Legal

Conflict of Interest Policy

We are required by the Financial Markets Conduct Act 2013 to do all things necessary to ensure that the Service we provide is fair, orderly, and transparent (Our Obligation).

In order to meet Our Obligation, we have implemented certain processes to help us manage any conflicts of interest which are set out in this document (Policy).

Introduction

In this Policy terms defined in the Terms and Conditions shall have the same meaning in this Policy unless inconsistent with the context or otherwise specified. This Policy forms part of the Blossum Documents.

Conflicts of Interest means any conflict between the commercial interest of a Blossum Group Affiliate and Our Obligation;

Conflicted Interest means when a Blossum Private Wealth Trust Limited Affiliate uses the Service as an Investor or a Borrower (or otherwise) which gives rise to a Conflict of Interest; and Terms and Conditions means the Blossum terms and conditions of service available on www.blossum.nz.

Handling Conflicts of Interest

As part of Our Obligation, we will:

(a) monitor the usage of the Service for any Conflicts of Interest.
(b) ensure that full disclosure has been given to all persons (Authorised Users or otherwise) that use our Service of any Conflicts of Interest (Disclosure);
(c) enforce Our Obligation on all Blossum Private Wealth Trust Limited Affiliates and ensure all Blossum Private Wealth Trust Limited Affiliates are aware of the obligations imposed by this Policy;
(d) not permit any person with a Conflicted Interest to use the Service unless Disclosure has been given first; and
(e) enforce any measures necessary to prevent a Conflicts of Interest from arising.

Exceptions

The Service may be used by a Blossum Private Wealth Trust Limited Affiliate as an Investor if:

(a) such use is on the same terms as any other Investor; and
(b) the knowledge that Blossum Private Wealth Trust Limited Affiliate has in respect of Blossum, the Service, the Platform or otherwise is unlikely to result in an unfair advantage or gain over other Authorised Users that do not have access to the same knowledge.

Current Disclosures

In accordance with this Policy, we make the following Disclosures:

(a) we are registered as an Investor on the Platform; and
(b) we may choose fund a Loan (either in full or in part);
(c) if a Borrower is experiencing unforeseen hardship (or at risk of experiencing unforeseen hardship), the Loan Agreement may be assigned to a Blossum Private Wealth Trust Limited Affiliate. All amounts owing under the Loan upon the date of assignment shall be paid by that Blossum Private Wealth Trust Limited Affiliate;
(d) we may (as determined at our discretion) assign any Loan to a Blossum Private Wealth Trust Limited Affiliate and refund all Investors under that Loan; and
(e) the Blossum Private Wealth Trust Limited is entitled to receive commission arising in connection with the Service.