Tiger Brokers (NZ) Limited

Financial Services Guide

(FSG)

(ARBN: 623 547 446      AFSL: 505213)

25 February 2021

1. About Tiger Brokers (NZ) Limited

Tiger Brokers (NZ) Limited (“TBNZ”) holds an Australian Financial Services Licence (AFSL 505213 ARBN 623 547 446). “We”, “us”, “our” or “TBNZ” in this Financial Services Guide (“FSG”) refers to Tiger Brokers (NZ) Limited and our details are set out below.

2. Purpose of this FSG

This FSG has been prepared by TBNZ pursuant to the requirements of the Corporations Act 2001 and is designed to assist you in deciding whether to use any of the financial services provided by TBNZ. It aims to define the role and responsibility of TBNZ when we provide you with the financial services.

This FSG also contains information about how complaints against us are dealt with. If you are a retail client, we are required to provide you with this FSG when we provide certain financial services to you. This FSG is not intended for ‘wholesale clients’ as defined by the Corporations Act 2001.

References to ‘you’ or ‘your’ refer to potential recipients of our financial services who are not wholesale clients.

This FSG contains information about:

• Other documents you may receive from us;
• The financial services TBNZ provides;
• TBNZ’s policy on financial product advice and order solicitation;
• What is TBNZ’s position when you trade with us;
• How to give us instructions;
• Important information about corporate actions;
• Risk of trading;
• Information about execution and clearing arrangements;
• Client money;
• Deposit and withdrawals;
• Custody arrangements;
• Remunerations, Fees and Charges;
  • Benefits paid by TBNZ to introducing advisors, referrers and investment managers;
  • Change to fees;
  • Interest on TBNZ Trust Account;
• Tax;
• How are TBNZ’s employees remunerated;
• Potential conflicts of interest, associations and relationships;
• Privacy;
• If you have a complaint and the Australian Financial Complaints Authority;
• Professional indemnity insurance;
• Anti-Money Laundering and Counter Terrorism Laws; and
• US Foreign Account Tax Compliance Act (“FATCA”) Reporting and Common Reporting Standard (“CRS”) Reporting.

From time to time we may update and change this FSG and when we do so, we will publish the latest version on our website and online trading platform, and/or email a copy to existing clients.

3. Other documents you may receive from us

Before we provide you with any financial services or make financial products available to you, you will receive other documents from us when you apply to open an account.

Before you can open an account, you must read and accept our Terms and Conditions, including our Client Agreement that sets out terms applying to specific services and products we provide. The Terms and Conditions are available at www.tigerbrokers.com.au. It is important that you read and understand the Client Agreement because it will govern the legal relationship between you and us.

In addition to this FSG, we may also be required to provide you with other disclosure documents. Where we offer to issue, or arrange for the issue of a financial product(s), we must provide you with a Product Disclosure Statement (“PDS”) for the financial product(s). In order to invest, you will need to complete the application form attached to the PDS. The PDS contains important information about the financial product(s) offered. We are not required to provide you a PDS if you acquire certain financial products such as ASX listed shares, ETFs or warrants. 

You should keep a copy of the Client Agreement, the FSG and any PDS or any other disclosure document which we provide to you for future reference.

TBNZ is not authorised to and does not provide any personal financial product advice, therefore, we will not provide you with a Statement of Advice (“SOA”).

4. The financial services TBNZ provides

We hold AFSL 505213 which authorises us to provide the following financial services to both retail and wholesale clients:

• general financial product advice in relation to
  • securities;
• deal in by applying for, acquiring, varying or disposing of the following financial product on behalf of another person
  • securities; and
• operate custodial or depository services other than investor directed portfolio services.

TBNZ provides dealing and custodial services for securities. TBNZ is not a market participant of a licenced financial market in Australia so that execution and settlement services are provided by a third party. When you trade exchange-traded products (e.g. listed company shares), TBNZ will act as an intermediary and instruct market participants to enter trades on the exchange according to your orders.

TBNZ is authorised under its AFSL to provide general financial product advice to retail and wholesale clients in securities.

Investment warning: The subscription service provides both factual information and general financial product advice through publications including newsletters, SMS notifications, websites, emails and social media.

