Publicly Available Disclosure

Our  Services

• Investments strategies (strategic asset allocation and investing)
• KiwiSaver investment strategies
• Debt management (including borrowing for personal and investment purposes)
• Personal risk insurance (life, health, income protection, and trauma

Products  we can provide financial advice about:

• KiwiSaver investments
• Managed investments
• Loans including mortgages, reverse mortgages   and deposit bonds
• Personal insurance policies

• Mortgages: ANZ, BNZ, ASB, Westpac, Kiwibank, TSB, SBS, The Co-operative Bank, Unity, Avanti Finance, Basecorp, Pepper Money, CFML Ltd, China Construction Bank, Bank of China, Nelson Building Society, First Mortgage Trust, Cressida Capital, Bluestone Home Loans, DBR Property Financiers, Heartland Bank, Finbase, ICBC, Zurix, Go Lend, MB Private, Liberty, Line Capital, Lendr, Plus Finance, Pallas Capital, Prospa, Funding Partners, Bizcap, ASAP Finance, Vincent Capital, Scotpac Business Finance, Southern Finance Partners, Welcome, Xceda.
• KiwiSaver: ANZ Investments, Milford Assets, Fisher Funds, Koura, Pathfinder, Generate, Booster.
• Insurance: AIA, NIB, Fidelity Life, Unimed.

Below is our policy. If all 3 conditions are met, there will be no fee charged from us.

1. You keep your mortgage with the same lender for a minimum of 3 years

‍If you sell the property, refinance to another lender, or fully repay the loan within 3 years, then we may charge you for any commission that the lender takes back from us.

‍This fee is capped at a maximum of $3,000. This does not include refixing your loan, this does not affect our commission.

2. Your loan is placed with a New Zealand registered bank

‍(ASB, ANZ, BNZ, Westpac, SBS, Co-operative, TSB, Kiwibank, Bank of China, China Construction Bank). The lender will cover our fees by paying us a commission on your loan. Typically, commissions are between 0.55-0.85% of the total loan amount. It is our strong preference to place you with a NZ registered bank.

If we cannot place your loan with a bank, another option may be non-bank lenders. These lenders do not pay us a commission and therefore we may charge a fee. In this case, any fees would be fully disclosed to you in writing by your adviser and need to be approved by you, the client, in writing.

3. Your loan is for buying a home, investment property, refinancing, or getting a top up on your existing home loan‍‍

Other lending, such as commercial or business loans, may incur a fee as lenders do not typically pay us any commission for non-residential loans. Again, this would be confirmed in writing by your adviser, and you, the client, would need to agree to this in writing.

‍

Where other costs are incurred in the process of providing our advice and services to you, you will be liable for these costs. However, we will agree all additional costs with you prior to incurring them.

For services in relation to investments, insurance, and loan products, commissions may be paid by the product provider as follows:

• Mortgages (Initial Commission): A percentage of the loan balance ranging from 0.55% to 0.90%.
• Mortgages (Ongoing Trail): A percentage of the outstanding loan amount ranging from 0.00% to 0.20%, usually calculated at the end of each month.
• KiwiSaver (Initial Commission): An upfront payment of up to $250 upon joining the scheme, depending on the size of your contributions within the first 12 months.
• KiwiSaver & Managed Funds (Ongoing Trail): A percentage of your investment balance ranging from 0.05% to 0.50%, usually calculated at the end of each month.
• Insurance (Initial Commission): A percentage of the first year's premium ranging from 10% to 250%.
• Insurance (Ongoing Trail): A percentage of the annual premium ranging from 0% to 20%.

We are here for our clients and to advise you as best we can. Your interests are our priority, although we do have business relationships with product providers.

From time to time, our product providers assist us with funding so we can bring our advisers together for conferences and professional development training.

To ensure our advisers prioritise our clients’ interests:

• We follow an advice process that ensures our recommendations are made appropriately, based on clients’ goals and circumstances.
• All our advisers undergo annual training about how to manage conflicts of interest.
• We explicitly declare material conflicts in our written Stage 2 and Stage 3 advice documents.
• We maintain registers of conflicts of interests and the gifts and incentives we receive. These registers are monitored regularly, and additional training is provided as required.
• We undertake an annual independent Compliance Assurance Review.

Reliability History Neither HLF Financial Limited, its Authorised Bodies, nor its advisers have been subject to any material reliability events, disciplinary actions, or bankruptcy proceedings.

Privacy and Data Security We manage all client information in strict accordance with the New Zealand Privacy Act 2020. Please refer to our full Privacy Policy on our website for details on how we collect, store, and protect your personal information.

Authorised Body Ownership & Cross-Referrals: HLF Insurance Limited is jointly owned by HLF Financial Limited (75%) and KiwiFuture LTD (25%, owned by insurance specialist Prashant Balsara). Because the directors of HLF Financial (Andy Palliser, Deepak Arya, Divya Gandhi) and Prashant Balsara all hold ultimate financial interests in HLF Insurance, a material conflict of interest exists when referring mortgage clients internally for risk protection. They financially benefit from the Authorised Body's profitability.

Furthermore, Director Divya Gandhi is the sibling of Prashant Balsara and operates an independent mortgage advisory business, Vaama Financial Advisor Ltd. We manage these commercial and familial conflicts through strict Stage 2 and Stage 3 disclosures to ensure absolute transparency, and by ensuring our mortgage advice processes operate entirely independently of director influence or related-party insurance referrals

We are bound by the duties of the Financial Markets Conduct Act (431I, 431K, 431L and 431M) to:

• Meet the standards of competence, knowledge and skill set out in the Code of Conduct
• Give priority to the clients’ interest and
• Exercise care, diligence and skill and
• Meet the standards of ethical behaviour, conduct, and client care set out in the Code of Conduct.

Both HLF Financial Limited and HLF Insurance Limited, alongside anyone who gives advice on our behalf, are bound by the duties under the Financial Markets Conduct Act 2013. We must give priority to our clients' interests, exercise care, diligence, and skill, and meet the standards of ethical behaviour and competence set out in the Code of Professional Conduct. If you have a complaint regarding either entity, our unified internal complaints process applies, backed by our free, registered dispute resolution scheme

If you have a problem, concern, or complaint about any part of our advice or service, please tell us so that we can try to fix the problem. Our internal complaints manager is Andrew Palliser, who can be reached via email at [email protected] or 028 8517 4720.

When we receive a complaint, we will acknowledge it within 24 hours. We will document your concerns, evaluate how they can be resolved, and may contact you to clarify any details. We will look to resolve your complaint internally and will communicate our proposed resolution to you within 15 working days.

If we cannot agree on how to fix the issue, or if you decide not to use the internal complaints scheme, you can contact our external disputes resolution scheme, Financial Services Complaints Limited (FSCL). This service will cost you nothing and will help us resolve any complaints.

Depending on which adviser you are working with, you can reference the following FSCL membership numbers:

• Gagan Sahoonja & Kobe Liam Oliver Williams: 9354
• Prashant Balsara: 9609

You can contact FSCL at:

• Address: PO Box 5967, Wellington, 6140
• Phone: 0800 347 257
• Email: [email protected]