or employer contributions. The Trustee of the Fund is Diversa Trustees Limited (ABN , RSE LIcence No L , AFSL ), a professional trustee company with many years of experience. The Trustee uses various service providers in relation to the administration and operation of the Fund and the oversight of the Fund s investments. These service providers may change from time to time. The Fund Administrator is Australian Administration Services Pty Ltd. ABN AFSL (a part of the Link Group). JANA Investment Advisors Pty Ltd (ABN , AFSL ) [JANA] provides asset consulting services to the Fund. JANA has consented to any statements attributable to, or provided by, JANA appearing in this PDS. To access information regarding Trustee and Executive remuneration and other information that a trustee must make available on the Fund s website, please visit Section 2: How super works Superannuation is a means of saving for retirement which is, in part, compulsory. There are different types of contributions available to a person (for example, employer contributions, voluntary contributions and government co-contributions) to help build retirement savings. As an employee you may also have the right to choose into which fund your employer should direct their (compulsory) superannuation guarantee contributions (called Choice of Fund ) Further information about Choice of Fund is available from However, it should be noted that ERFs may only be used as a temporary repository for amounts transferred to the Fund from other regulated superannuation funds. This means that Super Safeguard is not able to accept any form of contributions or any monies from the Australian Taxation Office (ATO) for its members. If we receive a contribution or any monies from the ATO for your membership, we will refund the money back to the source. Superannuation receives concessional tax treatment, that is, tax savings are provided by the Government. Refer to Section 7 of this PDS for more information. While you can ask us to transfer your benefit in Super Safeguard to another superannuation product at any time, there are limitations on cash withdrawals from superannuation. These limitations apply to all superannuation funds. Generally, you can access your superannuation savings once you retire on or after reaching your preservation age or in other circumstances permitted by law (for example, death and permanent incapacity) - called conditions of release. The conditions of release for temporary residents are more restrictive than those applicable to Australian citizens, New Zealand citizens or permanent residents of Australia. There are also limitations on who can receive your benefit in the event of death. Usually superannuation benefits can only be paid to a dependant (as defined in Government legislation) and/or the legal personal representative of a deceased member. There are certain circumstances in which superannuation benefits must be transferred by the Trustee to the ATO (for example, small or unidentifiable lost accounts, unclaimed benefits on or after age 65 and unclaimed benefits of former temporary residents). If you would like more information contact the Administrator. General information about super is available from Section 3: Benefits of investing with Super Safeguard This Product provides a low cost accumulation style arrangement where your account balance is made up of your initial and subsequent investments (if any), after taking into account any investment earnings, fees, costs and taxes that may apply. There is no choice of investment options available (all benefits are invested in a single investment pool). This helps keep the costs of the Fund as low as reasonably possible. There are no insurance benefits available to members in this Product. Claim your Super When a member retires, or meets some other legislative condition for payment of their superannuation such as permanent incapacity or death, their account is payable as one or more lump sums. You can also transfer your benefit out of the Fund at any time. A transfer out request form has been sent to you upon joining the Fund. If you need another copy, one can be obtained from our website at or by calling our contact centre on If you feel that you are able to access your benefit in cash because you satisfy a condition of release as explained in Section 2 of this PDS, please contact us and we will inform you of any further details and send you the appropriate documentation. (Our contact details are on the front cover of this PDS.) Other Significant features and benefits of this Product Investment earnings are passed on to members through the declaration of crediting rates, after allowing for relevant fees, costs, taxes and the Fund s reserving policy. For information about annual crediting rates, refer to the Fund s annual reports which are available from or on request by phoning Interim crediting rates apply if you leave the Product during the year before the declared annual crediting rate has been determined and applied to member accounts. You can nominate a preferred beneficiary(ies) for the