Disclosure Statement

September 2024

Our licence information

JMI Wealth Limited (‘JMI’, ‘we’, ‘us’) holds a Financial Advice Provider (‘FAP’) licence issued by the Financial Markets Authority (‘FMA’) in accordance with the Financial Markets Conduct Act 2013 (‘FMCA’) to provide financial advice services in New Zealand. JMI gives this FAP disclosure in accordance with the FMCA and its regulations. As a FAP licence holder, we provide financial advice services through our employees who are Financial Advisers (‘Advisers’).

Our Financial Service Provider Registration number is FSP93061. This Disclosure Statement provides you with important information about the services we offer, which should help you decide whether to choose us to provide you with financial advice.

What types of products do we provide Financial Advice for?

We provide advice on a wide range of investment products including, direct New Zealand and Australian equities, New Zealand bonds, foreign exchange, Managed Investment Schemes (including Clarity and Devon Funds) and KiwiSaver (including JMI Wealth KiwiSaver Scheme).

What fees will you pay?

We charge a fee for the financial advice and monitoring service that we provide. This fee will be based on your funds under advice and is typically calculated on a percentage basis. This could be up to 1.25% p.a. JMI may also charge an implementation fee for the advice provided. In all cases, fees charged for financial advice and implementation will be agreed with you beforehand and set out in your Investment Proposal.

Once fees are agreed, you have the option to be invoiced directly for fees or have them deducted from your custodial account. If you choose to be invoiced directly, payment is due by 20th of the following month.

There may be other charges when we invest your money, for example: brokerage and foreign currency fees. We will discuss and agree these with you at the time and capture them in your Terms of Engagement.

Our conflicts of interest, commissions and other incentives

JMI, Clarity Funds Management Limited (Clarity), TAHITO Limited(TAHITO), Select Wealth Management Limited (Select) and Devon Funds Management Limited (Devon) are wholly owned subsidiaries of the Investment Services Group Limited (ISG).

Clarity is the licenced manager of the Clarity Funds Scheme and the Daintree Funds Scheme. Devon is the licenced manager of the Devon Investment Funds. Select is the licenced manager of the Select Discretionary Investment Management Service (DIMS) and distributor of the JMI Wealth KiwiSaver Scheme. JMI are the investment manager for the Select DIMS portfolios and the JMI Wealth KiwiSaver Scheme. JMI Advisers are distributors and promoters of ISG products.

If we recommend that you invest in a financial product or service managed by an ISG related party, any fees generated will be a benefit to the licenced manager and ultimately ISG. All fund and portfolio fees are specified in the relevant Product or Service Disclosure Statements and paid to the respective licenced managers.

Our Advisers are employees paid a base salary with potential for a bonus. Individual product recommendations to clients do not affect their salary, but may result in an increase to funds under advice and advice fee revenue. To be eligible for a bonus all Advisers must be able to show how they have complied with their duties under FMCA.

Our Advisers may from time to time recommend an investment purchase. For example, a new product issue. New product issues may result in JMI receiving a commission from the product provider. We will present this to you in writing to help you make your decision.

We have frameworks in place to manage these conflicts of interest and any others that may arise which include:

• Our Advisers follow an advice process that ensures each client's interests are prioritised, their objectives and needs are identified, and recommendations of financial products are made based on those objectives and needs.
• We disclose and explain any perceived or potential conflicts of interest to each of our clients before providing financial advice to that client.
• We have a conflicts of interest policy, maintain a conflicts of interest register and provide staff with regular updates and training.

What can you do if you are unhappy with any part of the service?

If you are not satisfied with any part of our service, please tell us so that we can try to fix the problem. You can contact us at [email protected] or via the contact us page on our website. You can also call us on 0800 990 055 or send a letter to PO Box 33 1106, Takapuna, Auckland 0740.

When we receive a complaint, if we cannot resolve it immediately, we will:

1. Let you know we have received the complaint within 2 business days.

2. Ensure that the complaint receives proper consideration.

3. Act in good faith in dealing with the complaint.

4. Work with you to obtain all relevant information to investigate the complaint.

5. Let you know what the outcome is as soon as practicable.

All complaints are logged and reviewed overtime to help us improve our service.

If we cannot agree on how to fix the issue, you can contact the Insurance and Financial Services Ombudsman Scheme, our external disputes resolution scheme provider. Contact details are:

	Insurance and Financial Services Ombudsman Scheme
Address:	PO Box 10-845 Wellington 6143
Phone:	0800 888 202
Email:	[email protected]
Website:	www.ifso.nz

This service is independent of JMI and ISG and will cost you nothing.

What are our duties when providing Financial Advice to you?

In providing you with financial advice our Advisers are bound by the Code of Professional Conduct for Financial Advice Services. We also have duties under the FMCA where we are required to:

• Give priority to your interests by taking all reasonable steps to make sure our advice is not materially influenced by our own interests.
• Exercise care, diligence, and skill in providing you with advice.
• Meet standards of competence, knowledge and skill set by the Code of Professional Conduct for Financial Advice Services (these are designed to make sure that we have the expertise needed to provide you with advice).
• Meet standards of ethical behaviour, conduct and client care set by the Code of Professional Conduct for Financial Advice Services (these are designed to make sure we treat you as we should and give you suitable advice).

This is only a summary of the duties that we owe you. More information is available by contacting us, or by visiting the Financial Markets Authority website at www.fma.govt.nz.

A hard copy of this disclosure statement can be obtained on request by calling us on 0800 990 055 or contacting us at [email protected].