All of TBNZ’s commentary, statements of opinion and recommendations in relation to financial products, whether in TBNZ’s publications or otherwise, contain only factual information and/or general advice. Please note that to the extent that any of TBNZ’s publications or services provide advice, this is general financial product advice only. That is, those statements of opinion and recommendations have been prepared without taking into account your personal objectives, financial situation or needs. You should always consider the appropriateness of any general advice as well as any additional warnings, disclaimers or qualifications in our publications, having regard to your individual and financial circumstances before you act on the general advice.

You should also consider any product disclosure statement (PDS), prospectus or other disclosure documents relevant to any financial product referred to in any TBNZ content before making any decision about whether to acquire any such product.  To obtain such documents you would need to contact the issuer of the relevant financial product or a distributor of the product.

The publications are prepared by TBNZ’s own representatives and may include reference from reliable sources such as disclosure documents (e.g. a prospectus) issued by a listed company or a company to be listed. While TBNZ will use all reasonable efforts to obtain information from reliable sources, TBNZ does not guarantee the accuracy or completeness of that information. TBNZ’s financial product advice may be withdrawn or changed at any time as other information becomes available to TBNZ.

TBNZ’s publications and services should be viewed as an additional investment resource, not as your sole source of information. TBNZ recommends that you obtain appropriate financial, legal and taxation advice before making any financial investment decision. In addition:

• you should be aware that past performance does not necessarily indicate a financial product’s likely future performance; and
• if applicable, before making any decision to acquire a particular financial product, you should obtain and carefully consider the relevant product disclosure statement and risk disclosure.

5. TBNZ’s policy on financial product advice and order solicitation

TBNZ is not authorised to provide personal advice. We can only provide you with factual information, and in certain circumstances, we may provide general financial product advice. If you want personal financial product advice, we recommend that you consult with a financial advisor that takes into account your objectives, financial situations and needs.

You may receive third party market analysis or research through TBNZ’s platform or mobile app. Where TBNZ passes on this information, you should treat this information as general financial product advice only; this information does not consider your objectives, financial situation or needs. You should ensure that you consider any such information which we pass on in light of your own circumstances. We strongly recommend that you contact a financial advisor if you require personal financial product advice.

The discussions or correspondence you have with any representative of TBNZ will be technical in nature if it concerns the specific features and functionality of TBNZ’s platform. If your discussions or correspondence with TBNZ specifically relates to a financial product or financial service offered by TBNZ, then our staff will provide you with factual information about the products or services. TBNZ’s representatives will not provide recommendations to you or solicit orders from you, and any information provided will not take into account your objectives, financial situation or needs. When you speak with or correspond with TBNZ, you are dealing with a representative of TBNZ and we are responsible for the factual correctness of any information given. However, you are responsible for the decisions you make about your account and any financial products.

6. What is TBNZ’s position when you trade with us?

When you instruct TBNZ to deal or arrange a dealing in a financial product on your behalf, TBNZ will generally be acting as your agent in executing or arranging that dealing.

Whether TBNZ is dealing as your agent or with you as principal, your relationship with TBNZ is governed by our Terms and Conditions, including the Client Agreement and the applicable laws.

7. How to give us instructions

Important: Access to the trading platforms and interfaces provided by TBNZ is controlled through use of secure login credentials. You are responsible for the confidentiality of your log-in information, including your login credentials. You must keep this information secure and must not give or disclose it to anyone. TBNZ does not know whether an unauthorised person is entering orders on your account using your login credentials and you will be responsible for any transactions which result.

We accept instructions from you by telephone or electronically via our trading platforms.

We provide securities trading and other services primarily through electronic means and most of your interactions with TBNZ will be through such means – this will primarily be via our online trading platform or our mobile trading platform, Tiger Trade, in relation to the buying and selling of financial products.

You can view information about your account and submit instructions to us through Tiger Trade. In Tiger Trade, you may participate in corporate actions and ask questions or make requests.

8. Important information about corporate actions

It is important that you understand TBNZ’s role in acting as your custodian and passing on information about corporate actions. We are not obliged to provide information on upcoming voluntary corporate actions to you by any means. We may provide information regarding corporate actions on a best-efforts only basis within Tiger Trade or by other means, and you should monitor Tiger Trade and emails on a regular basis.

You must ensure you make any election to participate in voluntary corporates actions within the timeframes specified by TBNZ in the corporate action notification or in the absence of a specified timeframe prior to the closing date announced by the relevant corporation. It is possible that TBNZ may impose an earlier deadline than the one imposed by the relevant corporation.

