Financial Services Guide

Preparation Date: 1 November 2022

What is the purpose of this financial services guide?

This financial services guide (FSG) is an important document. It is designed to assist you in deciding whether to use any of the financial services offered by us, as described in this FSG. We are required to give you an FSG if we provide certain financial services to you and you are a retail client. This FSG contains important information about:

• who we are;
• the financial services we offer;
• the financial products to which those services relate;
• how we and others are paid in connection with those services;
• your privacy;
• how we deal with complaints; and
• how we can be contacted.

This FSG is not intended for ‘wholesale clients’ as defined by the Corporations Act 2001 (ie professional investors).

References to ‘you’ and ‘your’ refer to potential investors who are not ‘wholesale clients’. This FSG is provided by Eley Griffiths Group Pty Limited (ABN 66 102 271 812, AFSL 224 818) (EGG). References to ‘EGG’, ‘we’, ‘us’ and ‘our’ refer to Eley Griffiths Group Pty Limited.

Are there any other documents that you will receive?

Will you receive a statement of advice?
A person who provides a retail client with personal advice (that is advice that takes into account the client’s objectives, financial situation and needs) must give the client a statement of advice (SOA). We do not provide personal advice to retail clients. Accordingly, you should not expect to receive an SOA from us.

Will you receive a product disclosure statement?
Before acquiring one of our products, you should be provided with a product disclosure statement (PDS), which is designed to assist you to make an informed decision about the product. The statement will contain information about the product and will usually include the costs and details of other fees and charges which may apply, including (if applicable) any fees, or other benefits (collectively referred to as Adviser Remuneration) payable to financial advisers.

Will you receive a general advice warning?
A person who gives retail clients general advice (that is, advice that is not personal advice) must generally warn the client that the advice does not take into account the client’s objectives, financial situation or needs. Where we provide you with general advice, we will also generally provide you with a general advice warning. The general advice warning will be given in the same manner as the advice is provided (ie in writing or verbally).

 How do you obtain further information?
This FSG contains general information about the financial services that we provide. When providing these financial services, we act on our own behalf. If you require more information, please contact us.

The financial services we are authorised to provide

Provide financial product advice to wholesale clients about:
Basic deposit products – Yes
Debentures, stocks or bonds issued or proposed to be issued by a government – Yes
Interests in managed investment schemes¹ – Yes
Securities – Yes

Provide general financial product advice to retail clients about:
Interests in managed investment scheme¹ – Yes
Securities – Yes

Deal in a financial product by arranging for another person to issue, apply for, acquire, vary or dispose of a financial product to wholesale clients in respect of the following classes of financial products:
Interests in managed investment scheme¹ – Yes

Applying for, acquiring, varying or disposing of a financial product
on behalf of another person to wholesale clients in respect of the following classes of products:

Basic deposit products – Yes
Debentures, stocks or bonds issued or proposed to be issued by a government – Yes
Interests in managed investment schemes Yes3
Securities Yes
1 Excluding investor directed portfolio services.

Any advice provided by EGG is limited to general financial product advice which we provide, for example, in our PDSs, investment newsletters, investor reports and website material. This information generally relates to product features, managing risk and return, investment market commentaries and economic overviews.

We do not provide personal financial product advice to retail clients. Before you make any investment decision, we recommend that you obtain advice tailored to address your individual objectives, financial situation and needs from a licensed financial adviser.

We are responsible for the financial services provided to you under our Australian Financial Services Licences (AFSL). We do not act as a representative for any other AFSL holder.

Why we do not give personal advice to retail clients

We believe investors should obtain financial product advice from qualified financial advisers who fully understand the investors’ individual objectives, financial situation and needs.

How we and others are paid for the financial services we provide

If you acquire one of our products, we will receive fees and other benefits. These are generally set out in the PDS for the product. Where permitted by law, this remuneration may include contribution fees, withdrawal fees and management fees applicable to the particular product.