receipt of your benefit in the event of death by completing the Member Change of Details Form available on request from the Administrator or from The nomination will be considered by (but is not binding on) the Trustee. Safeguarding Your Privacy The Trustee is committed to providing the highest level of service, and this includes safeguarding your privacy. The Trustee is required to comply with obligations under Privacy legislation. These obligations include standards for the handling of personal information, including the collection, use, disclosure, storage and disposal of information, as well as the rights of individuals to access and correct that information. Access to our Privacy Policy Statement is available upon request or available on fund s website, please visit We may disclose your personal information to external parties which provide services to us in relation to the Fund (for example the Fund Administrator, other superannuation providers, auditor, providers of printing or postal services, providers of location services to assist with identifying or confirming member address details) or as otherwise required or permitted by law. Under recent government reforms relating to anti-money laundering and counter terrorism financing, we may be required to report personal information about you to AUSTRAC (a government agency responsible for this area). We may use your personal information to conduct data matches with other superannuation providers or with the Australian Taxation Office unless you request otherwise. You should read the important information about privacy before making a decision. Go to section 1 Privacy of the Incorporated Information Booklet which is also located at The material relating to privacy may change between the time when you read this PDS and the day you acquire this product. protecting lost super 3

4 Section 4: Risks of super Things you should know: All investments carry risk Different investment strategies may carry different levels of risk depending on the assets that make up the strategy. (Note: this Product only offers one investment strategy) Assets with the highest long-term returns (such as shares and property) may also carry the highest level of short-term risk. The significant risks associated with Super Safeguard s investments are inflation risk, individual investment risks, market risk, interest rate risk, currency risk, liquidity risk and operational risk. As Super Safeguard does not provide different investment options, members aren t able to modify their investment strategy according to their individual situation or needs (including risk profile) which may also be regarded as a risk to achieving your retirement goals. Other general risks relevant to the Fund, are: The value of your investment will vary The level of returns will vary, and future returns may differ from past returns Returns are not guaranteed, and you may lose some of your money Superannuation laws may change in the future The amount of your future superannuation savings may not be enough to provide adequately your retirement Your level of risk will vary depending on a range of factors including your age, investment timeframe, where other parts of your wealth are invested and your risk tolerance. Section 5 of this PDS contains the risk profile of the Fund s investment strategy. The Trustee aims to allocate investment earnings to each member s account at a competitive rate. However, from time to time a portion of the earnings of the Fund may be retained in the Expense Reserve to allow for the payment of Fund expenses and tax. The Expense Reserve ranges on average between 50,000 to $100,000. The reserving policy may change in future years. Section 5: How we invest your money Warning: When making an investment decision, consider the likely investment return and risk of our investment strategy and your investment timeframe Investments The Trustee invests members money with a specific aim of providing: sufficient earnings to ensure that the Product can meet the cost of its financial obligations to its suppliers and to provide a reasonable rate of return to members, a very cost efficient investment process, and an Expense Reserve from which to draw to pay Fund expenses. Crediting Rate and Reserving Policy The Trustee maintains an Expense Reserve in order to manage the expenses of the Fund and has established an Operational Risk Financial Requirement (ORFR) Reserve to provide funding for incidents where material losses may arise from operational risk relating to the Fund. Investment Objectives The broad objectives of the Fund are: to protect the members capital while providing long term growth in line with inflation by achieving a rate of return of at least 2% per annum (after tax and fees) in excess of inflation (as measured by CPI) measured over rolling five year periods. to control the variability of investment returns through diversification across a range of asset classes. on average negative returns are not expected to be incurred more frequently than two or three years in any 20 year period. Investment Strategy