There is also no guarantee that you will be allocated the full amount of rights/shares or any other kind of benefit that you subscribed to. We may exercise our absolute discretion to scale back the offer using a different methodology adopted by the relevant corporation.

9. Risk of trading

Although securities may offer the potential for profits, the risk of loss in trading can also be substantial. The risks of loss inherent in trading in financial products will vary depending on the financial product traded. The price of a security may rise and fall considerably depending on what other people are prepared to pay for a financial product at the time of a transaction. This price volatility will depend on many factors, including but not limited to, information about the company, market sentiment, opinions about the country the security or derivative is traded in and the prospects for the industry. Sometimes companies go bankrupt and investors may lose the entire value of their investment in it. You must consider what is appropriate for you in the light of your financial circumstances, objectives and needs.

There are additional risks associated with overseas-listed investment products and so called ‘penny stocks’. You must carefully consider and understand risks disclosed in the Risk Disclosure Statement before conducting any trading activities with TBNZ. The Risk Disclosure Statement is available at www.tigerbrokers.com.au

When you trade in securities through TBNZ, these securities are held by TBNZ in an omnibus account. This means that securities which TBNZ holds for you may be held in the same account as securities of other clients of TBNZ. TBNZ acts as custodian in relation to any financial products held by TBNZ for you. In addition, TBNZ may appoint a sub-custodian which may be an affiliate of TBNZ, any International Financial Market Participant or any sub-sub-custodian appointed by any of them to hold financial products for TBNZ. If there is an irreconcilable shortfall following the default of TBNZ or a third party broker or custodian, you may share in that shortfall proportionately with others whose assets are held in the omnibus account.

10. Information about execution and clearing arrangements

TBNZ is an intermediary of market participants of Australian or international markets. When TBNZ is an intermediary of a market participant, TBNZ arranges for the execution and clearing of your orders by or through a market participant of the relevant financial market. TBNZ’s Disclosure for Electronic Trading and Order Routing Systems explains how we handle your orders for equity market products.

11. Client money

TBNZ will handle client money it receives in acccordance with the rules set out in the Corporations Act 2001 and the terms of its agreement with you.

Client money received by TBNZ from you (or on your behalf) will be deposited into a trust account for holding client money. We may hold client money across multiple trust accounts to manage exposure to individual banks and to facilitate your dealing in different financial products. In all cases, the money TBNZ holds in its client money accounts is held on trust for its clients.

TBNZ only uses client money in accordance with the Corporations Act and the terms of our Client Agreement with you. These uses include but are not limited to:

1. to pay the fees and charges to which you have agreed, for example commission, or fees charged by your advisor or investment manager.
2. to discharge the obligations incurred by TBNZ on your behalf as a result of your trading, such as settlement costs and other obligations for exchange traded securities. Client money will be forwarded to an omnibus account for this purpose; and
3. to meet other costs arising from your instructions, for example to make payments required to execute your instructions to participate in certain corporate actions.

TBNZ may withdraw money held for you to pay to itself amounts that you owe to TBNZ for the services it provides or the products it issues to you.

TBNZ may also receive, derive and retain any interest or income generated from any client money held in a TBNZ trust account.

12. Deposit and withdrawals

As of the date of this FSG, TBNZ only holds client money in Australian dollar (AUD), US dollar (USD), Singapore dollar (SGD) and Hong Kong dollar (HKD). You can only deposit in these currencies and TBNZ does not support holding any other currencies at this time.

TBNZ accepts deposit by electronic fund transfer and we may accept other funding methods at a later date as advised. However, TBNZ does not accept deposits by cheque or in cash. You should ensure that you follow the instructions on how to deposit funds carefully to ensure that there are no delays in attributing deposits to your account. If you wish to withdraw money held for you, TBNZ will (subject to the Terms & Conditions in the Client Agreement and your current available liquid funds) pay this amount to you (but not to any third party). You must provide the correct payment instructions (including account details) and ensure you perform withdrawal requests correctly. Whilst TBNZ will take reasonable steps to comply with your payment instructions, TBNZ accepts no responsibility for any failure to comply with those instructions and, if a failure occurs, the relevant monies will continue to be held by TBNZ.

