Regulatory Status

Apex Group Ltd. and wholly owned entities of Apex in Australia  (hereafter “Apex”) are committed to delivering the highest standard of service to our clients and ensuring that all complaints are resolved satisfactorily and in a timely manner. We will work with you to resolve any concerns raised and treat you with respect throughout the resolution process.

The objective of this policy is to assist the company, its executive team, and employees in resolving complaints in an efficient, effective, and professional manner.

This Complaints policy is written to comply with and in accordance with the regulatory obligations as an AFS Licensee. We ensure that our dispute resolution system meets the requirements of the Corporations Act 2001, ASIC Regulatory Guide 165, and ASIC Regulatory Guide 271.

We have developed this policy, having regard to relevant legal requirements and current best practices, including the guidance provided in Australian/New Zealand Standard AS/NZS10002:2014 Guidelines for complaint management in organisations. The legislation provides a framework to the processing of complaints made by a person or organisation  ‘the Complainant’ in a timely and appropriate manner and sets the minimum criteria for Apex’s investigation into a complaint to be conducted in a prudent manner.

For complaints in respect of, or requests for refunds by, the Registered Training Organisation (RTO) services provided by Apex Compliance Solutions (Australia) Pty Ltd please refer to the Addendum. 

Apex Fund Services Bahrain W.L.L., license number F.Adm/002, is licensed as a Fund Administrator by the Central Bank of Bahrain.

Apex Fund Services Ltd. is regulated and licensed by the Bermuda Monetary Authority (“BMA”) for fund administration services with a full Fund Administrator license (License No. 33832). Apex Corporate Services Ltd. is regulated and licensed by the Bermuda Monetary Authority (“BMA”) for corporate services with a Limited Corporate Services Provider license (License No. 43607).  Apex Insurance Fund Services Limited is regulated and licensed by the Bermuda Monetary Authority (“BMA”) for fund administration services with a full Fund Administrator license (License No. 39614).

Modal Asset Management Ltda. is regulated as an Investment Manager and Fiduciary Administrator in Brazil by the Comissão de Valores Mobiliários (CVM).  MAF Distribuidora de Títulos e Valore Mobiliários S.A. is regulated as an Investment Manager, Fiduciary Administrator, Custodian, Bookkeeping and Securities Distributor by the CVM, with oversight from the Brasil Central Bank (BCB).

BRL Trust Investimentos Ltda. is regulated as an Investment Manager and Fiduciary Administrator in Brazil by the CVM.  BRL Trust DTVM S.A. is regulated as an Investment Manager, Fiduciary Administrator, Custodian, Bookkeeping and Securities Distributor by the CVM, with oversight from the BCB.

The license held by the aforementioned entities is a Receita Federal do Brasil (RFB).  The Registered Office of the four companies is Rua Alves Guimarães, 1212 São Paulo – SP, Brasil.

Apex Fund Services (Cayman) Ltd. is regulated and licensed by the Cayman Islands Monetary Authority for fund administration services with a full Mutual Fund Administrator license (License No. 668942) and corporate and custody services with its Trust license (License No.  1465726).  Apex Group (Cayman) Limited is regulated and licensed by the Cayman Islands Monetary Authority for fund administration services with a full Mutual Fund Administrator license (License No. 1828816) and corporate services with its Company Manager license (License No. 1294624).  Apex Group Trustees (Cayman) Limited is regulated and licensed by the Cayman Islands Monetary Authority for corporate services with its Trust license (License No. 100178).

Apex Fund and Corporate Services (Guernsey) Limited is regulated and licensed by the Guernsey Financial Services Commission under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 as amended and the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020 as amended. Registered in the Bailiwick of Guernsey with No.33475 at 1 Royal Plaza, Royal Avenue, St Peter Port, Guernsey GY1 2HL.

Sanne Group (Guernsey) Limited is regulated and licensed by the Guernsey Financial Services Commission ("GFSC") under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 as amended and the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020 as amended. Registered in the Bailiwick of Guernsey with Registration No.56167 at 1 Royal Plaza, Royal Avenue, St Peter Port, Guernsey GY1 2HL. The GFSC Licence number is 2102145.