The Product s assets will be invested in accordance with the following table. The table outlines a Neutral Asset Allocation as well as the minimum and maximum allocations for Target Asset Allocations. An explanation of key terms appears below the table. Target Asset Allocation Asset Class Neutral Asset Allocation Minimum Maximum Australian Shares 12.8% 7.8% 17.8% Global Shares (Unhedged) 6.8% 1.8% 11.8% Global Shares (Hedged) 6.8% 1.8% 11.8% Property 1.6% 0% 6.6% Total Growth Assets 28% 23% 33% Defensive Alternatives (Low Correlation Strategy) 2% 0% 7% Diversified Debt 70% 65% 75% Total Defensive Assets 72% 67% 77% All investment earnings of the Fund (i.e. gross earnings) are allocated to the Expense Reserve. The Trustee determines an interim crediting rate based on the earnings of the Fund s assets to allow the payment of benefits from the Fund. Interim crediting rates are reviewed quarterly and may be positive or negative. Defensive assets include cash, defensive alternatives and fixed interest. Growth Assets include shares, property and private equity. Hedging is used, in relation to the Fund s investment in Global or overseas shares, to manage the Fund s currency exposure. JANA manages the Fund s currency exposure through employing external managers. JANA can alter the proportion of the Fund s foreign currency exposure as part of a Strategic Overlay process (described further below under Target Asset Allocation ). The Trustee will determine an annual earnings rate to be allocated to member s accounts after taking into consideration the actual returns for the year minus any relevant tax, fees or expenses or any amounts retained in or allocated from the reserves of the Fund. Annual crediting rates may be positive or negative. The declared annual crediting rate is allocated annually to each member s account effective 30 June. If a member leaves Super Safeguard before the declared annual crediting rate has been determined and allocated to member accounts, an interim crediting rate is allocated to the member s account up to the date of that member exiting the Fund. The Trustee does not take into account labour standards or environmental, social or ethical considerations in the selection, retention or realisation of investments for this Product. 4 super safeguard

5 JANA Diversified Debt The JANA Diversified Debt Strategy invests mainly in short maturity global and Australian fixed income assets. Other assets such as commodities and hybrid securities may be used to hedge against inflation or provide additional diversification. Foreign currency exposures will generally be substantially hedged to the Australian dollar. Low Correlation Strategy (LCS) The LCS invests in a diversified range of alternative investment strategies which provide low correlation to equities. A key focus of the strategy is to avoid negative returns during periods of negative equity markets. Foreign currency exposures will generally be hedged to the Australian dollar. Enhanced Cash The Strategy invests predominantly in a range of cash and short-term Australian money market securities as well as some longer dated debt instruments such as fixed and floating rate corporate bonds. It aims to provide investors with a regular income stream and over time is expected to earn a return that exceeds the USBA Bank Bill Index. Neutral Asset Allocation The Neutral Asset Allocation is long term in nature and is not altered frequently. The Trustee will maintain this allocation until such time as the rationale for the strategy no longer remains appropriate. A neutral asset allocation of 28% Growth Assets and 72% Defensive Assets is expected to achieve the Fund s objective (CPI + 2%) over the long term. Target Asset Allocation To capitalise on situations where particular asset classes are over or undervalued, a Strategic Overlay is used to adjust the investment strategy from the Neutral Asset Allocation within certain agreed ranges. The resultant asset allocation is referred as the Target Asset Allocation. To allow the Strategic Overlay to be implemented in a timely way, the Trustee has given JANA the discretion to make changes to the asset allocation within agreed ranges, without gaining Trustee approval beforehand. For example, the range for the growth assets allocation is from 23% to 33%. Rebalancing Variations in asset allocations may occur from time to time. Rebalancing of the investments is conducted to ensure the actual allocation to each asset class remains within relatively tight bands of the desired allocation. JANA manages the portfolio s rebalancing. JANA aims to keep the actual asset allocation to within 5% of the Target Asset Allocation. Exceptions to this 5% threshold may occur in instances of extreme market movements or for illiquid asset classes (eg Private Markets). Note that any under (over) allocation to Private Markets will be offset by a corresponding over (under) allocation to global shares (hedged). Underlying investments A range of professional investment managers may be used to achieve the exposure to assets in accordance with the strategy. In