Disclosure Statement – Seven Oaks Capital

Product Disclosure Statement

TABLE OF CONTENTS

1. Introduction
1.1 Purpose of this document
1.2 Important risk notice
1.3 Who we are
2. Foreign exchange contracts
3. Spot contracts
4. Significant benefits of spot contracts
4.1 Easy and efficient
4.2 Simple to understand
5. Significant risks of spot contracts
5.1 Unwinding transactions
5.2 Intra-day volatility
6. How do foreign exchange spot contracts work?
7. Forward contracts
8. How do forward contracts work?
9. Credit
10. Significant benefits related to using forward contracts
11. Significant risks related to using forward contracts
12. Significant general benefits of our products
12.1 Cash flow certainty
12.2 Flexibility
13. Significant general risks of our products
13.1 Market risks
13.2 Government risks
13.3 Force majeure
13.4 Counterparty risks
13.5 Operational risks
13.6 Cyber security
13.7 Cooling off period
13.8 System risks
13.9 Electronic transactions
13.10 Correspondent banking relationships
13.11 Restriction on currency
13.12 Payment risks
14. Settlement
14.1 Spot contracts
14.2 Forward contracts
14.3 Late payments
14.4 Corresponding funds transfers
15. Costs
15.1 How we are paid
15.2 The costs of our products
15.3 Fees and charges
16. Terms and Conditions
16.1 Our terms and conditions
16.2 Indemnity
16.3 Governing laws
16.4 Identification information
16.5 Electronic funds transfers
16.6 Wire transfer confirmation
17. How we handle your money
18. Stopping or cancelling a payment
19. Tax implications
20. What are our different roles?
21. What should you do if you have a complaint?
22. Privacy
23. Telephone Recordings of Conversations

1. INTRODUCTION

1.1 Purpose of this document
This Product Disclosure Statement (“PDS”) provides information about the
Products Seven Oaks Capital Pty Ltd (“Seven Oaks Capital, we, us, our”) can offer you.
The purpose of this document is to:
(a) Provide you with the information to help you determine whether the
products we offer are appropriate for you;
(b) Help you compare the various products we offer with similar products
offered by other providers;
(c) Explain the terms and conditions, rights and obligations associated with
our products.
The information in the PDS is general information only. To the extent that any
of the information constitutes general advice, it does not take into account
your personal objectives, financial situation or needs. You should consider
these things and this PDS before making a decision about using our products.

1.2 Important risk notice
It is your responsibility to ensure that you fully understand the products we
offer, as well as how currency transactions work and the risks that are involved
in such transactions. This PDS sets out the significant risks and benefits related
to the products we offer. However, if you need to do so, you should obtain
further information before making decisions regarding the products.
To the extent permitted by law, we do not accept any responsibility for any
loss arising from your use of this document.
If you have any queries about our products or this document, please do not
hesitate to contact us on the contact details on the front page of this PDS.
Further information about our services is also available at our website
www.sevenoakscapital.com.au, and through our Financial Services Guide (“FSG”).
Information in this PDS that is not materially adverse to those who use our
products may change from time to time. If it does, it will be updated on our
website www.sevenoakscapital.com.au.

1.3 Who we are
Seven Oaks Capital is a provider of foreign exchange services. In particular, we provide
spot foreign exchange and forward foreign exchange contracts to wholesale clients.
These contracts are explained later in this PDS. You will be classified as a wholesale client
if you meet one of a number of tests, such as the total value of financial products that you acquire
or the level of your net assets or gross income. When you acquire a financial product from us,
you will be entering into a contract with us.

The contract comprises of:
(a) The account application form, which you will be required to complete
with the information we request;
(b) This PDS (to the extent relevant); and
(c) The terms and conditions we provide to you. To the extent of
inconsistency between those documents, this PDS prevails. Any
capitalised terms in this PDS adopt the same meaning or definition as
included in the terms and conditions.