FundRock Management Company (Guernsey) Limited is regulated and licensed by the Guernsey Financial Services Commission ("GFSC") under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 as amended. Registered in the Bailiwick of Guernsey with Registration No.17484 at 1 Royal Plaza, Royal Avenue, St Peter Port, Guernsey GY1 2HL. The GFSC Licence number is 1019127.

Apex Administration (Guernsey) Limited is regulated and licensed by the Guernsey Financial Services Commission ("GFSC") under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 as amended and the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020 as amended. Registered in the Bailiwick of Guernsey with Registration No.51371 at 1 Royal Plaza, Royal Avenue, St Peter Port, Guernsey GY1 2HL. The GFSC Licence number is 2011047.

Apex Fiduciaries (Guernsey) Limited is regulated and licensed by the Guernsey Financial Services Commission ("GFSC") under the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020 as amended and is licensed and permitted to carry on by way of business regulated activities under s.2(1)(e) of the Law in respect of Pension Scheme Business and Gratuity Scheme Business. Registered in the Bailiwick of Guernsey with Registration No.59697 at 1 Royal Plaza, Royal Avenue, St Peter Port, Guernsey GY1 2HL. The GFSC Licence number is 2265283.

Apex Fund Administration (Guernsey) Limited is regulated and licensed by the Guernsey Financial Services Commission ("GFSC") under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 as amended. Registered in the Bailiwick of Guernsey with Registration No.46441 at 1 Royal Plaza, Royal Avenue, St Peter Port, Guernsey GY1 2HL. The GFSC Licence number is 1040212,

Sanne Fund Services (Guernsey) Limited is regulated and licensed by the Guernsey Financial Services Commission ("GFSC") under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 as amended and as a Secondary Licensee under the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020 as amended. Registered in the Bailiwick of Guernsey with Registration No. 43046 at 1 Royal Plaza, Royal Avenue, St Peter Port, Guernsey GY1 2HL. The GFSC Licence number is 1025942.

Corporate services and private client solutions are provided by Apex Hungary Corporate Services LLC, which is regulated by the National Tax and Customs Administration (NTCA) Financial Intelligence Unit in accordance with anti-money laundering regulatory requirements.  Registered office: Dohány utca 12, 2nd Floor, H-1074 Budapest, Hungary.

Corporate services and private client solutions are provided by Apex TSI Limited and Apex IFS Limited which are registered with the Department of Justice and Equality as Trust or Company Services Providers under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended.  Registered in Ireland No. 163472 and No. 129223 respectively.  Registered offices: 2 Grand Canal Square, Grand Canal Harbour, Dublin 2. Management company authorized under chapter 15 of Law of 17 December 2010 and authorized as an alternative investment fund manager under Article 5 of the law of 12 July 2013 on alternative investment fund managers, as amended”.

Apex Fund Services (IOM) Ltd. is regulated by the Isle of Man Financial Supervision Authority and Apex Corporate Services (IOM) Limited is regulated by the Isle of Man Financial Supervision Authority.

Corporate Services and Private Clients services are provided by Apex Financial Services (Jersey) Limited (registered in Jersey No. 92185) and some of its direct and indirect subsidiaries and affiliates, Apex Financial Services (Alternative Funds) Limited (registered in Jersey No. 86301), Apex Fund and Corporate Services (Jersey) Limited (registered in Jersey No. 99112), Apex Group Fund Administration Limited (registered in Jersey No. 112422) and some of its direct and indirect subsidiaries and affiliates, Apex Group Trustee Services Limited (registered in Jersey No. 112368) and some of its direct and indirect subsidiaries and affiliates, Apex Group Fiduciary Services Limited (registered in Jersey No. 41570) and some of its direct and indirect subsidiaries and affiliates, Apex Group Fund Services (Jersey) Limited (registered in Jersey No. 125726) and some of its direct and indirect subsidiaries and affiliates, and MJ Hudson Fiduciaries Jersey Limited (registered in Jersey No. 92038) and some of its direct and indirect subsidiaries and affiliates which are licensed and regulated by the Jersey Financial Services Commission for the conduct of Trust Company Business and/or Fund Services Business or as permit holders pursuant to Collective Investment Funds (Jersey) Law 1988. Registered office: IFC 5, St. Helier, JE1 1ST, Jersey.