consultation with the asset consultant, the Trustee may choose to replace, remove and/or appoint investment managers. The Trustee may also alter the proportion invested with a particular investment manager if it reasonably considers it to be in the best interests of members. Derivatives Policy The Trustee will not directly buy or sell derivative instruments but permits its underlying investment managers to use futures, options and other derivative instruments. This is to assist the effective investment management of the Product s assets. However, derivatives will not be used to gear the Product s portfolio of assets (that is, borrowings) or for speculative purposes. The use of derivatives is monitored by or on behalf of the Trustee. Suitability This Product is intended to be suitable for conservative investors. The minimum suggested investment timeframe is 3 years. Risk Level Based on the Standard Risk Measure, the below classifications for the MLC Conservative Option apply: Risk Band: 4 Risk Label: Medium Expected Neg Returns Over 20 yrs: 2 to less than 3 The Trustee may change the Product s investment strategy or underlying investments from time to time. The Trustee may close the Product to new investments. The Standard Risk Measure is based on industry guidance to allow members to compare investment options that are expected to deliver a similar number of negative annual returns over any 20 year period. The Standard Risk Measure is not a complete assessment of all forms of investment risk, for instance it does not detail what the size of a negative return could be or the potential for a positive return to be less than a member may require to meet their objectives. Further, it does not take into account the impact of administration fees and tax on the likelihood of a negative return. Members should still ensure they are comfortable with the risks and potential losses associated with their chosen investment option. The Standard Risk Measure is segmented into the following bands: Risk Band Risk Label Estimated number of negative annual returns over any 20 year period 1 Very Low Less than Low 0.5 to less than 1 3 Low to medium 1 to less than 2 4 Medium 2 to less than 3 5 Medium to high 3 to less than 4 6 High 4 to less than 6 7 Very high 6 or Greater Section 6: Fees and costs DID YOU KNOW? Small differences in both investment performance and fees and costs can have a substantial impact on your long term returns. For example, total annual fees and costs of 2% of your account balance rather than 1% could reduce your final return by up to 20% over a 30 year period (for example, reduce it from $100,000 to $80,000). You should consider whether features such as superior investment performance or the provision of better member services justify higher fees and costs. Your employer may be able to negotiate to pay lower administration fees. Ask the fund or your financial adviser. TO FIND OUT MORE If you would like to find out more, or see the impact of the fees based on your own circumstances, the Australian Securities and Investments Commission (ASIC) website ( has a superannuation calculator to help you check out different fee options. Fees and costs can be paid directly from your account or may be deducted from investment returns or Fund assets. You can use the fees and costs information below to compare costs between different superannuation products. However, bear in mind the nature of the investment option that you are comparing. For a list of definitions relating to fees please visit protecting lost super 5

6 SUPER SAFEGUARD TYPE OF FEE AMOUNT HOW AND WHEN PAID Investment fee Nil Not Applicable Administration fee 1. Other fees and costs may apply. Refer to the Additional Explanation of Fees and Costs section of the Incorporated Information Booklet for further details. 2. This amount is a reasonable estimate only based on the information available from the previous financial year and may vary. You should read the important information about the fees and costs before making a decision. Go to the Incorporated Information Booklet available from or on request by phoning The information relating to fees and costs may change between the time you read this PDS and the day when you acquire this product. Example of annual fees and costs This table gives an example of how the fees and costs in the default investment option for this superannuation product can affect your investment over a 1 year period. You should use this table to compare this product with other superannuation products. EXAMPLE BALANCE OF $50,000 Investment fees Nil For every $50,000 you have in the product you will be charged $0 each year PLUS Administration fees PLUS Indirect costs for the Super Safeguard Fund EQUALS Cost of product $12.50 per annum $12.50 per annum Deducted from your account at 30 June each year or on leaving, on a pro rata basis Buy-sell spread Nil Not Applicable Switching fee Nil Not Applicable Exit fee Advice fees relating to all members investing in a particular investment option Other fees and costs 1 Indirect cost ratio A withdrawal