2. FOREIGN EXCHANGE CONTRACTS

A foreign exchange contract is an enforceable agreement between two willing parties to
exchange one currency for another currency at an agreed-upon price. This price is known as the exchange rate.
Through foreign exchange contracts, you can transfer one currency into another currency.
Some types of foreign exchange contracts, such as a forward contract,
are a traditional riskmanagement tool used to obtain protection against adverse exchange rate
movements. Foreign exchange contracts involve an agreement between you and us to
exchange one currency for another on a predetermined date (referred to in
this PDS as the value date and also referred to in the industry as a “settlement
date”). An implicit part of our foreign exchange contracts is what the law calls
a “non cash payment facility.” This means that you can nominate a beneficiary
to the exchanged currency in various countries around the world and we will
send your money to them (outbound) or receive money from them and pay
you (inbound). If there are countries to which we do not provide services, we
will advise you in the course of a transaction.
We are bound by Australia’s Anti-Money Laundering and Counter-Terrorism
Financing Laws. Due to the inherent risks in transferring money, we have
adopted procedures to ensure that we comply with all anti-money laundering
and counter-terrorism financing laws which apply to our services. Further
details of our compliance with these laws are set out in our terms and
conditions.
There are many reasons to enter into a foreign exchange contract. As an
importing business, you may be required to pay for your imported goods in the
currency of the country where your trading partner resides. You may be
purchasing property in another country. As a manufacturer, you may be
shipping your goods to a foreign country and receiving payment in the
currency of that other country.

We offer two types of foreign exchange contracts:

(a) SPOT CONTRACT
This is a foreign exchange contract for buying and selling currency where
the exchange rate is determined by the market conditions at a precise
moment in time for settlement in 2 business days or less. The date of
entering the contract and agreeing to the price with us is known as the
“transaction date”. Once you have accepted an exchange rate it will
remain fixed. The date on which you need to pay us, is typically the
business day before the value date. In this PDS, a business day refers to a
day which is not a weekend or public holiday in NSW or in one of the
currencies or countries involved in the transactions.

(b) FORWARD CONTRACT
This contract is similar to a spot contract, except that a forward contract
allows you to buy or sell one currency against another for settlement at
a predetermined time in the future. A forward contract may be used by
a business or an individual who would like to fix the exchange rate for
settlement on a future date of more than 2 business days, providing the
ability to manage exposure to currency movements, and manage cash
flow. The rate quoted will depend on matters such as your chosen value
date, the current prevailing spot exchange rates of the currencies
involved in the transaction and the interest rates of the two currencies
involved. The date on which you need to pay us, is typically the business
day before the value date.

Step 1 – Client Secures a foreign exchange (or “FX”) rate
Example:
You operate in Australia as an importer of goods and receive an invoice
from your US based supplier. You require an FX service provider to
convert your Australian dollars to US dollars and facilitate payment of
this invoice.
You telephone us to enquire what USD rate is available to you in order
to pay the USD100,000.00 invoice.
We offer you the FX rate of 0.7400.
We inform you that in order to pay the USD100,000.00 invoice with the
0.7400 rate offered, you would be required to pay us
AUD135,135.13(USD 100,000.00 / 0.7400 = AUD $135,135.13). A
transfer fee may also be applicable to the transaction. Please refer to
our website and/or Section 15.2 of this document for the relevant fees.

Step 2 – Acceptance of FX Rate
If you accept the quoted FX rate, we generate and provide you with a
contract confirmation.
You are required to acknowledge the terms outlined in the contract
confirmation.

Step 3 – You Pay Us
You are required to pay us an amount in accordance to the contract
confirmation by the date and time specified in the contract
confirmation.
This payment is generally required to be made by you the day before
the value date.

Step 4 – We Complete the FX Contract by Remitting the Funds to your
nominated beneficiary.

