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Regulatory Status

Fund Services, Corporate Services and Private Clients.

Australia

Apex Fund Services Pty Ltd (previously Mainstream)

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.

Mainstream Superannuation Services Pty Ltd

Mainstream Superannuation Services provides member administration, unit pricing and accounting services to industry funds, corporate superannuation funds and retail superannuation master trusts.

Apex Australia (Apex Fund Services (Australia) Pty Ltd)

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.

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.

Apex Australia (Apex Fund Services (Sydney) Pty Ltd)

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.

Independent Professional Services Pty Ltd (IPS)

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.

Click here for complaints handling policy

Bahrain

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

Bermuda

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 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 BMA for fund administration services with a full Fund Administrator license (License No. 39614).

Emerging Asset Management Ltd. is registered with the Bermuda Monetary Authority as a Class B Person under the Investment Business Act 2023 and is permitted to carry on investment business in or from Bermuda.

Click here for complaints handling policy

Brazil

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.

Cayman Islands

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 Insurance Services (Cayman) Ltd. is regulated and licensed by the Cayman Islands Monetary Authority as an Insurance Manager (License No. 2092635).

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China

Apex Investment Consulting (Shanghai) Co., Ltd is not a regulated entity but a registered entity in Mainland China.

Apex Group Financial Management Consulting (Shanghai) Co., Ltd is not a regulated entity but a registered entity in Mainland China.

Guernsey

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"). Registered in the Bailiwick of Guernsey with Registration No.56167. The GFSC Licence number is 2102145.

FundRock Management Company (Guernsey) Limited is regulated and licensed by the GFSC under the Protection of Investors (Bailiwick of Guernsey) Law, 2020. Registered in the Bailiwick of Guernsey with Registration No.17484. The GFSC Licence number is 1019127.

Apex Administration (Guernsey) Limited is regulated and licensed by the GFSC. Registered with Registration No.51371. The GFSC Licence number is 2011047.

Apex Fiduciaries (Guernsey) Limited is regulated and licensed by the GFSC under the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020 as amended. Registered with Registration No.59697. The GFSC Licence number is 2265283.

Apex Fund Administration (Guernsey) Limited is regulated and licensed by the GFSC. Registered with Registration No.46441. The GFSC Licence number is 1040212.

Sanne Fund Services (Guernsey) Limited is regulated and licensed by the GFSC. Registered with Registration No. 43046. The GFSC Licence number is 1025942.

Hong Kong

Apex Fund Services (HK) Limited
Apex Corporate Solutions (HK) Limited
Apex Services (APAC) Limited

Apex Fund Services (HK) Limited (License no. TC007025), Apex Corporate Solutions (HK) Limited (License no. TC007366), and Apex Services (APAC) Limited (License no. TC003489) are regulated and licensed by the Hong Kong Trust and Company Service Provider (TCSP) for Corporate services in accordance with the requirements of the Cap. 615 Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).

The registered office of Apex Fund Services (HK) Limited, Apex Corporate Solutions (HK) Limited, and Apex Services (APAC) Limited is located at 2/F, 17/F, ROOM 1801-2 18/F & ROOM 1902 19/F, Beautiful Group Tower, 77 Connaught Road Central, Hong Kong.

Apex Fund Solutions (HK) Ltd

Fund Solutions is not a regulated activity in HK.

Hungary

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.

India

Throgmorton Services India LLP (GIFT branch) is regulated under IFSCA which has established its place of business in GIFT City to provide administration services, book-keeping, accounting services and other services auxiliary to financial services to its Special Economic Zone (SEZ) and non-SEZ clients.

Ireland (Dublin)

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.

Isle of Man

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.

Japan

Apex Group Trust (Japan) Company Limited

Wholly owned entity of Apex Group Ltd which operates Japan Trust business and related concurrent business.

Apex Group Japan K.K.

Wholly owned entity of Apex Group Ltd which operates Fund Administration services.

Apex Business Solutions K.K.

Wholly owned entity of Apex Group Ltd which operates consulting services.

Apex Tax Corporation

Apex Group Company under Collaboration agreement with Apex Business Solutions K.K., which operates tax services.

Jersey

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), Apex Group Trustee Services Limited (registered in Jersey No. 112368), Apex Group Fiduciary Services Limited (registered in Jersey No. 41570), Apex Group Fund Services (Jersey) Limited (registered in Jersey No. 125726), and MJ Hudson Fiduciaries Jersey Limited (registered in Jersey No. 92038), 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.

Luxembourg

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.

Click here for the complaints handling procedure

Malta

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

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 MFSA pursuant to Article 5 of the Company Service Providers Act, to provide corporate services, which include the following:

EDB Malta Branch provides Custody services to funds licensed in Malta as well as funds which are licensed in reputable third country jurisdictions. EDB Malta also offer Full Depositary duties and Depo Lite services.

Mauritius

Apex Financial Services Mauritius Limited ("AFSML"):

Apex Financial Services (Mauritius) Ltd is a Trusts and Corporate Service Provider regulated by the FSC ("Financial Services Commission"). It holds a management licence issued by the FSC and (i) FS-3.2 Nominee company licence and (ii) FS-3.1B Management Licence (Qualified/Corporate Trustee only). AFSML is a Management Company incorporated in Mauritius in December 1993 and licensed by the FSC to provide asset and corporate administration services.

Apex Fund Services Mauritius Limited ("AFS"):

AFS is a Management Company incorporated in Mauritius in June 2006 and licensed by the Financial Services Commission ("FSC") to provide asset and corporate administration services to entities mainly operating in the global business sector. Its core business is provision of fund administration services, corporate secretarial, directorship, tax, investor services, company incorporation, and other related services to investment funds, hedge funds, private equity funds and other global business companies.

