Conflicts of Interest Policy - Effective 1 July 2014 to 23 July 2015

HARMONEY LIMITED

CONFLICTS OF INTEREST POLICY

Under the Financial Markets Conduct Act 2013 (Act) and the Regulations under the Act, Harmoney is required to have in place adequate systems and procedures for handling conflicts between the commercial interests of Harmoney (and its associated persons and entities) and the need for Harmoney to have fair, orderly, and transparent systems and procedures for providing its services.

This document is Harmoney’s conflict of interests policy, which forms part of the systems and procedures referred to above.

This document is in effect from 1 July 2014.

SUMMARY OF POLICY

Harmoney is part of the Harmoney group of companies, which provide certain aspects of the services which are offered by Harmoney through the Harmoney website at www.Harmoney.co.nz. In addition, certain Harmoney group companies, Harmoney itself, and Harmoney’s associated persons and entities may use the Harmoney services for their own benefit.

In order to ensure that all persons dealing with Harmoney and its associated persons and entities are fully informed about the way in which Harmoney delivers the services, and the involvement of the Harmoney group of companies and their associated persons and entities in the provision and use of the Harmoney services, Harmoney has implemented this policy.

APPLICATION OF POLICY

This policy applies to:

  • all companies in the Harmoney group from time to time.
  • all shareholders in each Harmoney group company
  • all directors of each Harmoney group company
  • each employee of each Harmoney group company

Each of these persons and entities is referred to in this policy as a relevant person.

DISCLOSURE OF CURRENT INTERESTS

With effect on the date of this policy, the following disclosures are made of current interests:

  • Harmoney Limited pays a fee to Harmoney Systems Limited to use the platform IP and licences.
  • Harmoney Limited pays a fee to Harmoney Services Limited for the provision of support and administration services.

RESTRICTIONS ON USE OF THE HARMONEY SERVICES

Any shareholder, director or employee who wishes to use any of the services provided by Harmoney:

  • must do so on the same terms as any other user of the service; and 
  • must not use any knowledge that person has of the Harmoney business, operations or services to create for him or her any benefit or advantage which is not otherwise available to any other user of that service.