that is to be sent to the Australian Taxation Office (ATO) will incur a $0.25c fee. All other withdrawals will be at a cost of $5.00 Nil Deducted from your account upon any withdrawal. Not Applicable Estimated This is deducted when 2.818% 2 determining investment earnings to be allocated to your account on an annual basis upon completion of end of financial year accounts And, you will be charged $12.50 in administration fees regardless of your balance 2.818% pa And, indirect costs of $1,409 each year will be deducted from your investment If your balance was $50,000, then for that year you will be charged fees of $1,421.50* for the product Note: * Additional fees may apply. And, if you leave the superannuation entity, you may also be charged exit fees of $5.00 (or 0.25c if the amount is sent to the ATO) of your total account balance (regardless of the amount of your account balance). Things you should know: The Trustee can change the amount of fees without your consent. Any material increases in fees must be notified at least 30 days in advance. Estimated fees may vary from year to year depending on the experience of the Fund and its underlying investments. The $12.50 administration fee may be increased without notice on 1 July each year in line with the Consumer Price Index. Estimated fees may change from year to year. The administration and exit fees quoted are exclusive of GST. Any applicable GST costs are included in the estimated indirect cost ratio. Operational Risk Reserve The Federal Government as part of its Stronger Super reforms has imposed a requirement for funds to establish and maintain an Operational Risk Reserve (ORR) to specifically cover potential losses arising from operational risks that may affect the Funds business operations. An operational risk is the risk of a loss resulting from inadequate or failed internal processes, people and systems, or from external events. The ORR may be drawn upon to assist in compensating members or the Fund in the event of an operational risk having materialised. The Trustee will build up the ORR within the Fund to the defined target amount over a 3 year transition period leading up to 30 June The ORR will be initially sourced from amounts transferred from the expense reserve, which will subsequently reduce the crediting rate to members. If the ORR falls below the target amount, the Trustee will seek to top up the ORR from these sources if required. Section 7: How super is taxed Contribution Tax No contribution tax applies to rollovers paid into your account, unless received from an untaxed source. Once deducted, we then remit the contribution tax to the Australian Taxation Office. Warning: Concessional tax rates do not apply on contributions which exceed Government contribution limits. The government has set limits on the amount of concessional contributions and the amount of non-concessional contributions that can be made into super in a financial year. Concessional contributions are before tax contributions made to superannuation (for example, amounts paid into the Fund from the Superannuation Holding Accounts Special Account and the shortfall component of any Superannuation Guarantee Charge paid to the Fund as well as employer contributions and deductible member contributions). Non-concessional contributions are after tax contributions made to superannuation (for example, non-deductible member contributions. They also include excess concessional contributions). If your concessional contributions and/or non-concessional contributions in a financial year exceed Government contribution limits, additional (excess) taxes will ordinarily apply.* Excess taxes for contributions are a personal tax liability which must be released from your fund in the case of excess non-concessional contributions. You may choose to release up to 85% of your excess concessional contributions which would be paid by us to the ATO after receiving a release authority. If your income and non-excessive concessional contributions exceed $300,000 in a financial year, an additional 15% tax will apply to the lesser of the member s non-excessive concessional contributions and the amount of the member s income and non-excessive concessional contributions that exceed $300,000. Please note, the Fund cannot accept contributions (concessional or non-concessional). Tax on Investment Earnings Superannuation funds are taxed on their investment earnings at a concessional rate. Currently, the maximum rate of tax on superannuation fund investment earnings is 15%. This tax may be offset in part or in whole by allowable deductions, such as franking credits. This tax is deducted from investment earnings before earnings are allocated to your account. Tax on benefits You may have to pay tax when you receive a superannuation benefit in cash. The amount paid will depend on your own circumstances such as your age and the components of your benefit. Benefits paid from a taxed source to a person aged 60 or more will be tax free. Benefits paid to death benefits dependants of a deceased member as a lump sum and members who are diagnosed with a terminal medical condition (as defined in government legislation) are also generally tax free. Death benefits paid as a lump sum to a person who is not a death benefits dependant will generally be subject to tax on the taxable component of the lump sum benefit at the rate of 15%** (plus Medicare levy). Additional tax applies if the taxable component contains an untaxed element. Benefits paid to a person aged under 60 are subject to tax, based on the following components. 6 super safeguard

