Portfolio Holdings Information
Domini and each of the Funds maintains portfolio holdings
disclosure policies that govern the timing and circumstances of disclosure to
shareholders and third parties of information regarding the portfolio
investments held by the Funds. These
portfolio holdings disclosure policies have been approved by the Board of
Trustees of the Funds.
Disclosure of each Fund’s complete holdings is required to
be made quarterly within 60 days of the end of each fiscal quarter (currently,
each January 31, April 30, July 31, and October 31) in the Annual Report and
Semi-Annual Report to Fund shareholders and in the quarterly holdings report on
Form N-Q. These reports are available,
free of charge, on the EDGAR database on the SEC’s website at www.sec.gov.
In addition, Domini’s website (www.domini.com)
contains information about each Fund’s complete portfolio holdings, including,
as applicable, the security description, the ticker, the security
identification number, price per share, par value, interest rate, maturity
date, market value, and percentage of total investments updated as of the end
of the most recent calendar quarter (i.e., each March 31, June 30,
September 30, and December 31). This
information is provided on the website with a lag of at least 30 days and will
be available until updated for the next calendar quarter. This information is publicly available to
all categories of persons.
Domini’s website also provides portfolio holdings
information as of a date at least 5 business days after a Fund’s Effective Date
(as defined below), with a lag of at least 7 business days, until portfolio
holdings information for the first full calendar quarter after the Effective
Date is available with a lag of at least 30 days. Such information is limited
to a description of the securities held by the Fund and the identification
numbers and/or ticker symbols for such securities.
A Fund’s “Effective Date” is the date a Fund commences
operations or the effective date of a change to a Fund’s investment objective
or principal investment strategy.
From time to time rating and ranking organizations such as
Standard and Poor’s may request complete portfolio holdings information in
connection with rating a Fund.
Similarly, pension plan sponsors and/or their consultants may request a
complete list of portfolio holdings in order to assess the risks of a Fund’s
portfolio along with related performance attribution statistics. The Funds believe that these third parties
have legitimate objectives in requesting such portfolio holdings
information. To prevent such parties
from potentially misusing portfolio holdings information, the Funds will generally
only disclose such information as of the end of the most recent calendar
quarter, with a lag of at least 30 days, or, as of a date at least 5 business
days after a Fund’s Effective Date with a lag of at least 7 business days, as
described above. In addition, the Chief
Compliance Officer of Domini, or his or her designee, may grant exceptions to
permit additional disclosure of portfolio holdings information at differing
times and with different lag times to rating agencies and to pension plan
sponsors and/or their consultants, provided that (1) the recipient is subject
to a confidentiality agreement, (2) the recipient will utilize the information
to reach certain conclusions about the investment management characteristics of
the Funds and will not use the information to facilitate or assist in any
investment program, (3) the recipient will not provide access to third parties
to this information, and (4) the recipient will receive this information no
earlier than seven business days after the end of the calendar quarter or, as
of a date at least 5 business days after a Fund’s Effective Date or any later
date during such calendar quarter with a lag of at least 7 business days. As of October 19, 2005, the Funds have
obtained confidentiality agreements and have arrangements to provide additional
disclosure of portfolio holdings information to the following rating and
ranking organizations and pension plan consultants: Bidart & Ross, Inc.;
Cambridge Associates LLC; Jeffrey Slocum & Associates, Inc.; Marquette
Associates, Inc.; Mercer Inc.; New England Pension Consultants; Standard &
Poor's; and RV Kuhns & Associates.
In addition, the Funds’ service providers, such as the
Funds’ subadvisers, custodian, and transfer agent may receive portfolio
holdings information in connection with their services to the Funds.
In no event shall Domini, Domini’s affiliates or employees,
or the Funds receive any direct or indirect compensation in connection with the
disclosure of information about a Fund’s portfolio holdings.
