sovereign bridge capital group - bennett wealth group · super, personal insurance, tax strategies...

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BENNETT WEALTH GROUP PTY LTD ABN 28142752234 57 Adams Road, RED HILL WA 6056 Phone: (08) 9274 2888 Fax: (08) 9274 3388 [email protected] www.bennettwealth.com.au Corporate Authorised Representative No 348491 Bennett Financial Services Pty Ltd ABN 26142752225 AFSL and ACL No 357917 FSG ACL Ver 3.6 - 09102017.docx This Financial Services Guide is issued with the authority of Bennett Financial Services Pty Ltd. Page No. 1 FINANCIAL SERVICES GUIDE & CREDIT GUIDE About Us Bennett Wealth Group Pty Ltd (Bennett Wealth Group) is a provider of core, strategic financial advice we work with our clients to assist them in meeting not only their financial but also their lifestyle goals. We understand that often people don’t take the time to plan their financial future or they don’ t necessary understand the complexities of superannuation, taxation or other legislation that may impact on their financial wellbeing. We want outcomes to maximise the income that they earn, minimise the tax that is paid, mitigate the risks and most importantly assist them in having the financial stability to achieve the lifestyle they desire. We are committed to ensuring transparency in all of our dealings with clients therefore you have the right to ask us about our charges, the type of advice we will give you and what you can do if you have a complaint about our services. We have outlined below key information to respond to what we believe are your most likely questions. We expect a relationship with Bennett Wealth Group to be long term in nature and based on a mutual understanding of what is required of each party. Under the Corporations Act 2001, Bennett Wealth Group is obligated to act in your best interest and this requires Bennett Wealth Group to collect all required information about your financial situation and needs and objectives, make inquiries into the information provided, and investigate appropriate products and strategies that will meet your needs and objectives. From time to time where Bennett Wealth Group cannot recommend any appropriate products or where Bennett Wealth Group feels your best interest will not be served by the group, Bennett Wealth Group has a right to refuse provision of advice or services. Bennett Wealth Group utilises an approved product list, i.e. a list of products that have been researched by professional research houses and also the Bennett Wealth Group advisory team and deemed as suitable for investment purposes. We will only provide recommendations to invest into products that have been included on this approved product list. Information You Will Receive You should be aware that you are entitled to receive and we will provide you with a Statement of Advice (SOA - document outlining the advice) whenever we provide you with any initial advice which takes into account your objectives, financial situation and needs. The Statement of Advice will contain the advice, the basis on which it is given and information about fees, commissions and associations which may have influenced the provision of the advice. On an ongoing basis after the initial Statement of Advice has been provided to you, we will provide you with either verbal advice or a documented Record of Advice (ROA) where the basis of advice does not significantly differ from the initial advice. The ROA document consists of recommendations made, basis of recommendations, remuneration disclosure and important issues relating to the advice. The ROA will be kept on file for 7 years from the date of the advice. You have a right to request a copy of these documents within this time period. In the event we make a recommendation to acquire a particular financial product (other than securities) or offer to issue or arrange the issue of a financial product, we must also provide you with a Product Disclosure Statement containing information about the particular product which will enable you to make an informed decision in relation to the acquisition of that product. Should you choose to use our credit services you will also receive a Credit Quote and a Credit Proposal Document. The Credit Quote provides you with details of the credit services provided to you and its associated costs. We will not charge you above what is noted within the Credit Quote. The Credit Proposal Document provides estimates on specific details of commissions, fees and charges that are payable to us, other credit providers and third party (e.g. referral party).

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Page 1: Sovereign Bridge Capital Group - Bennett Wealth Group · super, personal insurance, tax strategies and estate planning. is a Representative of Bennett Financial Services in addition

BENNETT WEALTH GROUP PTY LTD ABN 28142752234

57 Adams Road, RED HILL WA 6056

Phone: (08) 9274 2888

Fax: (08) 9274 3388

[email protected]

www.bennettwealth.com.au

Corporate Authorised Representative No 348491

Bennett Financial Services Pty Ltd ABN 26142752225

AFSL and ACL No 357917

FSG ACL Ver 3.6 - 09102017.docx

This Financial Services Guide is issued with the authority of Bennett Financial Services Pty Ltd. Page No. 1

