Accument Pty Ltd
Financial Services Guide and Privacy Policy
ABN 90 613 345 556
Corporate Authorised Representative No. 1266283
Date of preparation 1 July 2021
Version: 2106A
Australian Financial Services Licensee IWM Advisors Australia Pty Ltd
ABN 38 133 517 021
Australian Financial Services License No. 343582
Purpose
This Financial Services Guide (FSG) is an important disclosure document, providing you with information about IWM Advisors Australia Pty Ltd (IWM) and Accument Pty Ltd (Accument).
It is designed to inform you of the financial services we offer, how we are remunerated and information on how we deal with complaints.
Services that we provide
Accument provides services to wholesale and retail clients via subscription to its website. These services include:
● Information about Exchange Traded Funds listed on an Australian stock market,
● Commentary and ratings in respect of those funds,
● General advice only. This means it is advice that does not consider your personal objectives, financial situation or needs. Before acting on general advice you should consider the appropriateness of the advice having regard to your situation.
Accument is authorised to advise and deal in the following classes of financial products to retail and wholesale clients:
● Deposit and payment products
● Government debentures, stocks or bonds
● Managed Investment Schemes, including Investor Directed Portfolio Services
● Securities
How you pay for our services
Clients of Accument are charged a subscription fees for the services we provide, currently those fees are:
● Subscription of $0 per month or $00 per year.
Accument may also provide tailored products to clients at a negotiated fee.
Accument’s employees receive a salary and may also be entitled to receive a performance bonus in monetary form.
You have the right to request further information in relation to the remuneration, the range of amounts or rates of remuneration, and soft dollar benefits received by Accument and IWM.
Associations and relationships
Accument is a Corporate Authorised Representative of IWM. Services are provided by Accument on behalf of IWM. IWM holds Australian Financial Services License Number 343582, allowing its Representatives to provide services outlined in this Financial Services Guide. IWM authorises the distribution of this Financial Services Guide.
Accument is wholly owned by the family of the Directors of Accument and IWM.
If you have been referred to Accument by a third party, IWM and Accument do not pay a referral fee to that third party.
How we deal with conflicts of interest
Accument seeks to deal with the possibility of a conflict of interest by ensuring the following:
· Remuneration: Accument provides services to wholesale clients and retail clients via subscription to its website. Accument may also receive fees for providing investment consulting services to clients. Investment consulting services include but are not limited to provision of advice in relation to managed accounts, model portfolios and approved product lists. Fees charged in relation to investment consulting services may be flat fees or asset based fees. The fees for some consulting arrangements may be determined by private agreement and take into consideration the overall depth and complexity of services provided. No fees charged are linked to any Accument ratings outcomes or the inclusion of financial products in portfolios or approved product lists. Accument also ensures that any discussions relating to remuneration occurs with appropriate information barriers in place.
· Communication : Accument ensures that relevant information is not communicated outside Accument before ratings are published. While fund issuers may be permitted to check draft reports for factual accuracy under controlled circumstances, recommendations or opinions contained within such reports are not provided.
· Approval process: Research quality and integrity is maintained by ensuring all research is approved by peer groups and authorised by experienced supervisors.
· Material interests: Directors and employees generally do not have a material interest in any of the financial products on which it provides investment research. Should Accument, its Directors or staff have a material financial interest in such a product, the following processes will apply; mandatory disclosure of these interests in the relevant report, adherence to staff trading windows, declining to provide investment research or exclusion of any individuals with a material interest from the research process.
· Associations or Relationships: Accument has no related party or other association links with product issuers or fund managers. Conflict management arrangements are in place where Accument provides research services to financial advisory businesses that provide financial planning services to investors and are also associated entities of product issuers.
Professional indemnity insurance
IWM and Accument hold and will take reasonable steps to maintain Professional Indemnity Insurance cover. This cover complies with our obligations under section 912B of the Corporations Act relating to breaches of IWM’s Australian Financial Services Licence obligations by both current and former representatives and staff.
IWM and Accument and associates (including our insurer) cannot guarantee the capital, investment returns or success of the services and products provided.
Complaints
We are committed to providing our clients with the highest standards of service. Should you have a complaint, we have procedures to ensure that your issue receives due consideration and is dealt with appropriately.
If you have a complaint about the service provided to you, please take the following steps:
1. Contact Accument immediately and explain the complaint.
2. If your complaint is not satisfactorily resolved within five working days, request a Complaint Reports Form and send it to us at:
Complaints Officer
IWM Advisors Australia Pty Ltd
PO Box 6082, Chapel Street North LPO
South Yarra Victoria 3141
1. The Complaints Officer will try and resolve your complaint.
2. Our Complaints Officer will look after your complaint and will keep you informed about it. The Complaints Officer may need to contact you for more information to assist in the resolution process.
