CROSS BORDER PAYMENTS FINANCIAL SERVICES GUIDE

The financial services described in this document are offered by Novatti Trading FX Pty Ltd (ACN 645 493 161) (“Novatti Trading FX”) and Flexewallet Pty Ltd (“Flexewallet”) (ACN 164 657 032) (“Flexewallet”)(together, “Novatti”, “we”, “us”) pursuant to intermediary authorisation agreements in place between Novatti and Aurora Capital Markets Pty Ltd (“Aurora”) (ACN 165 534 958) (AFSL No. 490749) and in line with Flexewallet’s AFSL (AFSL No. 448066). Aurora and Flexewallet have authorised the distribution of this Financial Services Guide (FSG).

A copy of this FSG is available for download from our website www.novattixb.com. If you have any questions about any part of this FSG, please contact us by phone at +61 03 9013 0066 or by email at [email protected].

Effective Date: 5/01/2022

Version No: 1.1

PURPOSE

This FSG is issued by Novatti Trading FX pursuant to an intermediary authorisation agreement in place with Aurora for the FX component of the product and by Flexewallet for the non-cash payment facility component of the product.. The purpose of this FSG is to help our clients decide whether to use any of the services we offer. This FSG provides important information about:

1. Who we are and how to contact us.
2. The products and services we are authorised to offer.
3. How to provide us with instructions.
4. Who we act for.
5. Our relationships to other entities.
6. Remuneration, commission and benefits received and paid by us.
7. Any relevant conflicts of interest we may have.
8. Our dispute resolution procedure.
9. Compensation arrangements.
10. Our privacy obligations.
11. The documentation we will provide to you.
12. Our record-keeping obligations.
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1. WHO WE ARE AND HOW TO CONTACT US

Any financial services offered are provided by Flexewallet and Novatti Trading FX. Novatti Trading FX provides FX related financial services and Flexewallet provides financial services in connection with non-cash payment facilities. You can contact us at:

Novatti Trading FX Pty Ltd
Address: Level 3, 461 Bourke Street, Melbourne, VIC, 3000
Telephone: +61 03 9013 0066
Email: [email protected]
Website: www.novattixb.com

Flexewallet Pty Ltd
Address: Level 3, 461 Bourke Street, Melbourne, VIC, 3000
Email: [email protected]
Website: www.flexewallet.com

2. PRODUCTS AND SERVICES WE ARE AUTHORISED TO OFFER

Australian Financial Services Licence (“AFSL”)
Novatti is an Authorised Representative (AR No. 001289459) of Aurora Capital Markets Pty Limited (ACN 165 534 958) (“Aurora”), who hold an Australian Financial Services Licence (AFSL No. 490749).

Under Aurora’s AFSL, Novatti is authorised to:

• Provide general financial product advice for derivatives, foreign exchange contracts and securities; and
• Deal in a financial product:
  • by issuing, applying for, acquiring, varying or disposing of derivatives and foreign exchange contracts; and
  • applying for, acquiring, varying or disposing of a financial product on behalf of another person in respect of derivatives, foreign exchange contracts and securities.

to retail and wholesale clients.

Under Flexewallet’s AFSL, Flexewallet is authorised to:

• Provide general financial product advice for deposit and payment products limited to non-cash payment products; and
• Deal in a financial product by:
  
  • Issuing, applying for, acquiring, varying or disposing of a financial product in respect of deposit and payment products limited to non-cash payment products.

to retail and wholesale clients.

Financial Services Provided
We provide the following services:

• Online foreign exchange transactions.
• Non-cash payment facilities in the form of Wallets and Global Accounts.
• General advice in relation to foreign exchange transactions and non-cash payment facilities.

Types of Products

We are authorised to deal in and provide general advice in relation to the following products;

1. Foreign exchange spot contracts (which must be settled within 48 hours).
2. Non-cash payment facilities.

Please refer to our PDS (available at www.novattixb.com) for more information about how our products operate.

It is important to understand that we are not a bank. All funds represented in your account will be collected and pooled with funds of other clients of ours in one or more segregated client accounts with a licenced bank in the UK (Barclays) by a third party provider (Currencycloud). These funds will be held separately from our funds.

General Advice Only

We provide general information in relation to foreign currency transactions. We can provide you with verbal advice about how deliverable foreign exchange transactions work. None of the information we provide to you, either on our website, via email or over the phone, will take into account your personal financial circumstances and needs. You will always need to exercise your own judgement and should obtain independent financial advice in relation to your specific financial requirements, including any tax implications. Additional information about our products and the potential benefits and risks of using our services are contained in our Product Disclosure Statement (PDS) located on our website (www.novattixb.com). You should read the PDS before making any decisions about using our services.

3. PROVIDING US WITH INSTRUCTIONS

Before you can use our services, you need to register by completing and returning the onboarding form. You will be required to review and agree to a number of documents and provide us with information which will allow us to verify your identity. If we approve your account, you will then be able to use our services.

If you would like to use our services, you must provide us with instructions online via our website.

4. WHO WE ACT FOR

We act on your behalf for the purpose of executing the Transactions you provide us Instructions for. We may, from time to time, also act as principal and enter into foreign exchange Transactions on our own behalf.

5. OUR RELATIONSHIPS WITH OTHER ENTITIES

Aurora Capital Markets Pty Limited
Novatti Trading FX Pty Ltd is an Authorised Representative of Aurora Capital Markets Pty Limited (ACN 165 534 958) who hold an Australian Financial Services Licence (AFSL No. 490749).