F I N A N C I A L S E R V I C E S G U I D E & C R E D I T G U I D E About Us Bennett Wealth Group Pty Ltd (Bennett Wealth Group) is a provider of core, strategic financial advice – we work with our clients to assist them in meeting not only their financial but also their lifestyle goals. We understand that often people don’t take the time to plan their financial future or they don’t necessary understand the complexities of superannuation, taxation or other legislation that may impact on their financial wellbeing. We want outcomes to maximise the income that they earn, minimise the tax that is paid, mitigate the risks and most importantly assist them in having the financial stability to achieve the lifestyle they desire. We are committed to ensuring transparency in all of our dealings with clients therefore you have the right to ask us about our charges, the type of advice we will give you and what you can do if you have a complaint about our services. We have outlined below key information to respond to what we believe are your most likely questions. We expect a relationship with Bennett Wealth Group to be long term in nature and based on a mutual understanding of what is required of each party. Under the Corporations Act 2001, Bennett Wealth Group is obligated to act in your best interest and this requires Bennett Wealth Group to collect all required information about your financial situation and needs and objectives, make inquiries into the information provided, and investigate appropriate products and strategies that will meet your needs and objectives. From time to time where Bennett Wealth Group cannot recommend any appropriate products or where Bennett Wealth Group feels your best interest will not be served by the group, Bennett Wealth Group has a right to refuse provision of advice or services. Bennett Wealth Group utilises an approved product list, i.e. a list of products that have been researched by professional research houses and also the Bennett Wealth Group advisory team and deemed as suitable for investment purposes. We will only provide recommendations to invest into products that have been included on this approved product list. Information You Will Receive You should be aware that you are entitled to receive and we will provide you with a Statement of Advice (SOA - document outlining the advice) whenever we provide you with any initial advice which takes into account your objectives, financial situation and needs. The Statement of Advice will contain the advice, the basis on which it is given and information about fees, commissions and associations which may have influenced the provision of the advice. On an ongoing basis after the initial Statement of Advice has been provided to you, we will provide you with either verbal advice or a documented Record of Advice (ROA) where the basis of advice does not significantly differ from the initial advice. The ROA document consists of recommendations made, basis of recommendations, remuneration disclosure and important issues relating to the advice. The ROA will be kept on file for 7 years from the date of the advice. You have a right to request a copy of these documents within this time period. In the event we make a recommendation to acquire a particular financial product (other than securities) or offer to issue or arrange the issue of a financial product, we must also provide you with a Product Disclosure Statement containing information about the particular product which will enable you to make an informed decision in relation to the acquisition of that product. Should you choose to use our credit services you will also receive a Credit Quote and a Credit Proposal Document. The Credit Quote provides you with details of the credit services provided to you and its associated costs. We will not charge you above what is noted within the Credit Quote. The Credit Proposal Document provides estimates on specific details of commissions, fees and charges that are payable to us, other credit providers and third party (e.g. referral party).

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B E F O R E Y O U G E T O U R A D V I C E

What services do we provide and who is your advisor?

The clients of Bennett Wealth Group have access to the entire Bennett Wealth Group team. By having a team approach to servicing our clients we can ensure clients have the most suitable resource acting on their behalf for various aspects of the planning and investment process.

Bennett Wealth Group Pty Ltd is a Corporate Authorised Representative (348491) of Bennett Financial Services Pty Ltd (AFSL No. 357917). Bennett Financial Services Pty Ltd is responsible for the advice provided by its Representative Bennett Wealth Group and the individual advisors.

Our team is led by the Directors Michael Bennett and Martin Cooke, and supported by experienced staff.

Michael Bennett

Michael (Mike) has been in the industry since 2001 and is the founder of Bennett Wealth Group. He has completed the Diploma of Financial Planning and is

a Certified Financial Planner®, which is the highest professional designation that can be given to a financial planner. He has extensive personal experience in wealth generation strategies using shares, property, superannuation and tax minimisation. Mike is also an accredited Life Coach.

Mike is a Representative of Bennett Financial Services in addition to being an Employee Credit Representative of Bennett Financial Services Pty Ltd.

Martin Cooke

Martin has been in the industry since 1999 and has extensive experience providing financial advice.