4. SIGNIFICANT BENEFITS OF SPOT CONTRACTS
This section sets out the significant benefits which are specific to spot
contracts. The general benefits associated with our products are set out in
Section 12.
4.1 Easy and efficient
Spot contracts are an efficient and easy way to purchase another currency and
pay someone quickly, using the prevailing spot rate.
4.2 Simple to understand
Spot contracts are less complex than other foreign exchange products. To
enter a spot contract, all you need to understand are the steps set out in
Section 3.

5. SIGNIFICANT RISKS OF SPOT CONTRACTS
This section sets out the significant risks which are specific to spot contracts.
The general risks associated with our products are set out in Section 13.
5.1 Unwinding transactions
Once you have entered into a transaction, the transaction will be executed at
your selected exchange rate.
If you seek to sell back currency, you may only be able to do so at a less
favourable exchange rate than the one you purchased the currency for.
5.2 Intra-day volatility
There may be some volatility even over a short period of time in the rates
which you obtain by using a spot contract.
For example, you could fix a price for a spot contract at 9am, but you may have
obtained a more favourable rate if you had entered into that contract later in
the same day.

6. HOW DO FOREIGN EXCHANGE SPOT CONTRACTS WORK?
To exchange currencies at the current foreign exchange rate, you will need to
advise us of the following information:
(a) The amount of money you wish to exchange;
(b) The two currencies involved;
(c) Which currency you would like to buy or sell;
(d) What value date that you would like the payment made.
We will then quote you a spot exchange rate (i.e. the rate at which we are
willing to buy or sell the currency involved in the transaction).
If you accept the rate over the phone or online, then you are bound to the
transaction. We will then send you a trade contract confirmation by email or
another method we have agreed upon with you. You will need to send the
agreed amount to our nominated bank account on the agreed date. On receipt
of your funds, we make the currency conversion at the agreed foreign
exchange rate and value date.
We then arrange for your bought currency to be sent to the bank account you
have nominated.

7. FORWARD CONTRACTS
Forward contracts allow you to buy or sell one currency against another for
settlement between 3 business days and anytime in the future. Forward
contracts are generally used by companies or individuals who would like to fix
the exchange rate for a future date in order to manage their exposure to
fluctuations in foreign exchange rates and manage future cash flows.

8. HOW DO FORWARD CONTRACTS WORK
A forward contract is for a fixed term and for delivery on a fixed date.
To buy a forward contract, you must tell us:

(a) The amount of money you wish to exchange;
(b) The two currencies involved;
(c) Which currency you would like to buy or sell; and
(d) The value date(s) that you would need to use the exchanged currency.

We may ask for a portion of the contract as a deposit – see the section titled
Credit below.
On the value date, or on a partial draw date (drawing down on a contract
means that you may use all or part of the agreed upon forward contract
amount prior to the original value date of the contract, thus creating a new
value date) you must send the amount owing to us to our nominated bank
account. On receipt of your funds, we make the currency conversion at the agreed
foreign exchange rate.

We then arrange for the bought currency to be sent on the agreed date of the contract to a
nominated bank account which may be another of your bank accounts, or a nominated
beneficiary bank account. This nominated bank account will be confirmed with
you via a contract confirmation prior to the funds being sent out, to ensure that they are
sent to the correct destination account. A forward contract transaction operates in the
same way that a spot contract transaction works, except the value date is greater
than 2 business days from the transaction date. For example, payment may be required
90 days from when a contract to purchase a boat from the US is due to settle. The Australian client-buyer may
not want to take on the risk that the AUD weakens against the USD, so may
lock in the currency today. The same steps follow as per the spot exchange
example, except we will quote a forward exchange rate.
Another example is: You contact Seven Oaks Capital and advise that you need to secure
USD$200,000 for the purchase of goods in exchange for AUD; however, you do
not need these funds for another 6 months. Seven Oaks Capital advises that the current
rate of exchange on a forward contract due in 6 months, inclusive of our
margin, is 0.7482. Therefore, you would need to pay AUD$267,308.20 on or
before the forward contract value date 6 months from now to complete this
contract. If you find this acceptable, you would instruct Seven Oaks Capital to conclude
the trade on your behalf. At this point, if Seven Oaks Capital has confirmed the booking
then the contract has started. Seven Oaks Capital will then send you a forward contract
as confirmation and this contract will have to be signed and returned the same
business day. If it is not, the forward contract is subject to cancellation and any
losses will be your responsibility.
You may extend the value date of a forward contract, if we agree – see the
section titled Credit below. Alternatively, in these circumstances we may simply
offer you a new value date for your contract.

