This Financial Services Guide (FSG) is dated 27/03/2024 and is provided to you by Pearler Investments Pty Ltd A.C.N 32 625 120 649 (“Pearler”, “we”, “our”, “us”) to inform you of the financial services provided by us and to comply with our obligations as the an Authorised Representative of Sanlam Private Wealth Pty Ltd (Sanlam) which is the holder of an Australian Financial Services Licence (AFS Licence No. 337927).

This FSG is meant to assist you to decide whether to use our services and to explain:

This FSG contains only general information about the services we offer. If you still have any questions after reading this FSG, please contact us. Our contact details are listed at the end of this document.

You will not be provided with any personal financial product advice from Pearler. Any advice or information we provide to you is general advice only and does not take into account your personal objectives, financial situations or needs. It is up to you to decide whether or not you want to use our services, and if you need assistance or advice in this regard, you should consult a suitably qualified financial adviser. You will not receive a Statement of Advice from Pearler.

Generally, where we arrange for the issue of a financial product to you, you will have had publicly available access for, or directly received a Product Disclosure Statement (PDS), Target Market Determination (TMD) or other relevant disclosure documents that include information about the product so that you can make an informed decision whether to acquire the product. It would include any relevant terms, significant risks and costs associated with the supply of that financial product.

We will accept order instructions via the Pearler website or Pearler app.

You must review any confirmation or statement we send to you immediately upon receipt to ensure its accuracy and report any discrepancies to us.

Pearler (AR Number 1281540) is responsible for the Financial Services described in this guide.

Pearler is an Authorised Representative of Sanlam Private Wealth Pty Ltd, AFS Licence Number: 337927.

Pearler is a representative of, and acts on behalf of, Sanlam Private Wealth. Pearler does not act as a representative of any other licensee in relation to the services or products it provides.

Pearler is authorised by Sanlam Private Wealth to provide general advice on and deal in the following classes of financial products to retail and wholesale clients (within the definition of the Corporations Act):

Pearler is an online platform that facilitates the buying and selling of select listed securities and managed funds on the Australian Stock Exchange and various US exchanges, as well as applying for units in certain retail managed investment schemes. If you choose to act on the information provided to you by Pearler you will need to open an account with a brokerage firm or the appropriate custodian, which Pearler may assist you with by referring you to one of its affiliated brokers or fund managers.

Sanlam Private Wealth is an investment and financial services house with extensive experience in servicing the needs of both private investors and corporate clients. Sanlam Private Wealth has an extensive suite of products to service the needs of private clients and institutional investors.

We can offer you factual market data and information, including general advice, regarding those products and services our authorisation permits us to provide. The products on which we may provide this information include:

We provide general advice and information regarding financial products and services that can be dealt through us. This information or advice does not take into account your personal and financial circumstances, needs and objectives and because of that you should, before acting on the advice, consider the appropriateness of the advice having regard to your personal and financial circumstances, needs and objectives.

It should be noted that if you open an account with us you will also be requested to provide some information relating to your financial circumstances and risk profile. This information is collected so that we can:

Pearler has a relationship with its affiliated brokers which are providers of identification and verification, execution, clearing and settlement services and portfolio administration services. These relationships in no way influence the provision of financial services by Pearler to you. We will update this table regularly, and inform you of any material changes, at our discretion.

The information in this section is subject to change and does not include information in relation to taxes or duties that you may be required to pay in relation to an investment. Unless otherwise stated, all fees, charges, commissions and benefits disclosed in this FSG are exclusive of the Goods and Services Tax (GST).

Pearler (through third party service providers) will arrange, as authorised by you, for commissions to be debited from your account when a transaction has been completed in consideration for services rendered. The amount of commission can differ greatly depending on the services provided. Generally, the commission may be charged on a per trade basis or on a cash under management basis. The following ranges are an indication of the commissions that may be charged:

Advisory and Dealing Services

Per Trade Basis

* Pearler retains the right to pause, hold or refuse to submit any order at its sole discretion. Without limiting its rights in this regard, if Pearler suspects you are using Pearler for wholesale or institutional purposes based on frequency and size of trade, your account may be suspended without notice and your Equities and Cash returned to you without notice. After purchase, prepaid credits purchased cannot be refunded or transferred and will expire in 10 years if not utilised

Pearler and Sanlam Private Wealth (through the affiliated broker) will arrange, as authorised by you, for brokerage, commission or transaction fees to be debited from your account when a transaction has been completed in consideration for services rendered. The amount of commission can differ greatly depending on the services provided (ie. ranging from execution only services to advisory and dealing services). Generally, the commission may be charged on a per trade basis.

US securities – Per Trade Basis

We currently use Currency Cloud as “Our FX Provider”.

All fees are in USD.

* After purchase, prepaid credits purchased cannot be refunded or transferred and will expire in 10 years if not utilised

Pearler does not earn interest on the monies held by our customers at Drivewealth’s US brokerage customer accounts.

Managed Funds

The table below shows fees and other costs that you may be charged in the Diversify and Chill Investment Option and can be used to compare costs between different simple managed investment schemes. Fees and costs may be paid directly from your investment account or deducted from investment returns.

Full details of the pricing and terms are found at PDS, TMD, AID and IOL and you should review all documents in accordance with the FSG, our Disclaimers and Terms when considering if this product is right for you.

Per Trade Minimum Considerations

ASX Securities

Pearler and Sanlam Private Wealth (through the affiliated broker) have a minimum transaction requirement of $500.00 AUD notwithstanding any other requirement or condition outlined in this document or our terms and conditions.