Martin has completed a Bachelor of Business, Post Graduate Diploma in Financial Planning and is a

Certified Financial Planner®, which is the highest professional designation that can be given to a financial planner. He has been providing advice since 2001 and has extensive experience with finance and loans, property, shares, managed funds, super, personal insurance, tax strategies and estate planning.

Martin is a Representative of Bennett Financial Services in addition to being an Employee Credit Representative of Bennett Financial Services Pty Ltd Jessica Wong

Jessica is a key part of the Bennett Wealth Group team providing para-planning and client services. Jessica has financial planning related qualifications in addition to extensive experience in strategy development. Jessica is an Authorised Representative (422856) of Bennett Wealth Group Pty Ltd. Stuart Webster Stuart has been in the industry since 2012 and has practical experience across all areas of Financial Planning. Stuart has completed his Degree in Commerce (Finance) at Curtin University, a Diploma of Financial Planning and a Diploma of Business/Management.

Stuart is also a Certified Financial Planner®, which is the highest professional designation that can be given to a financial planner. Stuart is an Authorised Representative (001242278) of Bennett Wealth Group Pty Ltd a Corporate Authorised Representative No. 348491 of Bennett Financial Services Pty Ltd. What advisory services are available to me?

Strategic financial advice and structuring Debt reduction strategies Wealth accumulation strategies Securities & investment advice Financial Planning strategies Superannuation & rollover advice Portfolio Management Retirement Planning Social Security advice Buying & selling shares Insurance and risk management advice Margin Lending & Gearing Mortgage Broking / Loan Refinancing Business Coaching

We provide advice on and deal in basic/non basic deposit, managed funds including Investor Directed Portfolio Services (IDPS), shares, debentures, standard margin lending, superannuation, retirement

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savings accounts (RSA) and insurance (risk & investment) products. When providing you with these advisory services, we act on your behalf. Product recommendations are only made after considering their suitability for your individual investment objectives, financial situation and needs and that they are included on our approved product list. We can provide regular reviews of your portfolio. If you choose to use this service, you will pay a fee that is tailored to your individual preference and circumstances. How will I pay for the service and what remuneration do you receive? Will I be advised of these?

Bennett Wealth Group is committed to ensuring that there is transparency in all fee arrangements and as such we seek client approval of fee arrangements (quote based) prior to providing our services. The quote will take into consideration both the time and complexity involved. The quoted fee is not based on funds you may invest as initial advice is generally only partially related to investing. Full disclosure will be provided to you within any provided SOAs, ROAs and Credit Quotes. Bennett Wealth Group generally offers a fee based approach. We may also receive some commissions as a result of insurance recommendations. Brokerage may also be received where share transactions are undertaken. Details of fees, commission and other remuneration arrangements are outlined under the Fee Arrangement section of this document. Where a fee is charged, you will be invoiced directly for the cost of the services provided. All other payments or incentives will be paid from the fund manager’s own resources. Bennett Financial Services collects fees and commissions from clients and product providers and retains a portion to cover the costs of providing the licensee services to and for Bennett Wealth Group. You have a right to request further information in relation to the remuneration received by Bennett Financial Services and Bennett Wealth Group. Business & Referral Arrangements

Bennett Financial Services Pty Ltd is not owned by any Fund Manager, credit providers or institution and

there are no relationships that will influence the advice that you receive from them.

Bennett Financial Services Pty Ltd has an alliance arrangement with Headspace Pty Ltd trading as Fitzpatricks Private Wealth. This arrangement provides us with access to support services in relation to research, portfolio construction and preferred pricing with some product issuers.

Bennett Wealth Group negotiate reduced fees and rates for clients, which are related to volume of business placed with relevant fund managers and credit providers, which in most cases we return directly to our clients. Where these apply to any recommendation we make to you, we will clearly state this at the time the advice is given. Bennett Financial Services Pty Ltd may from time to time receive a benefit from preferred product providers by way of sponsorship of educational seminars, conferences or training days. Details of benefits above $300 will be maintained on a register. Adviser remuneration is not linked nor related to specific investment recommendations but is related to company profits and individual performance. Your adviser may hold an interest in a financial product. Any significant interest/ownership will be recorded in a register of financial product holding and where appropriate, this holding will be disclosed to you in the SOA or ROA. Where we assist clients to obtain loans through our banking relationships we are often able to obtain cheaper interest rates or a commission that we can rebate to the client. We charge a fee for our work. We have access to the loan products of the major banks through providers such as MLC Mortgage Solutions, Westpac and Bankwest. Bennett Financial Services Pty Ltd has an alliance arrangement with Launch Finance Pty Ltd. This arrangement provides our clients with services in relation to finance and loan products. Launch Finance Pty Ltd may refer their clients to Bennett financial Services Pty Ltd under this arrangement. Bennett Wealth Group has negotiated a preferential fee arrangement with OzForex for its clients. Should you require this type of service we will introduce you to OzForex, as part of this arrangement Bennett Wealth Group will receive a referral fee. Details of the fee, introduction process will be provided should you be interested in this arrangement.