9. CREDIT
We may require you to pay a deposit as part of the transaction. This will be
assessed on a case by case basis and we will consider your credit rating and
history with us in deciding whether or not a deposit will be required.
If we don’t agree to provide credit, we will quote you a forward rate and tell
you what deposit you will need to send us to enter into the forward contract.
Should you agree to conduct a trade at the quoted exchange rate, Seven Oaks Capital
will conclude the trade on your behalf and send you the forward contract,
typically, by email. You will then need to send the agreed deposit amount so it reaches our
nominated bank account within 2 business days of the transaction date or the
contract is subject to cancellation with losses payable by you to Seven Oaks Capital.
In the USD$200,000 example above Seven Oaks Capital may form the view that it will
not offer a forward contract on credit, and instead advises that to secure the
forward contract, you would need to make an initial deposit of AUD
$26,730.82. You will then send AUD$26,730.82 to the bank account we have
nominated.
On the value date of the contract, 6 months from the initiation of the contract,
you send Seven Oaks Capital the remaining AUD$240,577.38. We arrange to have
USD$200,000 sent the bank account you have nominated. If the payment to
the nominated bank account is by wire, we may require an additional wire
payment fee to cover this transaction. This fee will be disclosed to you before
you enter into a transaction. Depending on market movements throughout the
tenure of the contract, you may also be required to provide additional margin deposits.
We will advise you should this situation arise.

10. SIGNIFICANT BENEFITS RELATED TO USING FORWARD CONTRACTS
This section sets out the significant benefits which are specific to forward
contracts. The general benefits associated with our products are set out in
Section 12.
(a) Forward contracts are a way of managing future currency exchange risk
and negating the impact of adverse movements in exchange rates.
(b) You can agree to an exchange rate now for the delivery of currency in the
future. This means that you will be able to manage your cash flow
because you know what you will have to pay in the future.
(c) Seven Oaks Capital forward contracts allow drawdown before the value date. You
can draw down and use all or part of the agreed upon forward contract
amount prior to the value date of the contract.

11. THE SIGNIFICANT RISKS RELATED TO USING FORWARD CONTRACTS
This section sets out the significant risks which are specific to forward
contracts. The general risks associated with our products are set out in Section

(a) A forward contract fixes a currency amount, exchange rate and a delivery
date. This means it does not allow you to take advantage of a favourable
movement in the prevailing spot exchange rate.
(b) If you use the forward contract to cover an obligation that ceases to exist,
or changes, prior to the delivery then the contract may need to be closed
out (that is, brought to an end). If the contract is closed out, you may
incur a loss as you could be liable for any loss suffered by Seven Oaks Capital due
to the cancellation or closure of this contract. The loss is typically the
difference between the mark-to-market valuation of the forward rate,
and the prevailing spot rate at the time of cancellation.
(c) Unless we agree to do so, you will not be able to extend the value date
of any forward contract that you have agreed upon. If you are unable to
deliver on your obligations the forward contract by the date you need to
pay us, the contract will be cancelled and you will be liable for any losses
incurred by Seven Oaks Capital due to the cancellation.
(d) Any margin required by us will need to be paid by wire or bank transfer
within 2 business days from the date of request.