Important: Clients who trade, or wish to trade financial products on international exchanges may only do so where in compliance with the disclosure requirements of the Corporations Act 2001 (Cth) or where the client is exempt from these requirements and may also be required to meet the obligations for a transaction in a foreign currency and may be entitled to delivery of foreign currency upon settlement. While TBNZ does not support the holding of a particular foreign currency, we will arrange for an instantly settled spot foreign exchange transaction to be executed on your behalf to meet the obligations of the dealing or to convert the proceeds resulting from settlement (if any).

Money may be paid to clearing houses directly by TBNZ or to participants or foreign exchanges to meet settlement obligations. Money paid out to and held by participants of international exchanges or the clearing house of the relevant international exchange will not be held by TBNZ according to the Australian Client Money Rules, rather, it will be held in accordance with the rules of the relevant jurisdiction. In particular, money held by such third parties may not have the same level of protection afforded to client money in Australia in the case of the insolvency, bankruptcy, or failure of third party brokers/intermediaries or clearing houses.

All currency exchange risks from your dealings remain your responsibility. Except where we have entered into an instantly settled spot foreign exchange transaction with you at an agreed price, any conversion from one currency to another required to be made for performing or executing any payment instruction, or for paying for, or settling a dealing in any financial product on your behalf, may be effected by TBNZ in the manner,  at the time and at the exchange rates that TBNZ in its absolute discretion decides.

13. Custody arrangements

TBNZ provides custodial services for its clients in conjunction with its primary business of providing securities trading services.

TBNZ may appoint a sub-custodian which may be an affiliate of TBNZ, any International Financial Market Participant or any sub-sub-custodian appointed by any of them to hold financial products for TBNZ. For products transacted on financial markets outside of Australia, TBNZ will appoint a third party as a sub-custodian to hold any securities or resulting positions for TBNZ. In either case, TBNZ will hold the benefit of financial products held through such sub-custody arrangements on your behalf in accordance with the Terms and Conditions and the Client Agreement.

Your positions in securities will generally be held in an omnibus account together with the positions of other clients of TBNZ and the clients of the relevant sub-custodian (as the case may be).

14. Remunerations, fees and charges

TBNZ charges commissions and fees when you buy or sell financial products such as shares on your trading accounts. As of the date of this FSG, TBNZ does not charge any specific separate fees for the custody services it provides but may do so in future by providing existing clients with 30 days’ prior notice. The amount of the commission or fee payable to TBNZ depends on the financial product traded. Unless otherwise stated, all fees, charges and any benefits disclosed in this FSG are inclusive of GST (when applicable).

The fees we charge you are set out in this FSG. Where any amount of remuneration (including commission) or other fees is not able to be ascertained as of the date of this FSG, you may contact us to request particulars of the remuneration (including commission) or other fees. Your request must be made within a reasonable time after you receive this FSG and before we provide you with any of the financial services referred to in this FSG.

Online orders - fees and charges on US listed products*

* Trading low price shares (e.g. share price less than $1 USD) may carry higher risks, including the risk of loss of the share price in full and the risk of delisting. Investors should be cautious about buying or selling those shares. TBNZ sets a maximum fee of 1.0% of trade value per order on the sum of trading commission, transaction fee and platform fee. However, a minimum fee applies if an order triggers both the minimum and the maximum fees. See examples below:

Example one:

A sell order of 100 shares at $10 USD per share. Total fee is the sum of

• trading commission = $0.0039 * 100 = $0.39. As it is below the minimum, TBNZ charges $0.99;
• external agency fee and trading activity fee = $0.00396 * 100 = $0.396. As it is below the minimum, TBNZ charges $0.99;
• platform fee = $0.004 *100 = $0.4. As it is below the minimum, TBNZ charges $1.00; plus
• US Markets SEC fee = $0.0000221 * 100 * 10 = $0.0221.

Total fee equals $3.0021 USD.

Example two:

A sell order of 1000 shares at $10 USD per share. Total fee is the sum of

• trading commission = $0.0039 * 1000 = $3.9;
• external agency fee and trading activity fee = $0.00396 * 1000 = $3.96;
• platform fee = $0.004 *1000 = $4.00; plus
• US Markets SEC fee = $0.0000221 * 1000 * 10 = $0.221.

Total fee equals $12.081 USD.

Example three:

A sell order of 1000 shares at $1 USD per share. Total fee is the sum of

• trading commission = $0.0039 * 1000 = $3.9;
• external agency fee and trading activity fee = $0.00396 * 1000 = $3.96;
• platform fee = $0.004 *1000 = $4.00; plus
• US Markets SEC fee = $0.0000221 * 1000 * 1 = $0.0221.