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W H E N Y O U G E T O U R A D V I C E Will you give me advice that is suitable to my investment needs and financial circumstances? Yes. However, to do so we need to find out your individual investment objectives, financial situation and needs before we recommend any investment to you. You have the right not to divulge this information to us, if you do not wish to do so. In that case, we are required to warn you about the possible consequences of us not having your full personal information. You should read the warnings carefully. We may also decline to provide you with our services if we do not have appropriate information. Loan Products - Is it appropriate for you? Before we can recommend a suitable loan package that would meet your requirements we must have a complete knowledge of your current financial situation, financial objectives and borrowing needs. As a credit licensee we are required to: Make reasonable inquiries about your financial

situation, and your requirements and objectives; Take reasonable steps to verify your financial

situation; and Make a preliminary assessment (for providing

credit assistance) or final assessment (if a credit provider) about whether the credit contract is ‘not unsuitable’ based on the inquiries and information obtained in the first two steps.

You can request for a written copy of the preliminary assessment within 7 years of the date of the credit assistance quote. Through our assessment and review process we aim to ensure that the credit contract is suitable for you. A credit contract may be unsuitable for you and would not be recommended if: You will not be able to maintain the credit

contract without substantial financial hardship; or

The credit contract does not meet your requirements or objectives.

What should I know about any risks of the investments or investment strategies recommended to me? We will explain to you any significant risks of investments and strategies that we recommend to you. If we do not do so, you should ask us for further clarification. What about your privacy? Bennett Wealth Group adheres to the Bennett Financial Services Pty Ltd privacy policy, which will ensure the privacy and security of your personal information. A copy of our privacy policy is included in this document. What information do you maintain in my file and can I examine my file? We maintain a record of your personal profile that includes details of your investment objectives, financial situation and needs. We also maintain records of any recommendations made to you. If you wish to examine your file, we will make arrangements for you to do so. As a financial service provider, we have an obligation under the Anti Money Laundering and Counter Terrorism Act to verify your identity and the source of any funds. This means that we will ask you to present identification documents such as passports and driver’s licence. We will also retain copies of this information. We assure you that this information will be held securely. Can I tell you how I wish to instruct you to buy or sell my investment? Yes. You may specify how you would like to give us instructions. For example by telephone, fax or other means. But in all cases we must receive a written confirmation of these instructions.

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Compensation Arrangements / Professional Indemnity Bennett Financial Services Pty Ltd confirms that it has arrangements in place to ensure it continues to maintain Professional Indemnity Insurance in accordance with s.912B of the Corporations Act 2001 (as amended) and s.48 of the National Consumer Credit Protection Act 2009. In particular our Professional Indemnity insurance, subject to its terms and conditions, provide indemnity up to the Sum insured for Bennett Financial Services Pty Ltd and our representatives in respect of our authorisations and obligations under our Australian Financial Services Licence and Australian Credit Licence. This insurance will continue to provide such coverage for any representatives who have ceased work with Bennett Financial Services Pty Ltd for work done whilst engaged with us. IF YOU HAVE ANY COMPLAINTS

Who can I speak to if I have a complaint about the advisory service? We are committed to providing quality advice to our clients. This commitment extends to providing accessible complaint resolution mechanisms for our clients. If you have any complaint about the service provided to you, you should take the following steps: 1. Contact your adviser and tell your adviser about

your complaint. 2. If your complaint is not satisfactorily resolved

within 7 days please contact Bennett Financial Services Pty Ltd on (08) 9274 2888 or put your complaint in writing and send it to us at 57 Adams Road, Red Hill WA 6056. We will try and resolve your complaint quickly and fairly.

