Fair Dealing Policy

Under the Financial Markets Conduct Act 2013 (Act) and the Regulations under the Act, Fifo Capital is required to have in place a fair dealing policy. This document is Fifo Capital’s fair dealing policy.

Summary of Fair Dealing Policy

Fifo Capital has in place specific processes and procedures for the purpose of verifying the identity of the Client, and for assessing the creditworthiness of the Client.

For a person to apply as a Client, that person must:

• provide to Fifo Capital all information which Fifo Capital requires, as set out in the application process on the Fifo Capital website at www.fifocapital.co.nz;
• be otherwise acceptable to Fifo Capital at Fifo Capital’s absolute discretion.

Fifo Capital reserves the right at any time to:

• not accept and take-on any person as a Client;
• restrict the activities of any Client except when prohibited according to the executed Deed of Trust,
• where Fifo Capital believes or has cause to believe that the relevant person or Client has, in relation to the Fifo Capital service or application process or otherwise:
• engaged in conduct that is misleading or deceptive or likely to mislead or deceive;
• made a false or misleading representation in contravention of section 22 of the Act;
• made an unsubstantiated representation in contravention of section 23 of the Act; or
• has otherwise been in breach of any of the terms under which Fifo Capital provides any service or access to its website at www.fifocapital.co.nz.

Application of the Fair Dealing Policy

Fifo Capital implements its fair dealing policy with a combination of automated and manual checks. During the automated approval process some process rules can pick up anomalies and inconsistencies in information provided and can decline the Client.

Fifo Capital’s customer service and collections staff are trained to identify deceptive and misleading conduct and report it to Fifo Capital management for investigation and possible reporting to the relevant authorities.