Corporate services are provided by Apex Fund Services S.A., which is supervised by the Commission de Surveillance du Secteur Financier (“CSSF”) as a Specialised Professional of the Financial Sector (“Specialised PFS”) to exercise the activities of (i) Corporate domiciliation agent (ii) Company incorporation and management services (iii) Client communication agent (iv) Administrative agent of the financial sector (v) registrar agent and (vi) family office. Registered office: 3 rue Gabriel Lippmann L-5365 Munsbach. RCS B241514.

Corporate services are provided by Apex Corporate Services S.A., which is supervised by the Commission de Surveillance du Secteur Financier as a Professional of the Financial Sector to exercise the activities of (i) Corporate domiciliation agent (ii) Company incorporation and management services (iii) Client communication agent (iv) Administrative agent of the financial sector (v) registrar agent and (vi) family office. Registered office: 68-70 Boulevard de la Petrusse L-2320 Luxembourg. RCS B117939.

Apex Fund and Corporate Products S.A., which is supervised by the Commission de Surveillance du Secteur Financier (“CSSF”) as a Specialised Professional of the Financial Sector (“Specialised PFS”) to exercise the activities of (i) registrar agent (ii) professional depositaries of assets other than financial instruments (iii) corporate domiciliation agent (iv) family office (v) professional providing company incorporation and management services (vi) administrative agent of the financial sector and (vii) client communication agent. Registered office: 3 Rue Gabriel Lippmann, L-5365 Munsbach, Luxembourg. RCS B138069.

"The Company is recognised by the Malta Financial Services Authority (“MFSA”) pursuant to Section 9A of the Investment Services Act, 1994, (“ISA”), to provide fund administration services, which include the following services for Funds:

• Preparation of Net Asset Value
• Reconciliation
• Pricing the Investment Portfolio
• Payment of Bills
• Preparation of Financial Statements
• Fund Accounting
• Performance Reporting
• Compliance Reporting
• Preparation of Contract Notes

The Company provides fund administration services to clients which are domiciled both in and outside of Malta. "

"The Company is authorised to act as a Class C CSP by the Malta Financial Services Authority (“MFSA”) pursuant to Article 5 of the Company Service Providers Act, to provide corporate services, which include the following:

• Formation of companies and other legal entities;
• Provision of a registered office, a business correspondence or administrative address and other related services for a company, a partnership or any other legal entity;
• Offering service to third parties of acting as director of secretary of a company, a partner in a partnership or in a similar position in relation to other legal entities;
• Arranging for another person to act as director or secretary of a company, a partner in a partnership or in a similar position in relation to other legal entities.

The Company provides corporate services to clients which are domiciled both in and outside of Malta. "

"EDB Malta Branch provides Custody services to funds licensed in Malta as well as funds which are licensed in reputable third country jurisdictions via its Global Sub-Custodian Citibank NA London Branch and any other sub-custodians it may appoint from time to timeSafe-keeping function
EDB Malta also offer Full Depositary duties and Depo Lite servcies which include:

• Cash Flow Monitoring & Reconciliation Procedure:
• Asset Verification of Custodiable Assets:
• Asset Verification of Other Assets:
• Oversight - Investment and Borrowing restrictions monitoring:
• Oversight – Income Distribution:
• Oversight - NAV Review:
• Oversight – Reporting: "

Corporate services and private client services are provided by Apex Financial Services B.V., a private limited liability company (besloten vennootschap met beperkte aansprakelijkheid), incorporated and existing under the laws of The Netherlands, having its statutory seat in Amsterdam and its registered address at Van Heuven Goedhartlaan 935A, 1181 LD Amstelveen, The Netherlands, registered with the Dutch Chamber of Commerce under number 28065255. Apex Financial Services B.V. falls under the supervision of the Dutch Central Bank (De Nederlandsche Bank) and has a licence to operate as a Trust Office under the Act on the Supervision of Trust Offices, registered with the Dutch Central Bank