3. If we cannot reach a satisfactory resolution, you can raise your concerns with the Financial Ombudsman Service on 1300 780 808. Bennett Financial Services Pty Ltd is a member of this complaints resolution service. For purposes of credit services provided, Bennett Wealth Group is also a member of the Financial Ombudsman Service.

4. The Australian Securities & Investments Commission (ASIC) also has a free call Infoline on 1300 300 630 which you may use to make a complaint or obtain information about your rights.

5. If your concerns involve unethical conduct, you may wish to consider raising these concerns with the Financial Planning Association of Australia (FPA). They can be contacted on 1300 337 301 or at PO Box 109 Collins Street West, MELBOURNE VIC 8007.

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Fee Arrangements As noted above, Bennett Wealth Group is committed to ensuring transparency in relation to all fee arrangements. We aim to achieve this through the following:

A written quote provided before work commences

Clients will approve the fee arrangements before the work is undertaken

All fees, commissions and other remuneration arrangements will be disclosed.

The following table outlines the various types of fees that may be applicable. Note that these fees are dependent on the actual services being provided to an individual client and are indicative only. We will provide a quote specific to your requirements and your approval will be sought before any work is undertaken.

Service/Activity

Fee Arrangement

Initial Financial Advice Process (3 parts)

1) Discovery Meeting

In this meeting we gather all necessary information for us to develop the “Terms of Engagement” document. This is generally a stimulating and thought provoking meeting where we identify your values, goals and objectives and develop a strong understanding of your current position. From this meeting, we prepare the Terms of Engagement document, and arrange our next “Engagement meeting”.

This meeting may be charged at the hourly rate of $330 or can be waived.

2) Engagement Meeting

During the engagement meeting, we run through the Terms of Engagement document and restate your current position and goals and objectives to ensure we have understood them correctly. This is vital to ensure we have the correct information as this forms the basis of the recommendations we will prepare for you.

During this meeting, we also provide an estimate of the cost for the Statement of Advice (SOA). This fee can range depending on the scope of advice and the complexity.

The initial fees generally fall into a range of $4,000 to $12,000 however sometimes they are more and sometimes they are less.

We generally require 50% of the quoted upper range of this fee upfront, before work commences. The balance is payable upon receipt of the Statement of Advice.

Upon receipt of the first 50% of the fee, work is then commenced on the SOA and the presentation meeting is arranged.

3) SOA Presentation Meeting

The third meeting is to present your SOA to you. The SOA remains the property of Bennett Wealth Group Pty Ltd until either a Fee Authority has been signed or the balance of the Statement of Advice fee has been paid.

Once you have reviewed the SOA and agree to take some or all of the advice, the Authority to Proceed (ATP) is then signed and any changes noted. This confirms that you wish for us to proceed with the recommendations. There will often be discussions that may result in minor changes to the recommendations, which should be documented on the ATP.

Balance of quoted fee is required.

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Special Project Fees

Periodically an existing client will have a “special project” which falls outside the work covered by the ongoing fee. For example a Redundancy, Estate Planning, Insurance work or management of an inheritance, which will require a special project SOA. In this case, an estimate of the costs involved is provided prior to the work being completed. Fees charged can vary depending on the scope of advice and the complexity.

The fee for this Special Project SOA is due 7 days after the presentation meeting is held or the document is posted.

Meeting Fees

Meetings are charged separately on an “as held” basis as each client requires a different amount of time.

Meetings are usually charged at a rate of $330 per hour including GST. Note: the Discovery Meeting, Engagement Meeting, Initial SOA Presentation Meeting and Initial Investment Recommendation meeting may be waived.

Ongoing Care

We provide ongoing management and review of our client’s financial affairs and for this we charge an ongoing fee. This fee covers the costs of facilitating your ongoing wealth generation and wealth management over the years of our relationship.

These fees charged will depend on the level of ongoing management, service, complexity. We also may change on a percent of you fund balance(s). Ongoing fees generally range from $2,000 to $40,000 per annum, however sometimes they are more and sometimes they are less.

Commissions on Insurance or other Products

We may receive commission from the product issuer we recommend to you. We may receive initial / upfront or ongoing / trail commissions from the recommendation of certain products or funds. In most cases, we are able to rebate this commission on a product level, meaning the payment is never made to us, either being once off or annual, however, in some cases, product providers do not allow this.

