Legal Conflicts of Interest Policy

Conflicts of Interest Policy

Harmoney Limited

Effective from 24 July 2015

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.

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 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.

Disclosure of current interests

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

Harmoney, its related companies, and their directors, shareholders and employees are not entitled to use the Harmoney services as Borrowers.

Harmoney, its related companies, and any of their directors, shareholders, employees and advisers (in their own capacities) may use the Harmoney services as Investors at any time, but only if he, she, or it:

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

The above restriction, does not prevent Harmoney and its related companies from receiving commission or other financial benefit from any person in connection with providing the Harmoney service or any loan.