7 A tax-free component made up of non-concessional (after-tax personal) contributions made from 1 July 2007 and other amounts transferred into the Fund which contain a tax-free component. No tax is payable on the tax-free component; A taxable component made up of the total superannuation benefit, less any tax-free component. The taxable component will be taxed at 20%** (plus Medicare levy) if paid to a person under their preservation age or 15%** (plus Medicare levy) on any amount over a specified threshold (which is subject to change from year to year) if paid to a person from preservation age to age 59 (amounts under the threshold will attract a nil rate of tax).** The threshold applicable from year to year can be found at or on request from the Administrator. Higher tax may apply if a member s TFN is not held.* Any payment of superannuation benefits must be withdrawn from the tax-free and taxable components in proportion. Taxes do not usually apply to transfers to another superannuation fund. Please visit for more information about the Temporary Budget Repair Levy or see your taxation adviser. Tax File Number (TFN) Under SIS, the Fund is authorised to collect your tax file number (TFN), which will only be used for lawful purposes. These purposes may change in the future as a result of legislative change. The Trustee of the Fund may disclose your TFN to another superannuation provider, when your benefits are being transferred, unless you request the Trustee in writing that your TFN not be disclosed to any other superannuation provider. It is not an offence not to quote your TFN. However giving your TFN to the Fund will have the following advantages (which may not otherwise apply): The tax on any taxable amounts paid to your account will not increase; Other than the tax that may ordinarily apply, no additional tax will be deducted when you start drawing down your superannuation benefits; and It will make it much easier to trace different superannuation accounts in your name so that you receive all your superannuation benefits when you retire. For taxation advice that takes into account your circumstances, consult a professional adviser. Further information about tax is available from Warning: You should provide your TFN to us. If the Fund doesn t hold your TFN, the tax on superannuation benefits may be higher and it may be more difficult to locate any lost super benefits or consolidate your superannuation. If you have not advised us of your TFN and wish to do so, please contact the Administrator on Section 8: How to open an account? Your account is established when your former superannuation fund or Retirement Savings Account provider transfers your benefit. This generally happens because you satisfy the criteria of your former fund or provider to transfer benefits to its nominated Eligible Rollover Fund. This may have occurred if you did not notify your previous fund of what to do with your benefit when you left your employer or you became lost as defined by superannuation legislation or in other circumstances specified by your previous fund. Once your account is set up information will be sent to you unless you are not contactable and your address is unknown. Superannuation providers (for example, superannuation fund trustees) wanting to commence the transfer of super benefits to the Fund must complete an application form, which will be provided with this PDS. Enquiries and Complaints The Trustee has a formal procedure for dealing with member enquiries and complaints. If you wish to make an enquiry or complaint, please send it in writing to or contact us at: Super Safeguard Enquiries and Complaints GPO Box 3426 Melbourne VIC 3001 Ph If after lodging an enquiry or complaint, you have not received a response or are not satisfied with the outcome within 90 days, you may have the right to lodge a complaint with the Superannuation Complaints Tribunal (SCT). The SCT is an independent body set up by the Commonwealth Government to hear complaints made by members and their beneficiaries against certain types of decisions made by superannuation trustees. The SCT can only consider complaints if you have already approached us first. Some decisions of the SCT may be reviewed by the Federal Court. The contact details for the SCT are: Superannuation Complaints Tribunal Locked Bag 3060 MELBOURNE VIC 3001 Phone: Fax: (03) protecting lost super 7

8 protecting lost super Product Disclosure Statement Date of Preparation: 18 May 2018 Printed on 55% recycled / 45% sustainable plantation card, elemental chlorine free /18 ISS7