We may receive an upfront commission on insurance of between 0% and 130% of the first year’s annual premium, and then an annual ongoing commission of between 0% and 40% of the annual premium. For example, for an insurance product with an annual premium of $2,000, where the issuer pays us an upfront commission of 120%, we will receive $2,400. The issuer will pay us 10% of the annual premium as ongoing commission for as long as you hold the product. Assuming an annual premium of $2,000, this equates to $200 per year.’

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POINTS TO NOTE

All fees are paid directly to Bennett Financial Services Pty Ltd.

Part of these fees is retained to cover the costs of providing the licensee services and the remainder is forwarded to Bennett Wealth Group. Michael and Martin are directors and shareholders of Bennett Wealth Group and Bennett Financial Services Pty Ltd and as such are entitled to a profit share arrangement and distribution.

All fees are deducted from the relevant client account unless alternative arrangements are made i.e. direct debit or direct deposit.

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PRIVACY POLICY C O L L E C T I O N O F I N F O R M A T I O N

We are committed to providing you with the highest levels of client service. We recognise that your privacy is very important to you. The Privacy Amendment (Enhancing Privacy Protection) Act, 2012 sets out a number of Australian Privacy Principles (APPs). Our aim is to both support and ensure that we comply with these principles. Further information on privacy in Australia may be obtained by visiting the website of the Office of the Federal Privacy Commissioner at http://www.privacy.gov.au. As a financial planning organisation we are subject to certain legislative and regulatory requirements, which necessitate us obtaining and holding detailed information, which personally identifies you and/or contains information or an opinion about you (“personal information”). In addition, our ability to provide you with a comprehensive financial planning and advice service is dependent on us obtaining certain personal information about you, including:

Employment details and employment history;

Details of your financial needs and objectives;

Details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, insurance cover and superannuation;

Details of your investment preferences and aversion or tolerance to risk;

Information about your employment history, employment circumstances, family commitments, health issues and social security eligibility;

Tax file numbers and Australian Business Numbers; We are required, pursuant to the Corporations Act, National Consumer Credit Protection Act, certain regulations issued by the Australian Securities and Investments Commission and the Rules of Professional Conduct of the Financial Planning Association, of which this organisation is a member, to collect information about you for the purpose of providing you with financial planning services. If you do not provide us with the information requested by us, we may not be able to provide you with the services you require of us. We also collect information about you for the purpose of reporting to AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. USE AND DISCLOSURE

We will from time to time disclose information about you to authorised representatives of this firm and to other professionals such as insurance providers, superannuation trustees, product issuers and para-planning and client administration contractors in connection with the implementation of financial planning services. In the event we consider it necessary to use or disclose information about you for purposes other than those related to the provision of financial planning services or related purposes, we will seek your consent. We take our obligations to protect your information seriously, this includes when we operate throughout Australia and overseas, as part of our operations some uses and disclosures of your information may occur outside your State or Territory and/or outside of Australia. We utilise contractors based in Singapore to undertake para-planning and client administration on our behalf. Our marketing databases may also be located offshore but the content is limited to basic contact details. We will not collect any personal information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us. You have a right to refuse us authorisation to collect information from a third party.

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Although in certain circumstances we are required to collect government identifiers such as your tax file number, Medicare number or pension card number, we do not use or disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party. We will not use or disclose Personal Information collected by us for any purpose other than:

(a) The purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or

(b) Where you have consented to such disclosure; or

(c) Where the National Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.

We are required under the Rules of Professional Conduct of the Financial Planning Association of Australia to make certain information available for inspection by the Association on request to ensure ongoing compliance with mandatory professional standards. This may involve the disclosure of your personal information. We are also obliged pursuant to the Corporations Act to maintain certain transaction records and make those records available for inspection by the Australian Securities and Investments Commission.

From time to time, we may provide you with direct marketing material. This will include articles and newsletters that may be of interest to you. If, at any time, you do not wish to receive this information any further, you may contact us with this request. We will endeavour to meet your request within 2 weeks. We maintain a Register for those individuals not wanting direct marketing material.

In the event of that we propose to sell the business, we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them.