Total fee equals $11.8821 USD. However, as the sum of trading commission, external agency fee and trading activity fee and platform fee is $11.86 and that is greater than 1.0% of trade value (i.e. $10), the total fee will be adjusted to $10.0221 USD.

Example four:

A sell order of 10 shares at $10 USD per share. Total fee is the sum of

• trading commission = $0.0039 * 10 = $0.039. As it is below the minimum, TBNZ charges $0.99;
• external agency fee and trading activity fee = $0.00396 * 10 = $0.0396. As it is below the minimum, TBNZ charges $0.99; plus
• platform fee = $0.004 *10 = $0.04. As it is below the minimum, TBNZ charges $1.00;
• US Markets SEC fee = $0.0000221 * 10 * 10 = $0.00221.

Total fee equals $2.980221 USD. Although the sum of trading commission, external agency fee and trading activity fee and platform fee is $2.98 and that is greater than 1.0% of trade value (i.e. $11), TBNZ prioritises the minimum fee rather than the maximum fee so that the total fee will stay at $2.980221 USD.

The above examples are for illustration purpose only.

Online orders - fees and charges on Hong Kong listed products

* These fees are collected by TBNZ on behalf of Hong Kong Exchanges and Clearing, Securities and Future Commission and/or Hong Kong government.

^ If the balance of cash dividend is less than $30 HKD, it will be deducted in full.

Online orders - fees and charges on Shanghai/Shenzhen-Hong Kong Stock Connect

Example:

Assuming that the market price of X stocks is ￥100 and 100 stocks are traded, the trade value of the stocks is￥10,000.*

The above example is for reference only.

Online orders - fees and charges on AU listed products

Example one:

A buy order of 100 shares at $10 AUD per share. Total fee is the greater of

• $8.80 AUD; and
• 100 * $10 * 0.11% = $1.1 AUD.

Total fee equals $8.80 AUD.

Example two:

A buy order of 100 shares at $100 AUD per share. Total fee is the greater of

• $8.80 AUD; and
• 100 * $100 * 0.11% = $11 AUD.

Total fee equals $11.00 AUD.

The above examples are for illustration purpose only.

Online orders - fees and charges on Singapore listed products

Example one:

A buy order of 1000 shares at $1 SGD per share. Total fee is the sum of

• Trading commission of Singapore listed Securities: $1 * 1000 * 0.06% = $0.6 SGD. As it is below the minimum, TBNZ charges $1.66 SGD;
• Platform fee: $1 * 1000 * 0.06% = $0.6 SGD. As it is below the minimum, TBNZ charges $1.66 SGD;
• Trading fee: $1 * 1000 * 0.0081% = $0.081 SGD;; and
• Clearing fee: $1 * 1000 * 0.035% = $0.35 SGD.

Total fee equals $3.751 SGD.

Example two:

A buy order of 1000 shares at $10 SGD per share. Total fee is the sum of

• Trading commission of Singapore listed Securities: $10 * 1000 * 0.06% = $6 SGD. As it is above the minimum of $1.66 SGD, TBNZ charges $6 SGD;
• Platform fee: $10 * 1000 * 0.06% = $6 SGD. As it is above the minimum of $1.66 SGD, TBNZ charges $6 SGD;
• Trading fee: $10 * 1000 * 0.0081% = $0.81 SGD; and
• Clearing fee: $10 * 1000 * 0.035% = $3.5 SGD.

Total fee equals $16.31 SGD.

The above examples are for illustration purpose only.

Market data service fees

We are charged royalty fees by the domestic and other international markets for the market data you use. There are various data options available on our trading platform for our clients. When you submit an account application online, you will be asked whether you are a non-professional investor. You may be required to pay a market data fee if you activate certain market data subscriptions. Please refer to our online trading platform for details about applicable market data fees.

Currency excahnge fees and transfer fees

Where a client transfers/receives money to/from TBNZ in a foreign currency other than AUD, the bank may charge a fee for international transfer or currency conversion. However, this fee is not charged by TBNZ and is out of TBNZ’s control. The client, instead of TBNZ, is responsible for paying the fee to the bank.

Position transfer-in and transfer-out fees

We can help transfer your existing share holdings in to or out from your trading account.