You can contact Aurora at:
Address: Level 41, 55 Collins Street, Melbourne, Victoria 3000
Telephone: 1300 000 002
Email: [email protected]
Website: www.auroramarkets.com.au

Currencycloud
We use Currencycloud to provide our services. We use Currencycloud’s platform to process transactions. Currencycloud holds all money in your Wallet, including your available balance, in a separate bank account to their business accounts.

Barclays
Barclays Bank UK PLC. (Registration No: 9740322) (“Barclays”) is authorised by the Prudential Regulation Authority in the UK and is regulated by the Financial Conduct Authority and the Prudential Regulation Authority (Financial Services Register number: 759676). Barclays provides Currencycloud with segregated bank accounts to hold customer funds.

6. REMUNERATION, COMMISSION AND BENEFITS

Transaction Fees

You will be charged a transaction fee per transaction. The fee varies depending on the currency you are converting to and the method of sending the funds (e.g. SWIFT or local currency).

We do not charge you an additional amount for third party Transaction fees. They are built into our Margin. However, in some cases, the intermediary banks we use to process payments may deduct Transaction fees that we have not anticipated. For example, in some jurisdictions, the receiving bank charges a receiving bank fee. We will try to notify you of these additional fees if we are aware of them, but we cannot always do so in advance. As a result, you may find, in some cases, the total amount received in the Beneficiary Account is less than expected because such fees have been deducted. You should bear this in mind if you are paying the precise amount of an invoice. You can contact us if you have any questions regarding the likelihood of third-party Transaction fees being levied by intermediary banks for your Transaction.

We reserve the right to amend the Payment Services Transaction Fees by giving you no less than thirty (30) days’ prior written notice. Such amendments to the Payment Services Transaction Fees will become effective on the date specified in the written notice.

Our Remuneration Generally
In relation to all Transactions, we make a profit on the transaction based on the difference between the rate quoted to you and the rate we can negotiate with our own providers. This profit is known as the “Margin”. The Margin will vary according to the currencies involved and the arrangements we enter into with our providers from time to time.

How our Employees are Paid
All of our employees receive a salary, superannuation and various benefits. Some employees may be entitled to commission or bonuses based on their performance.

How Aurora is Paid
We pay Aurora a monthly fee in order to be listed as an Authorised Representative of Aurora.

How Currencycloud is Paid
We pay Currencycloud a monthly fee in order to use their services.

Introducer Agreements
We may pay our third-party partners a referral fee or commission for introducing new clients to us. This generally consists of a trailing commission, calculated as a percentage of the profit we receive from the clients the partner introduces to us.

7. CONFLICTS OF INTEREST

We do not have any relationships or associations which might influence us in providing you with our services.

8. DISPUTE RESOLUTION PROCEDURE

Internal Disputes Procedure
If you have a complaint, you can contact us at:

Phone: +61 03 9013 0066
Mail: P.O. Box 171, 380 Bourke Street, Melbourne, VIC, Australia, 3001
Email: [email protected]

We will handle all complaints according to our internal dispute resolution procedure.

Our dispute resolution procedure requires that we acknowledge your complaint within 24 hours, provide an initial response to your complaint within 5 days, and provide a final response within 30 days.

The period of 30 days may be extended in exceptional circumstances.

Australian Financial Complaints Authority

After 30 days, if you are not satisfied with the outcome of our internal disputes procedure, you have the right to complain to the Australian Financial Complaints Authority (AFCA). AFCA provides independent financial services complaint resolution which is free for consumers.

You can contact AFCA via:
Mail GPO Box 3, Melbourne VIC 3001
Phone 1800 931 678
Fax 03 9613 6399
Website www.afca.org.au
Email [email protected]

Arbitration
If your dispute does not fall within the rules of the AFCA, you may submit the dispute to arbitration to be determined by the Arbitrators and Mediators of Australia Expedited Commercial Arbitration Rules, and to the extent permitted under those rules, the Arbitrator will be a person recommended by the New South Wales Chapter of the Institute of Arbitrators and Mediators of Australia. You agree to accept the determination of the arbitrator.

9. COMPENSATION ARRANGEMENTS

We maintain a professional indemnity insurance policy that satisfies the requirements for compensation arrangements under section 912B of the Corporations Act 2001 (Cth). The policy will cover claims that relate to the conduct of our former representatives and current employees.

10. PRIVACY

We are committed to protecting your personal information. Our Privacy Policy can be found on our website (www.novattixb.com) and sets out how, why and when personal information is used, collected, stored, disclosed or otherwise handled by us.

11. DOCUMENTATION WE WILL PROVIDE

The following documents are available for you to view and download on www.novattixb.com. It is important that you read and understand the documents listed below before using our products or services. If you do not agree to the terms and conditions outlined in the documents then you must not use our services.

Product Disclosure Statement
You will have access to our PDS before you are provided with the services. The PDS is designed to assist you with deciding whether our Products are right for you.

Financial Services Guide
You will also have access to this Financial Services Guide (FSG). The FSG is designed to tell you about us and the Financial Services we provide.

Master Agreement – Cross Border Payment Terms and Conditions
We will ask you to agree to the Master Agreement which sets out the terms and conditions relating to the provision of our foreign exchange services generally. The Master Agreement applies to all Transactions that you subsequently enter into with us. You must read and agree to the terms set out in the Master Agreement before entering into any Transactions. Each Transaction you enter into will be a separate contract, which is governed by the terms of the Master Agreement. If you wish to enter into a Transaction, you may do so by giving us Instructions online.

Privacy Policy
You should also read our Privacy Policy before you decide to use the Product.

12. RECORD-KEEPING OBLIGATIONS

We maintain records of all general advice given and transactions entered into. We may use these records should any misunderstanding or dispute arise between us.