DOCUMENT STORAGE PRACTICES

Your personal information is generally held in your client file. Information may also be held in a computer database. We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential. In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in a secure off site storage facility for a period of 7 years in order to comply with legislative and professional requirements, following which time the information will be destroyed.

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WEBSITE

Our website provides links to third party websites. The use of your information by these third party websites is not within our control and we suggest you check the Privacy Policy of the linked website should you require any additional information relating to their Privacy Policy. Our website uses cookies to deliver content specific to Website visitors’ interests and to improve the convenience and efficiency of its clients’ experience when using its products and services. A cookie is a piece of data stored on the user's hard drive tied to statistical information about the user. Usage of a cookie is in no way linked to any personally identifiable information in our products and email messages. Visitors may choose to not accept cookies, but in doing so they may not be able to use some of the website's products and services. Some of our business partners, such as our Web analytics provider, also use cookies on our Website. These cookies are used to track visitor behavior and we have no access to or control over these cookies. This Privacy Policy covers the use of cookies by our website only and does not cover the use of cookies by any third parties. ACCESS TO YOUR INFORMATION

You may at any time, by contacting us, request access to your personal information and we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held. Some exceptions exist where we will not provide you with access to your personal information if:

providing access would pose a serious threat to the life or health of a person;

the request for access is frivolous or vexatious;

the information is related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;

providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;

providing access would be unlawful;

denying access is required or authorised by or under law;

providing access would be likely to prejudice certain operations by or on behalf of an enforcement;

denying access is required or authorised by or under law;

providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.

Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal. ACCESS AND CORRECTION POLICIES AND PROCEDURES

We will endeavour to ensure that, at all times, the personal information about you, which we hold is up to date and accurate. In the event that you become aware, or believe, that any Personal Information, which we hold about you is inaccurate, incomplete or out dated, you may contact us and provide to us evidence of the inaccuracy or incompleteness or out datedness and we will, if we agree that the information requires correcting, take all reasonable steps to correct the information.

Page 12: Sovereign Bridge Capital Group - Bennett Wealth Group · super, personal insurance, tax strategies and estate planning. is a Representative of Bennett Financial Services in addition

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This Financial Services Guide is issued with the authority of Bennett Financial Services Pty Ltd. Page No. 12

SPAM

Spam is a generic term used to describe electronic ‘junk mail’- unwanted messages sent to a person’s email account or mobile phone. In Australia, spam is defined as ‘unsolicited commercial electronic messages’. ‘Electronic messaging’ covers emails, instant messaging, SMS and other mobile phone messaging, but not cover normal voice-to-voice communication by telephone. We comply with the provisions of the Spam Act when sending commercial electronic messages. Equally importantly, we make sure that our practices are in accordance with the Australian Privacy Principles in all activities where they deal with personal information. Personal information includes our clients contact details. Internal Procedure for dealing with complaints

The three key steps we follow:

Consent – Only commercial electronic messages are sent with the addressee’s consent – either express or inferred consent.

Identify – Electronic messages will include clear and accurate information about the person who is responsible for sending the commercial electronic message.

Unsubscribe – We ensure that a functional unsubscribe facility is included in all our commercial electronic messages and deal with unsubscribe requests promptly.

Comply with the law regarding viral messages

We ensure that Commercial Communications that include a Forwarding Facility contain a clear recommendation that the Recipient should only forward the Commercial Communication to persons with whom they have a relationship, where that relationship means that person could be said to have consented to receiving Commercial Communications. Comply with the age sensitive content of commercial communication

Where the content of a Commercial Communications seeks to promote or inspire interaction with a product, service or event that is age sensitive, we take reasonable steps to ensure that such content is sent to Recipients who are legally entitled to use or participate in the product service or event COMPLAINTS RESOLUTION

We are committed to providing members, and other parties whose personal information we hold, a fair and responsible system for the handling of their complaints. If at any time you have any complaints in relation to privacy, please contact our Privacy Officer. We will seek to address any concerns that you have through our complaints handling processes, but if you wish to take matters further you may refer your concerns to the Office of the Federal Privacy Commissioner.

CONTACT US

If you seek any further information about this Statement or our privacy policy generally, please contact our Privacy Officer using the details below:

Postal Address: 57 Adams Road, RED HILL WA 6056

Telephone: (08) 9274 2888

Facsimile: (08) 9274 3388