Sanne Group (Netherlands) B.V. (SGNL) provides ASTO services (management and domiciliation "plus" services). SGNL also provides AML services such as administration services (accounting), corporate secretarial services, loan agency services etc. SGNL statutory seat is in Amsterdam and its registered address is at Van Heuven Goedhartlaan 935A, 1181 LD Amstelveen, The Netherlands, registered with the Dutch Chamber of Commerce under number 24196052. SGNL falls under the supervision of the Dutch Central Bank (De Nederlandsche Bank) and has a licence to operate as a Trust Office under the Act on the Supervision of Trust Offices, registered with the Dutch Central Bank.

Apex Fundrock Investment  Closed Joint Stock Company service investment license by Ministry of Investment Reference No : 102114507257955

Apex Fundrock Investment Joint Stock Company Under Incorporation license by CMA Capital Market Authority Reference No : 32-24279

The following companies are licensed as Financial Services Providers in terms of the Financial Advisory and Intermediary Services Act (No. 37 of 2002), as amended, and supervised by the Financial Sector Conduct Authority.

• Apex Fund Services South Africa Limited – Registered office: River Park, Gloucester Road, Mowbray, 7700
• Apex Fund and Corporate Services SA (Pty) Ltd – Registered office: 11th Floor, Pier Place, Heerengracht, Cape Town, 8001
• Boutique Investment Partners (Pty) Ltd – Registered office: Catnia Building, Bella Rosa Street, Bella Rosa Village, Bellville, 7530
• SkyBlue Fund Managers (Pty) Ltd – Registered office: Catnia Building, Bella Rosa Street, Bella Rosa Village, Bellville, 7530
• Instit (Pty) Ltd – Registered office: Catnia Building, Bella Rosa Street, Bella Rosa Village, Bellville, 7530  

The following companies are registered and approved by the Financial Sector Conduct Authority under the Collective Investment Schemes Control Act (No. 45 of 2002), as amended.

• FundRock Management Company (RF) (Pty) Ltd – Registered office: 11th Floor, Pier Place, Heerengracht, Cape Town, 8001
• Boutique Collective Investments (RF) (Pty) Ltd – Registered office: Catnia Building, Bella Rosa Street, Bella Rosa Village, Bellville, 7530

Corporate services and private client are provided by Apex Corporate Trustees (UK) Limited (Registered in England and Wales No. 239726), which is registered with HM Revenue and Customs for the purposes of the Money Laundering Terrorist Financing and Transfer of Funds Regulations 2017, Apex Pension Trustees Limited (Registered in England and Wales No. 03030424) and Apex ATL Pension Trustees Limited (Registered in England and Wales No. 02317256).  Registered office of these three companies is 140 London Wall, London EC2Y 5DN, UK.

Outsourced accounting, payroll, tax, HR and company secretarial services are provided by Apex Corporate and Business Services UK Limited, (registered in England and Wales, No 3853848). Registered office: 140 London Wall, London EC2Y 5DN.  Apex Corporate and Business Services UK Limited is registered with HM Revenue and Customs for the purposes of the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017.

Abu Dhabi

Apex Corporate Services (ME) Ltd - ACS (ME) Ltd

Apex Corporate Services (ME) Ltd is registered with Abu Dhabi Global Market (ADGM) as a DNFBP

Apex Fund Services (AD) Limited

Apex Fund Services (AD) Ltd is authorised and regulated by the Financial Services Regulatory Authority (FSRA)

Apex Fund Services Ltd - Abu Dhabi

Apex Fund Services Ltd - Abu Dhabi is regulated by the Securities and Commodities Authority UAE

Fundrock Investment Management (ME) Ltd

Fundrock Investment Management (ME) Ltd is authorised and regulated by the Financial Services Regulatory Authority (FSRA).

Dubai

Apex Compliance Solutions Ltd

Apex Compliance Solutions Ltd is registered with the Dubai Financial Services Authority (DFSA) as a DNFBP

Apex Fund Services (Dubai) Ltd

Apex Fund Services (Dubai) Ltd is authorised and regulated by the Dubai Financial Services Authority (DFSA)