Failure to do so will constitute a default of the terms of a forward contract and you will be
liable for any costs associated with the closure of your contract.
This may include the enforced liquidation of your position as well as
additional losses which would typically be the difference between the
contract rate and the prevailing spot rate at the time the funds you requested to
purchase are sold back to the market
An example of the potential losses that may be realised in relation to a forward
contract is if there is a sudden surge in the price of the currency which is part
of a forward contract. If we have asked you for a deposit, we may need to ask
you for additional funds to cover both the deposit payment and the position.
If you are unable to make these payments, we will cancel the forward contract
and you will be liable to pay us the amount of any losses we may suffer.

12. SIGNIFICANT GENERAL BENEFITS OF OUR PRODUCTS
Our products provide a range of benefits. Foreign exchange contracts can be
an important risk management tool for the management of exposure to
exchange rates. You can use a spot or forward contract to protect yourself
against adverse market swings. Also, foreign exchange contracts may be used
to provide you or your business with cash flow certainty.
Sections 4 and 10 of this PDS contain information about the benefits
associated with those specific products. However, there are some general
benefits of spot or forward foreign exchange contracts, which are set out in
this section:

12.1 Cash flow certainty
Entering into a foreign exchange contract that will settle at a later date allows
you to determine the cost of the exchange rate at that time, giving you
certainty over your cash flows.

12.2 Flexibility
You are able to tailor foreign exchange contracts to your specific
circumstances. A foreign exchange contract is not standardized – you are able
to enter into a contract which meets your requirements. For example, you can
vary the amount of a contract, and the duration of that contract. Please note
that, as we don’t provide personal advice, we will not recommend a particular
tailored product. Rather, you can request certain features in a product.

13. SIGNIFICANT GENERAL RISKS OF OUR PRODUCTS
Sections 5 and 11 of this PDS contain details of the specific risks associated
with spot and forward foreign exchange contracts. You should also be aware
of the following risks that apply to all foreign exchange contracts:

13.1 Market risks
Foreign exchange markets can be volatile. The exchange rate which you are
quoted may change significantly due to volatility, up until such time as you
choose to accept that exchange rate. Once you have accepted an exchange
rate it will remain fixed.

13.2 Government risks
There is a risk that your money may be delayed or lost due to an event or
incident of a sovereign, strategic, political, or governmental nature in any of
the countries in which we operate. In such an event, we would attempt to
recover your money, however we do not guarantee the security of your funds
in this situation.

13.3 Force majeure
There is also a risk that your money may be delayed or lost due to unforeseen
circumstances. We will not provide a refund due to “force majeure,” as defined
in the case law of Australia. This includes catastrophic disasters, terrorist
attacks, and other events beyond our control that affect our services.

13.4 Counterparty risks
Because you are dealing with us as a counterparty to every transaction, you
will have an exposure to us in that you rely on our ability to meet our
obligations to you under the terms of each transaction. This risk is sometimes
described as a “counterparty risk” or “credit risk.”

13.5 Operational risks
We have obligations under Australia’s Anti-Money Laundering and
Counter Terrorism Financing laws. One of these obligations is to screen
clients and transactions for risks of money laundering, terrorist financing and
other criminal activity. There is a risk that your transaction may be delayed or cancelled
due to the processes or systems we have in place for these screening purposes.
Our banking partners also adhere to similar processes which may
also delay or cancel your transaction without notice. Neither we nor our
banking partners have the authority to tell you the reasons for the delay, if
there is a suspicion of money laundering, terrorism financing or other criminal
activity.

13.6 Cyber security
There is a risk that your email account or contact details are compromised and
we receive an instruction that appears to be from you to pay money on your
behalf. If we send money in these circumstances, you will be solely responsible
for any loss, if the result is the result of an unauthorised data breach or data
disclosure or cyber-attack to your business or your account.

13.7 Cooling off period
There is no cooling off period associated with our products. Once you enter
into a forward or spot contract with us, the contract cannot be terminated or
varied without our consent.

13.8 System risks
We rely on technology providers and their systems to provide you with our
services. We ensure that these systems are regularly updated.
We may also rely on third party providers (such as our correspondent banks)
to assist in currency transfers. Any disruption to the system of a third party
provider is beyond our control.

