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 [1]. In addition, Domini's website contains information about each Fund’s complete portfolio holdings, including, as applicable, the security description, the security identification number, 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.