Financial advisers may receive (in accordance with applicable legal requirements) Adviser Remuneration if they provide advice to you or arrange for you to acquire our products. Only costs associated with advice that relates to your superannuation may be deducted from your superannuation account.

Any Adviser Remuneration, if paid by us, is set out in the PDS under which you acquired the product. The amount (or method of calculating the amount) of Adviser Remuneration should be disclosed in the SOA you should receive from the adviser.

Our staff are paid a salary and may be entitled to receive bonuses and non-monetary benefits. These bonus payments are not an additional cost to you.

You may receive advice about our products from financial advisers. These advisers may receive remuneration from us if you buy our product. Your adviser is required to set out their Adviser Remuneration in the FSG and/or SOA they must give to you. If you have an ongoing fee arrangement with your financial adviser they must also provide you with a fee disclosure statement on an annual basis.

We do not pay fees or other benefits to third parties for solely referring customers to us. However, we may pay a third party to be our administrator. We may provide benefits to financial services intermediaries where the law permits us to do so. If we do, we will provide these benefits from our own resources. We maintain a register of these benefits. If you would like to review our register, please contact us.

Related parties and service providers

We may enter into transactions with, and use the services of, any related parties. It is our policy to ensure that such arrangements are on arm’s length commercial terms. We or any related parties or any director or officer of any of them may invest in any financial product we manage.

We receive fees as the investment manager. Directors, being employees or independent directors receive a salary (from employment) or director fees. From time to time the directors may hold interests in shares of financial products we manage.

Privacy

We respect your privacy and have provided detailed information in the PDS in relation to how we collect, use and disclose your personal information. Our Privacy Policy can be obtained by contacting us directly or by visiting our website.

Conflict of interest

Potential conflicts may occasionally arise between the interests of investors, ourselves and our related parties and other parties (including service providers appointed by us). We have statutory and common law fiduciary duties to manage conflicts of interest, act in the interests of investors and, if there is a conflict, give priority to investors’ interests and/or duties (as applicable).

We have policies, procedures and organisational arrangements in place to manage conflicts of interest. Our Board is responsible for the management and resolution of conflicts of interest arising in relation to the operation of the financial products we manage.

Compensation arrangements

EGG is insured under the terms of a current professional indemnity insurance policy, in satisfaction of the

requirement under section 912B of the Corporations Act that EGG has in place this type of insurance. These

insurances provide cover even if one of our employees has ceased to work for us.

How we deal with complaints

As part of our commitment to providing quality services to our clients, we endeavour to resolve all complaints quickly and fairly. Our policy is to acknowledge any complaint within 24 hours or as soon as practical after receiving it and investigate, properly consider and decide what action (if any) to take and to communicate our decision to you within 30 calendar days for standard complaints.

If you have a particular complaint regarding your financial product or investment, please do not hesitate to contact us by calling our Investor Services team on +61 (2) 92710 0900 or by emailing [email protected] or by writing to :

Complaints and Dispute Resolution Officer
Eley Griffiths Group
Level 24, 1 Farrer Place
Sydney NSW 2000

If you are not happy with our response or how the complaint has been handled (or if we have not responded within 30 days), you may contact the following external dispute resolution scheme:

Australian Financial Complaints Authority (AFCA)
GPO Box 3
Melbourne VIC 3001
Tel: 1800 931 678
Email: [email protected]
www.afca.org.au

AFCA provides fair and independent financial services complaint resolution that is free to consumers. There are some time limits for lodging certain complaints including those related to a death benefit. Please consult the AFCA website to find out if or when the time limit relevant to your circumstances expires.

How can you contact us and provide us with instructions?

To change your investment or personal details or conduct transactions, you can instruct us in writing. Some products and services may have their own rules on how to provide instructions or carry out certain instructions, including accepting instructions on the phone or via our Investor portals. Please refer to the relevant PDS or other communications relating to your product for details.

You can contact us by:
Calling our Investor Services team on +61 (2) 8311 5175
Visiting www.eleygriffithsgroup.com
Writing to us at Level 24, 1 Farrer Place, Sydney NSW 2000