13.9 Electronic transactions
Because we use electronic systems to conduct transactions, there are also risks
associated with the use of software including errors and bugs, and delays or
interrupted services. These risks are inherent to online transactions and are
beyond our control.

13.10 Correspondent banking relationships
To deliver our services to you, we may use correspondent banks. We take
reasonable care in selecting our correspondent banking relationships.
Although we will take reasonable steps and return your funds if our
correspondent bank is unable to deliver the required currency when due, to
the extent allowed by law we will not be liable for any direct or indirect loss
suffered by you as a result of the failure of a correspondent bank to deliver the
required currency. The correspondent bank may also charge fees. Generally
these fees are deducted from the funds sent but if you wish to pay fees you
can by advising us.

13.11 Restriction on currency
Some currency we deliver may be governed by certain legal and regulatory
requirements. If a particular country is subject to sanctions, we may not be
able to provide foreign exchange services to those countries. By using our
services, you agree that you will comply with any such requirements. As set
out above, we are bound by Anti-Money Laundering and Counter-Terror
Financing regulations when we provide services to you. This means that in
some circumstances, we will be restricted from providing services to you. Also,
in appropriate cases, all communications and information concerning your
activities with us that we hold may be disclosed to and reviewed by law
enforcement agencies and regulatory authorities.
Further information about the restrictions that may be in place in relation to
the services we provide are set out in the terms and conditions.

13.12 Payment risks
Seven Oaks Capital will not refund your money if there was an error (e.g. an incorrect
beneficiary) on the contract confirmation and you do not tell us of the error
within the timeframe set out in our terms and conditions and/or contract
confirmation.

14. SETTLEMENT

14.1 Spot contracts
All spot contracts must be settled, that is paid for, within two business days of
the transaction date (that is, the date you place your order with us). Payments
for trades must be made by wire or electronic funds transfer from your bank
directly to ours. We will provide you with specific banking instructions to help
you facilitate the transfer to our account.

14.2 Forward contracts
An initial deposit on a forward contracts must be paid (where requested)
within two business days of the date the contract is agreed upon. The
remaining funds must be paid on or before the completion date of the forward
contract as specified in your contract details. Forward contracts are to be paid
by the same methods as given for spot contracts.

14.3 Late payments
Late payments may result in the cancellation of the foreign exchange contract
provided by us to you. At this point you will be liable for any costs and/or
exchange rate losses incurred by us from the cancellation of your contract. The
factors that contribute to the amount of these costs are based on the current
market pricing at the time the funds you requested to purchase are sold back
to the market.

14.4 Corresponding funds transfers
Prior to transmitting fund transfers on your behalf, you will be provided with
a contract confirmation. This document sets out the details of the transaction
and the name and banking information of the beneficiary you intend to pay.
The contract confirmation will be sent to you via email, or in another method
agreed with you. We may require a signature on some forward contracts.
Once we have confirmed receipt of your funds, have identified the originator
of the funds and have received your contract confirmation, we will initiate our
funds transfer as per your instructions. Please note that delays in supplying us
with the contract confirmation will result in transmission delays. We are not
able to send a funds transfer until we have a corresponding confirmation for
each scheduled transfer. You may choose to have your funds transferred to
your own bank account directly or to a third party account.
For each payment, we must have accurate banking information on file.

When you enter into a contract with us, you are immediately bound to
the terms of that contract. You are bound to the contract despite the fact
that settlement may not actually occur until a later date.

15. COSTS

15.1 How we are paid
The revenue we generate is based on a margin. The margin is a difference
between the wholesale exchange rate we obtain and the exchange rate we
offer you. The margin may be impacted by a number of factors:
(a) More frequent trading sometimes reduces the margins;
(b) Highly liquid currency pairs typically have lower margins;
(c) Low market volatility may reduces margins; and
(d) Larger transactions may reduce margins.
In contrast:
(a) Infrequent trading may increase the margin;
(b) Exotic, less liquid currencies have higher margin;
(c) High market volatility increases the margin; and
(d) Smaller transactions increases the margin.