For position transfer-in and transfer-out other than US stock and HK stock, TBNZ as an intermediary of market participants of Australian or international markets will pass through the fees charged by the participants to you. Should you have any questions regarding a transfer, please contact our customer service at +61 02 9169 6999 (AU) or +0011 86 400 603 7555 (Global Helpline) for further details.

14.1 Benefits paid by TBNZ to introducing advisors, referrers and investment managers, and other referral arrangements

TBNZ may pay commission or provide other benefits to introducing advisers, referrers and investment managers for the introduction or referral of clients to TBNZ. The commission paid by TBNZ to introducing advisers, referrers and investment managers may include a flat rate, or an amount calculated as a percentage of the commissions retained by TBNZ when you trade. TBNZ will disclose the commission structure when clients open an account at TBNZ.

If you trade with TBNZ through an introducing adviser, referrer or investment manager, that introducing adviser, referrer or investment manager may have its own schedule of fees. Please refer to your introducing adviser, referrer or investment manager’s financial services guide, website or contact your introducing adviser, referrer or investment manager for further information. In those circumstances, if there are differences in the introducing adviser, referrer or investment manager’s fees for a particular service, the introducing adviser, referrer or investment manager’s fees will apply, not the fees for the service outlined in this FSG. Where payments are not considered as conflicted remuneration, we may make payments to third parties, representatives or employees without your prior consent.

If you have agreed to pay a third party advisor or investment manager a fee for the services that they provide to you, then unless otherwise stated, you agree for us to pay that fee to your advisor or investment manager on your behalf. You will be required to pay to us an amount equal to the specified advisor fee or investment manager fee in addition to any amount you owe us.

TBNZ may have in place referral arrangements to the providers of other services, including foreign broker services under which referral fees may be paid.

14.2 Change to fees

All fees, costs and charges and other amounts payable are correct as of the date of the FSG but are subject to change from time to time. TBNZ will give you at least thirty (30) days’ notice of any increase in fees or other changes that will adversely impact you. TBNZ reserves the right to negotiate different fees and charges with different clients.

14.3 Interest on TBNZ Trust Account

TBNZ holds your money in a TBNZ Trust Account in certain circumstances in accordance with the Corporations Act 2001. We may receive, derive and retain any interest or income generated from this TBNZ Trust Account.

15. Tax

Transaction taxes, such as value added taxes may apply in some jurisdictions. The taxation implications of trading in financial products will depend on your particular circumstances and it is recommended that you obtain your own independent taxation advice.

16. How are TBNZ’s employees remunerated

The directors and selected employees of TBNZ are paid a salary and bonus dependant on their individual performance. You can request further information regarding remuneration, commission and other benefits received by selected employees and directors of TBNZ by contacting our Compliance Department through compliance.au@tigerfintech.com. Your request, however, must be made within a reasonable time after you are given this FSG and before any financial service identified in this FSG is provided to you.

17. Potential conflicts of interest, associations and relationships

TBNZ does not, nor do any affiliates within our business group, have any relationships or associations with any product issuer that could reasonably be expected to be capable of influencing us in the provision of financial services. Unless otherwise disclosed, TBNZ generally acts on its own behalf when providing financial services to you.

Depending on what products you acquire from or through TBNZ, we may act as your agent (for instance, when we acquire or arrange for the acquisition of exchange traded financial products such as listed shares on your behalf) or as principal ourselves (for instance, when we settle instant spot foreign exchange transaction to you).

TBNZ does not generally undertake any principal trading in financial products that we acquire as your agent, except where we must correct error positions.

As a market participant or an intermediary of market participants, TBNZ executes trades on the markets on behalf of its clients and on behalf of offshore affiliates entities that provide securities trading services within our group (typically these will be trades originated for or on behalf of the clients of the relevant offshore affiliate). TBNZ handles all orders it receives in accordance with Disclosure for Electronic Trading and Order Routing Systems and Client Agreement.

Regarding TBNZ’s general financial product advice, TBNZ, its associated entities, and their respective directors, associates, connected parties and/or employees may from time to time deal in or otherwise have a financial interest in securities and other financial products referred to in its publications or other general financial advice it provides. Representatives including authorised representatives, employees and directors are guided by TBNZ’s internal compliance policy and procedures in order to avoid conflicts of interest or manage/disclose conflicts of interest.

