Disclosure Statement

What Sets Us Apart

Bespoke Wealth Limited was founded on a simple but important observation: the New Zealand wealth management industry has a structural conflict of interest problem. Most advice businesses are owned by product manufacturers, rely on commissions, and concentrate client portfolios in New Zealand assets — arrangements that serve the institution, not the investor.

We built Bespoke Wealth to be genuinely different:

• Independently owned — no institutional parent, no product manufacturer, no shareholder requiring us to direct your capital anywhere
• Flat, all-inclusive fee — one transparent annual fee covers everything. We do not receive commissions from any product provider
• Institutional-grade custody — your assets are held by BNP Paribas, one of the world's leading custodian banks, entirely separate from our business
• Globally diversified portfolios — built across multiple asset classes and geographies, not concentrated in NZ equities
• Access to alternative assets — including private equity and private credit, previously accessible only to institutional investors
• Fund rebates returned to you — where we use managed funds, we use our scale to seek manager rebates which are credited directly to your account

The advisers engaged by Bespoke Wealth have extensive experience across institutional and retail financial markets in New Zealand and internationally, spanning investment banking, private wealth, and portfolio management.

Licence Information

Bespoke Wealth Limited (FSP1011643) holds a Financial Advice Provider (FAP) licence issued by the Financial Markets Authority (FMA) to provide financial advice services.

Our licence authorises us to provide the following categories of financial advice:

• Independent investment advice
• Managed portfolio advice
• KiwiSaver advice
• Fund advice

There are no conditions or limitations on our licence that restrict the advice we are able to provide within the above categories.

Contact Details

Nature and Scope of Our Financial Advice

Bespoke Wealth Limited provides personalised financial advice to individuals, families, trusts, and entities with investable assets. We specialise in building and managing globally diversified investment portfolios tailored to each client's goals, risk profile, and circumstances.

We provide financial advice in relation to the following:

• Investment advice — holding specific advice
• Managed portfolio advice — including portfolio construction, asset allocation, manager selection, and ongoing portfolio management
• KiwiSaver advice — fund selection, provider comparisons, and contribution strategy
• Fund advice — including managed funds, PIE funds, and exchange-traded funds (ETFs)

We do not provide advice on life insurance, health insurance, mortgages, or general insurance products. If you require advice in these areas, we can refer you to an appropriate specialist.

How We Work

Our advice process is built around understanding your financial goals, time horizon, and risk tolerance before making any recommendations. We follow a structured, internationally recognised advice process:

• Understand — we learn about your goals, circumstances, and what matters to you
• Analyse — we assess your current position and identify opportunities and gaps
• Recommend — we present a personalised strategy with clear reasoning
• Implement — we execute the agreed strategy on your behalf
• Review — we monitor your portfolio and meet with you regularly to ensure it remains on track

Active Investor Plus Visa Clients

Bespoke Wealth works with investors applying for, or holding, New Zealand's Active Investor Plus (AIP) visa. We are experienced in structuring and managing portfolios that meet the eligible investment requirements of the AIP programme, and we work closely with immigration advisers and legal counsel to ensure our clients' investment arrangements are appropriately documented and reported. If you are an AIP visa applicant or holder and would like to discuss how we can assist, please contact us directly.

Conduct and Duties

Bespoke Wealth Limited, and anyone who gives financial advice on our behalf, has duties under the Financial Markets Conduct Act 2013 and the Code of Professional Conduct for Financial Advice Services.

We are required to:

• Give priority to your interests by taking all reasonable steps to ensure our advice is not materially influenced by our own interests
• Exercise care, diligence, and skill in providing you with advice
• Meet standards of competence, knowledge, and skill set by the Code of Professional Conduct for Financial Advice Services
• Meet standards of ethical behaviour, conduct, and client care set by the Code of Professional Conduct for Financial Advice Services

This is a summary of our duties. More information is available by contacting us or visiting the Financial Markets Authority website at fma.govt.nz.

