This document sets out the processes we have in place to ensure the fair dealing requirements of the Financial Markets Conduct Act 2013 are upheld (Policy).

Introduction

Terms defined in the Terms and Conditions (defined below) shall have the same meaning in this Policy, unless inconsistent with the context or otherwise specified. This Policy forms part of the

Blossum Documents

Prohibited Conduct means a person who, in relation to the Service:

(a) engages in misleading or deceptive or likely to mislead and deceive conduct;

(b) makes false or misleading representations; or

(c) makes an unsubstantiated representation; in a manner that breaches sections 21, 22 or 23 of the FMCA. Terms and Conditions means the Blossum terms and conditions of service available on www.blossum.nz.

Our Commitment

We are committed to having effective processes and systems in place to conduct background checks on Borrowers and Investors, including verifying the Borrower’s/Investor’s identity and assessing the Borrower’s complete financial information. The purpose of this Policy is to prevent persons from using the Service if they engage in Prohibited Conduct.

Process We perform these checks by:

(a) Conducting credit checks.

(b) Performing checks using our systems and our staff will also perform checks to ensure compliance. Blossum may outsource some checking and verification tasks, such as compliance with the Anti-money Laundering and Countering of Financing of Terrorism Act 2009.

When our system and credit checks flags information that may be misleading or is inconsistent with what the Borrower or Investor has told us, then a Blossum staff member will manually check such information to ensure that the Borrower or Investor is not engaged in Prohibited Conduct.

Engaging In Prohibited Conduct

If a Borrower or Investor is found to have engaged in Prohibited Conduct then we will take all the necessary steps to:

(a) restrict that person from accessing the Platform;

(b) prevent that person from investing on the Platform; or

(c) borrowing. In the event:

(a) a Borrower with an existing Loan engages in Prohibited Conduct, we will require immediate repayment of that Loan. (b) an Investor, that has already invested through the Platform, engages in Prohibited Conduct, such investment may be immediately returned to the Investor minus any fees that may be payable. The return of investment in these circumstances may be dependant on Blossum Trustee receiving the relevant amount from the Borrower.