3. If you still do not receive a satisfactory outcome within 30 days and you wish to take your complaint further you can contact the external dispute resolution body, Australian Financial Complaints Authority, of which we are a member:
Mail: GPO Box 3, Melbourne Victoria 3001
Phone: 1800 931 678 (free call)
Online: www.afca.org.au
Email: info@afca.org.au
For further information about your rights you can contact the Australian Securities and Investment Commission by telephone on 1300 300 630.
Privacy Policy
The privacy of our clients and their personal information is an important issue for IWM Advisors Australia Pty Ltd and Accument (We) .
The Privacy Amendment (Enhancing Privacy Protection) Act 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.
Collection of information
We collect personal information in a number of ways, primarily when you provide information during our online sign up process, through a data collection form or by phone or email. The information that we collect may include;
● Your name and contact information,
● Credit card information.
Without your consent we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or criminal record. This is subject to some exceptions including where the collection is required by law; and when the information is necessary for the establishment, exercise or defence of a legal claim.
Where you provide us with information about another person, you must ensure that they are aware information has been provided to us and of the existence of this document.
Use and disclosure
We may disclose your personal information to organisations outside IWM Advisors Australia Pty Ltd. The organisations to which we disclose information may include:
● compliance consultants to ensure that we are meeting our compliance standards;
● paraplanning contractors or temporary staff to handle workloads during peak periods;
● mailing houses;
● your professional advisers, including your solicitor or accountant as authorised by you;
● information technology service providers to maintain, review and develop our business systems, procedures and infrastructure including testing or upgrading our computer systems;
● Government and regulatory authorities and other organisations, as required or authorised by law, for example, to government or regulatory bodies for the purposes related to public health or safety, the prevention or detection of unlawful activities or to protect public revenue.
● another representative of IWM Advisors Australia Pty Ltd if necessary;
● a potential purchaser/organisation involved in the proposed sale of our business for the purpose of due diligence, corporate re-organisation and transfer or all or part of the assets of our business.
● Any specified party where you have given your express consent to provide information to that party.
These organisations will be required to maintain confidentiality.
Please note that we also may use your information where it is related to the primary purpose of your engagement and it is reasonable for you to expect the information to be disclosed.
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. We may only use sensitive information about you for direct marketing once we have obtained your consent. If, at any time, you do not wish to receive this information, you may contact us with this request.
Quality of information
We will make every effort to ensure that the personal information we collect is accurate and complete. However we will rely on you informing us if your personal details change.
Security of information
IWM Advisors Australia Pty Ltd takes its obligations to protect your information seriously, this includes where 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. In some circumstances we may need to obtain your consent before this occurs.
Accument holds some personal information in Amazon Web Services (AWS) data centres. These data centres may be located in the USA.
We will take reasonable steps to protect the personal information we hold from misuse, loss, and from unauthorised access, modification or disclosure. Where your personal information is no longer needed, and we are not required by law to maintain it, we will ensure that it is securely and permanently destroyed.
Website
Our website uses cookies to provide you with a better user experience. Cookies also allow us to identify your browser while you are using our site – they do not identify you. If you do not wish to receive cookies, you can instruct your web browser to refuse them.
Access to personal information
You may at any time request access to your personal information that we hold. We will endeavour to comply with your request as soon as possible, which would normally be within a period of 14 days. In most cases there will be no charge for providing such information; however requests involving large amounts of information may incur a fee.
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;
● providing access would have an unreasonable impact on the privacy of others;
● 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 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.
You may request in writing a copy of any advice document up to seven (7) years after the advice has bee given.
Please contact our Privacy Officer if you wish to complain about any breach or potential breach of your privacy rights. Your complaint will be addressed within 7 days . If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Privacy Commissioner.
Privacy Officer
IWM Advisors Australia
PO Box 6082
Chapel Street North LPO
SOUTH YARRA VIC 3141
Office of the Australian Information Commissioner
enquiries@oaic.gov.au
GPO Box 5218
Sydney NSW 2001
Contact Details
IWM Advisors Australia Pty Ltd
ABN 38 133 517 021
Australian Financial Services License No. 343582
Accument Pty Ltd
ABN 90 613 345 556
Authorised Representative No: 1266283
Office Postal
Level 2, 7 River Street PO Box 6082
South Yarra Victoria 3141 Chapel Street North LPO
South Yarra Victoria 3141
Telephone (03) 9005 4740
Email: contact@accument.com.au Web: www.accument.com.au