Apex Fund and Corporate Services Limited ("AFCS"):

AFCS is a Management Company incorporated in Mauritius in September 2010 and licensed by the FSC to provide asset and corporate administration services. Its core business is provision of fund administration services, corporate secretarial, directorship, tax, investor services, company incorporation, and other related services to investment funds, hedge funds, private equity funds and other global business companies.

Netherlands

Corporate services and private client services are provided by Apex Financial Services B.V., a private limited liability company 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.

Sanne Group (Netherlands) B.V. (SGNL) provides ASTO services (management and domiciliation "plus" services) and also provides AML services such as administration services (accounting), corporate secretarial services, loan agency services etc. SGNL is registered with the Dutch Chamber of Commerce under number 24196052 and falls under the supervision of the Dutch Central Bank.

Click here for the complaints handling procedure

New Zealand

FundRock NZ Limited is licensed as a "manager of a registered scheme" under New Zealand's Financial Market Conduct Act 2013 (FMC Act), enabling us through our Fund Hosting business to issue and manage funds in NZ.

InvestNow is a New Zealand-based investment platform that provides online access to KiwiSaver, Managed Funds and Term Deposits from leading fund managers and banks from around the world.

Apex NZ has provided outsourced investment administration services to New Zealand based investment managers and investment product providers. The outsourced investment administration services include Scheme Administration / Registry and Fund Accounting.

ICSL offers custodial services to New Zealand based Financial Advisers and their investors utilising the Wealth Administration services of Apex NZ. Custodial service involves safekeeping, trade instructions, trade matching and corporate actions/proxy.

Saudi Arabia

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

Singapore

Apex Fund Services (Singapore) Pte. Ltd.

Registered with ACRA to provide Fund Administration Services.

Apex Fund Services Pte. Ltd.

Registered with ACRA to provide Fund Administration Services.

South Africa

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:

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:

PAIA Manual: Apex Fund Services South Africa Limited

PAIA Manual: FundRock Management Company (RF) (Pty) Ltd

PAIA Manual: Instit (Pty) Ltd

Apex SA Client Complaints Management Procedure

PAIA Manual: Apex Fund Services HoldCo SA (Pty) Ltd

PAIA Manual: Boutique Collective Investments (RF) (Pty) Ltd

PAIA Manual: SkyBlue Fund Managers (Pty) Ltd

PAIA Manual: Apex Fund and Corporate Services SA (Pty) Ltd

PAIA Manual: Boutique Investment Partners (Pty) Ltd

Apex SA Conflict of Interest Handbook

UK

Trustee and Corporate services are provided by Apex Corporate Trustees (UK) Limited (Registered in England and Wales No. 239726), Apex Pension Trustees Limited (No. 03030424) and Apex ATL Pension Trustees Limited (No. 02317256). Registered office: 4th Floor, 140 Aldersgate Street, London, EC1A 4HY, UK. Apex Corporate Trustees (UK) Limited is registered with HM Revenue and Customs for the purposes of the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017.

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: 4th Floor, 140 Aldersgate Street, London, EC1A 4HY, UK.

Apex Advisory and Capital Raising Limited (Registered in England and Wales No. 14548654)

Apex Advisory and Capital Raising Limited (FRN: 1003106) is an appointed representative of Laven Advisors LLP (FRN: 447282) which is authorised and regulated by the Financial Conduct Authority.

Apex Depositary (UK) Limited (Registered in England and Wales No. 08749704)

Apex Depositary (UK) Limited (FRN: 610203) is authorised and regulated by the Financial Conduct Authority.

Apex FundRock Limited (Registered in England and Wales No. 06252939)

Apex FundRock Limited (FRN: 469627) is authorised and regulated by the Financial Conduct Authority.

Apex Group Fiduciary Services (UK) Limited (Registered in England and Wales No. 05666576)

Apex Group Fiduciary Services (UK) Limited (FRN: 448301) is authorised and regulated by the Financial Conduct Authority.

Apex Investment Advisers Limited (Registered in England and Wales No. 04533331)

Apex Investment Advisers Limited (FRN: 539747) is an appointed representative of Apex Group Fiduciary Services (UK) Limited (FRN: 448301) which is authorised and regulated by the Financial Conduct Authority.

Apex Listed Companies Services (UK) Limited (Registered in England and Wales No. 09879916)

Apex Listed Companies Services (UK) Limited is registered with HM Revenue and Customs for anti-money laundering supervision.

Apex Unitas Limited (Registered in England and Wales No. 08255713)

Apex Unitas Limited (FRN: 591814) is authorised and regulated by the Financial Conduct Authority.

FundRock Partners Limited (Registered in England and Wales No. 04162989)

FundRock Partners Limited (FRN: 469278) is authorised and regulated by the Financial Conduct Authority.

ADU MIFIDPRU 8 Disclosure 2024

AUL Conflicts Policy 2024

Click here for the Complaints Handling Procedure UK which applies to the below Apex UK entities:

United Arab Emirates

Abu Dhabi

Apex Corporate Services (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).

USA

Atlantic Shareholder Services, LLC, a wholly owned subsidiary of Atlantic Fund Administration, LLC d/b/a Apex Fund Services, part of the Apex Group Ltd, is registered as a Transfer Agent with the U.S. Securities and Exchange Commission.

Emerging Asset Management Ltd. (NFA ID 0473416) and EAM (USA) Ltd. (NFA ID 0478271) are registered with the United States of America Commodity Futures Trading Commission as a Commodity Pool Operator and Swap Firm and are a member of the National Futures Association.

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