All employees of TBNZ including those who prepare research and other advice are subject to rules for their personal trading activities. The major trading rules are:

• Employees cannot trade based on advance knowledge of information that will be published by TBNZ;
• Employees must hold any shares that they own for at least 10 days; and
• Employees must report their transactions to TBNZ’s compliance department within 24 hours of executing a transaction.

18. Privacy

Your privacy and personal information are important to us. We have adequate measures in place under the Privacy Act 1988 and will manage your personal information accordingly. We only collect personal information about you so that we may provide you with the financial product(s) and associated services(s) you request, as well as information on other products offered by us.

TBNZ collects personal information from you, including but not limited to, your name, address, contact details, tax file number, banking details and information on transactions carried out through TBNZ by you or any agent you appoint. TBNZ may use cookies, which also collect information from you. Clients of TBNZ may update personal details by emailing us clientservice@tigerbrokers.com.au.

TBNZ collects personal information from you as required by the laws to which we are subject to (for example AML/CTF laws) in order to provide you financial services (including custody services) and verify your identity. TBNZ will not sell, disclose or rent personal information collected without your consent.

TBNZ may be required by the law to disclose information about you to external parties including regulatory bodies. In such cases, TBNZ must fully cooperate with the relevant request.

You may choose to withhold certain information but this may mean that TBNZ is unable to provide you financial services.

TBNZ is bound by the Privacy Act 1988 and Australian Privacy Principles when we collect personal information from you. We take your privacy seriously, please review our Privacy Policy which may be viewed at www.tigerbrokers.com.au. We have taken steps to ensure that your personal information is kept both private and secure.

19. If you have a complaint

TBNZ is committed to providing a high quality product and service. If you have a query about the services and products we offer, we encourage you to contact us.

TBNZ’s complaint process is designed to ensure your complaint is handled promptly, appropriately and fairly, and dealt with in the strictest confidence.

We may request that you submit any complaints online to ensure such complaints are dealt with the most efficient manner. You may make your complaint by email compliance.au@tigerfintech.com or clientservice@tigerbrokers.com.au, and provide a completed TBNZ Complaint Form available at www.tigerbrokers.com.au. We will aim to acknowledge receipt of your complaint in writing as soon as possible and address your complaint within 30 days where possible. You may refer to TBNZ Dispute Resolution Policy available on our website for more details.

19.1 The Australian Financial Complaints Authority

If you are not satisfied with how your complaint is responded to by TBNZ or 45 days have elapsed, you may direct your concerns in writing to the Australian Financial Complaints Authority (“AFCA”) which is an independent dispute resolution scheme of which TBNZ is a member. The dispute resolution scheme offered by AFCA is provided to you free of charge. AFCA details are:

Australian Financial Complaints Authority

GPO Box 3, Melbourne, Victoria 3001

Telephone: 1800 931 678

Internet: www.afca.org.au

Email: info@afca.org.au

20. Professional indemnity insurance

The financial services offered by TBNZ are covered by a professional indemnity insurance policy which satisfies the requirements for compensations arrangements set out under section 912B of the Corporations Act 2001. This covers financial services provided by TBNZ and its employees, including employees after they cease working with us.

Subject to the terms and conditions of the policy, its coverage may include losses or damages suffered by retail clients as a result of breaches by TBNZ of its relevant obligations under its AFSL.

21. Anti-Money Laundering and Counter Terrorism Laws (“AML/CTF laws”)

TBNZ must meet strict identification requirements before we provide designated services to you. When you apply for an account with TBNZ, we will notify you of what information we need during the account opening process.

We may be legally required to disclose information we have obtained about you to regulatory or law enforcement agencies under AML/CTF laws.

TBNZ may decline to carry out a transaction or an instruction if we have reasonable grounds to believe it may breach Australian law or the law of any other country.

22. US Foreign Account Tax Compliance Act (“FATCA”) Reporting and Common Reporting Standard (“CRS”) Reporting

Under the Inter-Government Agreement between the Australian and US government, TBNZ has certain obligations to report transaction information to the Australian Tax office (ATO) on US citizens and various US and non-US entities. We may request you to provide certain FATCA information if you come within the requirements of the legislation.

We do not provide taxation advice, or advice about FATCA. You should consult your personal tax adviser if you believe that you are impacted by FATCA obligations.

The CRS is the single global standard for the collection, reporting and exchange of financial account information on foreign tax residents. TBNZ use the CRS due diligence rules to review accounts, identify those held by non-residents and report the relevant information to the ATO.