US Securities

Pearler and Sanlam Private Wealth (through the affiliated broker) have a minimum transaction requirement of $50.00 AUD notwithstanding any other requirement or condition outlined in this document or our terms and conditions.

Cash

Pearler works with third parties who provide a range of payment processing functions to simplify and facilitate your investment decisions and is not a bank or deposit holder. Pearler does not hold any 'Client Money' (i.e. money to which Subdivision A of Division 2 of Part 7.8 of the Act or s1017E of the Corporations Act applies) on behalf of its clients.

We arrange for your monies to be held on your behalf in accordance with Subdivision A of Division 2 of Part 7.8 of the Corporations Act applies, on terms contemplated under section 981A of the Corporations Act. Your funds are processed for investing purposes only and we work with institutional partners like Sanlam to make this happen safely and securely.

Your funds are held overnight (or longer) in National Australia Bank Limited trust accounts held by our financial services licensee, Sanlam Private Wealth Pty Ltd (ACN 136 960 775, AFSL 337927) (Sanlam), in accordance with its AFSL obligations and we have also appointed Perpetual Corporate Trust Limited (“Perpetual”) as custodian to open a bank account and act on the instructions from us in relation to the movement of funds.

Perpetual's role is limited to holding assets of the trust as agent of Pearler. Perpetual has no supervisory role in relation to the operation of the trust and is not responsible for protecting your interests. Perpetual has no liability or responsibility to you for any act done or omission made in accordance with the terms of the custody agreement.

Pearler does not charge you any fees for processing or arranging for the holding of your monies, nor any account inactivity or withdrawal fees. Full details of brokerage, commission or transaction fees payable by you are outlined in our FSG and the Client Agreement entered into between the affiliated broker and you.

The actual commissions and charges payable will depend upon the relevant service provided by Pearler. Full details of commission payable by you in the Client Agreement entered into between Pearler and you.

Where client monies are held awaiting your instructions, any interest earned on the trust account is paid to the third-party licensee, custodian or agent as the case may be, to cover the cost of operating the bank accounts and obligations. Pearler may enter into sub-agreements with those third-parties to retain surplus interest to cover the costs of providing payments processing and associated operating purposes. Neither third-party or Pearler has an obligation to pass this interest onto you.

By holding or depositing money using Pearler you agree and acknowledge that Pearler has the appropriate instructions and approvals to process your payments between our payments and banking providers for the necessary functioning of our app or service.

General comments

Included within the commission will be any administration or agents' execution fees. In addition to these commissions, Pearler may require you to reimburse it for any fees levied on Sanlam Private Wealth by a market operator or clearing and settlement facility in respect of transactions entered into by Sanlam Private Wealth for you.

Pearler will receive a percentage of the fees received by Sanlam Private Wealth and Sanlam Private Wealth will retain the balance.

Our employees may, if authorised by you, be remunerated on a commission basis for the services provided to you. Their remuneration is included in the commissions discussed above.

Where your business has been referred to Pearler or your trade instructions require the use of a third party, Pearler may be required to share a percentage of the commission or other charge with other parties, as disclosed and authorised by you in the Client Agreement entered into between Pearler and you.

We maintain a list of our ongoing deals here.

If you wish to make a complaint, the Company Secretary can be contacted by email at support@pearler.com. We will try to resolve your complaint quickly and fairly.

In the event that we are unable to resolve any issue or complaint you can contact Sanlam Private Wealth who has formalised client complaint resolution procedure in place to resolve any complaints or concerns you may have about the service provided to you. These should be directed to the Compliance Manager (Ms Amanda Roberts) can be contacted on (03) 8640 5508 or by email SPW_compliance@privatewealth.sanlam.com.au.

All complaints are reviewed and investigated by our Compliance Manager. If you make a complaint, our first response will be to contact you to discuss the complaint and to register a formal record of such complaint.

If, despite our best efforts, you believe your complaint has not been satisfactorily dealt with, we offer the use of an independent industry arbiter, namely, the Australian Financial Complaints Authority (AFCA). Sanlam Private Wealth has agreed not to contest a final resolution from AFCA.

You can contact AFCA by writing to:

Australian Financial Complaints Authority
GPO Box 3
Melbourne VIC 3001
Toll Free: 1800 931 678 (free call)
Email: info@afca.org.au
Website: www.afca.org.au

Sanlam Private Wealth as the authorising licensee for Pearler holds Professional Indemnity Insurance cover for the activities conducted under its AFS licence and continues to maintain Professional Indemnity Insurance that generally satisfies the requirements of s912B of the Corporations Act Regulatory Guide RG126.

Privacy is an important issue for us and we are committed to ensuring full compliance with Privacy Act requirements.

The personal data that we collect from you will only be used by us to assist in the provision of general product advice to clients, planning of marketing proposals, education seminars and otherwise only as permitted under the AMLCTF Act 2006. Pearler does not sell your data to anyone for any reason.

Pearler Investments Pty Ltd
Mail: MCIC UNSW, Gate 2 Ave, Kensington 2033 Level 2, 33 York St, Sydney NSW 2000
Website: pearler.com
Email: support@pearler.com

Sanlam Private Wealth Pty Ltd
Telephone: (02) 8245 0500
Facsimile: (02) 8245 0599
Mail: Level 2, 33 York St, Sydney NSW 2000
Website: www.sanlamprivatewealth.com.au
Email: SPW_compliance@privatewealth.sanlam.com.au