Gembroker Transparancy Statement v0.1

Background

Gembroker is an online brokerage platform facilitating the trading of US equities and ETFs for New Zealand residents. Operational since May 25, 2022, our Platform offers both web dashboard trading and advanced systematic investment technology through our affiliated entity, Gembot Limited.

Nature and Scope of Our Services

Registered as a Financial Services Provider under the oversight of the Financial Markets Authority, Gembroker offers services encompassing the management of money, securities, investment portfolios, and operates a money or value transfer service. Our commitment to regulatory compliance is steadfast, ensuring adherence to industry rules.

At Gembroker, it's essential to clarify what we do not provide to manage expectations transparently. We do not offer personalised financial advice to our users. While our platform equips users with powerful tools for self-directed investing, we refrain from making specific recommendations tailored to individual financial situations. Our services are designed to facilitate informed decision-making, but users should note that we do not engage in activities such as managing money on their behalf or providing comprehensive financial, taxation, or legal advice.

Furthermore, we do not guarantee any specific investment outcomes, and users are encouraged to exercise their judgement and seek independent professional advice for their unique financial circumstances. Our commitment lies in empowering users with the necessary tools and information to make their investment decisions autonomously, emphasising the importance of personal responsibility in financial choices.

In Plain Language: We adhere strictly to regulatory standards and expect the same from all our users. Additionally, we do not provide financial advice.

Limitations on Nature and Scope of Our Services

Gembroker presently does not provide financial advice. Our tools empower users for self-directed investing at a cost-effective level, allowing them to make informed decisions. The Platform's functionalities include grouping assets and scheduling orders as per user requirements.

In Plain Language: We offer tools for self-directed investing; however, no financial advice is provided.

Fees and Expenses

Gembroker charges fees for specific services, clearly outlined on our Pricing Page. From stock and ETF trade fees to a subscription offering (Gembroker Plus), all applicable fees are transparently communicated to avoid any surprises.

In Plain Language: We are upfront about our fees, ensuring transparency in all transactions.

Our current fee schedule is as follows:

• Stock and ETF Trade Fees - 0.4% maximum with fees as low as 0.2%
• Interest on Cash Balances - A 50/50 revenue share with Alpaca
• Payment for Order Flow - Ac50/50 revenue share with Alpaca
• Spread on Crypto Transactions 0.75% - a 50/50 revenue share with Alpaca
• Foreign Exchange for $NZD Deposits and Withdrawals - 1% - a 50/50 revenue share with Wise.com
• Subscription offering for Gembroker Plus which enables users access cheaper transactions and other premium services and features

Conflicts of Interest, Commissions or Other Incentives

Gembroker's affiliations, including being wholly owned by Maddition Limited and utilising Gembot Limited's technology, are transparently disclosed. Alpaca Securities LLC, our broker-dealer partner, provides the trading infrastructure.

In Plain Language: We maintain transparency in all aspects, and if any conflicts arise, we will communicate promptly.

Complaint Handling and Dispute Resolution

If for any reason you are not satisfied with our financial services, you should notify us directly in the first instant via email [email protected].

If the matter is not resolved to your satisfaction, or you do not wish to raise it with us directly, you can make a complaint through the following channels:

• By mail at [email protected]
• In writing to the Complaints Manager, Gembroker NZ Limited, Level 8, 23 Customs Street East, Auckland 1010
• In person at our office
• Or by telephone 0212236249 to our Complaints Manager

All complaints received will be considered in accordance with our internal complaints handling process.

We will acknowledge receipt of the complaint within 2 working days of receipt.

Ae will aim to respond to your complaint at the earliest possible time, but no later than 14 working days from receipt of such a complaint.

To facilitate the effective investigation, we may reach out directly to you to seek additional information.

We will contact you via email or in writing to let you know the outcome of our investigation into your complaint.

If we cannot resolve your complaint, or if we fail to provide you with a reasonable response within 40 working days of your lodging the said complaint, you can contact Financial Dispute Resolution Service, a Financial Ombudsman Service and our external independent dispute resolution provider.

Financial Dispute Resolution Service provides a free, independent dispute resolution service that may help investigate or resolve any retail client’s complaint where we have not been able to resolve the complaint to your satisfaction.

You can contact Financial Dispute Resolution Service by:

Emailing [email protected]

Calling (locally) 0508 337 337

Calling (international) +64 4 381 5047

Completing a complaint form on their website here: https://fdrs.org.nz/complaints/make-a-complaint/

You can also write to them at: FDRS, Free Post 231075, P O Box 2272, Wellington, 6140, New Zealand.

In Plain Language, we have a very simple complaint escalation and resolution process with independent parties involved. Should you not be happy with our processes, you are most welcome to escalate this with the Financial Ombudsman Services at any time.