How We Are Remunerated

Advisory Fee — Flat Annual Fee (plus GST)

We charge a single flat annual advisory fee, calculated as a percentage of assets under management, plus GST. This rate is the same for every client and every dollar — there are no tiered schedules and no structures that create an incentive to favour accounts of a particular size.

A flat fee means the quality of care you receive is not a function of the size of your portfolio. We think that is how it should be, and we have structured our business accordingly.

In plain terms: You always know exactly what you are paying us. There are no surprises, no complexity, and no structures designed to obscure the true cost of advice.

Our advisory fee is agreed with each client at the outset of the engagement and confirmed in your Letter of Engagement. All fees are quoted exclusive of GST. Please speak with us directly to discuss a fee arrangement appropriate to your circumstances.

Transaction Costs — Agreed at Engagement (plus GST)

A transaction cost applies to securities transactions to cover costs we incur. This rate is agreed with you at engagement and confirmed in your Letter of Engagement. It does not represent a material revenue line for Bespoke Wealth — when we make a change to your portfolio, it is because we believe it is the right decision, not because it generates income for us.

Rebates — Negotiated on Your Behalf and Returned to You

Where Bespoke Wealth is able to negotiate rebates directly with fund managers, those rebates are passed through to you in full as a direct reduction in the cost of your portfolio. We do not retain negotiated rebates as additional firm revenue.

Summary

Conflicts of Interest

Bespoke Wealth is independently owned and operated. Our business model is specifically designed to minimise conflicts of interest:

• We charge a flat annual fee — we have no financial incentive to recommend one product over another
• We do not receive commissions from any product provider, fund manager, or platform
• Our custodian, BNP Paribas, is an independent, globally regulated institution with no ownership connection to Bespoke Wealth
• Where we use managed funds and receive rebates from fund managers, those rebates are passed directly to you — we do not retain them

Bespoke Wealth also engages Aurellan Asset Management as an external investment office for asset allocation support and research. Aurellan provides these services at no direct cost; in acknowledgement of this, we may on a suitability basis consider Aurellan products for client portfolios. Where we do so, this relationship will be disclosed in your Statement of Advice.

We take any perceived or actual conflicts of interest seriously and maintain a conflicts of interest register. We review this register regularly and disclose any relevant conflicts to you before providing advice.

Complaints Handling and Dispute Resolution

If you are not satisfied with our financial advice service, we encourage you to contact us as soon as possible so we can work to resolve your concern.

How to Make a Complaint

Our Internal Complaints Process

When we receive a complaint, we will:

• Acknowledge receipt of your complaint promptly
• Consider your complaint carefully and contact you if we need further information
• Aim to resolve your complaint within 10 working days. If we need more time, we will contact you within that period to let you know
• Contact you by phone or email to let you know our proposed resolution

External Dispute Resolution

If we are unable to resolve your complaint to your satisfaction, you can refer it to the Insurance & Financial Services Ombudsman Scheme (IFSO Scheme), our independent, approved dispute resolution scheme. The IFSO Scheme provides a free, independent service to consumers.

Privacy and Data Collection

To provide you with the best possible financial advice, we need to collect personal and financial information about your circumstances. We take our obligations under the Privacy Act 2020 seriously.

• We only collect information that is relevant to the advice we are providing
• The accuracy of the information you provide is critical to the quality of our advice — we rely on you to keep us informed of any material changes to your circumstances
• We will protect your information and store it securely
• You can request access to your personal information or ask for it to be corrected at any time
• We will only share your information where necessary to deliver our services (for example, with BNP Paribas as custodian, fund managers, or other third parties required to implement your portfolio)
• We may also be required to share information with the Financial Markets Authority (FMA) as our regulator, or with external compliance advisers engaged for quality assurance purposes
• We have policies and procedures for dealing with any data breaches promptly
• Any information no longer required will be destroyed securely

You can read our full Privacy Policy at bespokewealth.nz.