15.2 The costs of our products
There is no costs to join Seven Oaks Capital and there are no ongoing annual fees.
For each Overseas International Inward or Outward Telegraphic Transfer
Payment or Receipt, you may be charged a flat fee of up to AUD $20.00.
You may also be charged the margin which is disclosed above. The margin will
be part of the cost of the currency we provide to you.
You can obtain information about the costs of our products free of charge by
requesting this from us by phone or email.

15.3 Fees and charges
In addition to the costs which are set out above, you may also be charged fees
by other service providers or intermediaries. These fees are out of our control.
For example, sometimes an overseas bank deducts a wire or lifting fee from
the payment amount. Where we know about these fees, we will make a
reasonable attempt to tell you about them.

16. TERMS AND CONDITIONS

16.1 Our terms and conditions
You will be provided with our terms and conditions before you open an
account with us. You must agree to these terms and conditions before we
provide you with services. You should read that document carefully to
determine whether or not you would like to use our services. Some significant
aspects of our terms and conditions are repeated below.
16.2 Indemnity
You will be required to indemnify us for any loss that occurs as a result of us:
(a) Acting in good faith on your verbal or written instructions;
(b) Transferring funds to an incorrect beneficiary where the error was
included in the contract confirmation;
(c) Transferring money to a third party because of instructions that we relied
upon, that were sent to us due to a fraud or cyber security incident or
other information breach that affected your business or email address or
account details; or
(d) Having to cancel a transaction.

16.3 Governing laws
You must provide all information to us that we reasonably require of you to
comply with any law in Australia or any other country. In particular, you must
provide adequate identification before you can use our products or services by
undertaking our customer onboarding procedure. We may disclose any
information that you provide to the relevant authority where required by any
law in Australia or any other country. When you use our services, you are
promising that you will not breach any law in Australia or any other country.

16.4 Identification information
We are not liable for any loss that arises from incorrect identification
information being provided by you, or from currency rate quotation errors.

16.5 Electronic funds transfers
Electronic funds transfers are efficient and safe. Sometimes a delay can occur
if the receiving bank is in a remote area or poorly staffed or for other reasons.

16.6 Wire transfer confirmation
It is your responsibility to carefully review the Confirmation of Wire Transfer
that we will provide to you, to ensure that the data we have on file matches
the data of the nominated beneficiary account that you have provided us.

17. HOW WE HANDLE YOUR MONEY
We will notify you of a number of nominated bank accounts, operated by us,
where you should transfer your money. Typically, money that we receive on
your behalf is a payment towards a foreign exchange contract. Deposits –
whether initial deposits or margin deposits, are part-payments towards the
pre-agreed contract value and are also client monies that we hold on trust for
you. Upon receipt of that money, we have a corresponding obligation to pay
money in a currency specified by you, to your nominated beneficiary, subject
to our terms and conditions.

We maintain a segregated client money account for certain situations. The law
requires that money must be placed in a client money trust account by the
next business day from when it is received if:
(a) A client pays money into our account without having first agreed to or
entered into the terms of a foreign exchange contract, and/or we cannot
contact them that day to confirm the purpose of the funds and enter into
a foreign exchange contract to use those funds; or
(b) A client pays more money into our account than what was previously
agreed to (eg. the client pays AUD$10,000 after agreeing to purchase a
foreign exchange contract for AUD$5,000), and we do not return the
surplus by the next business day and we cannot contact them to confirm
their instructions with respect to the surplus funds.
(c) You have purchased currency from us but are still awaiting the terms of
settlement and/or payment details.

18. STOPPING OR CANCELLING A PAYMENT
The factors that contribute to the amount of these costs are based on the
currency market pricing at the time the funds you requested to purchase are
sold back to the market. Once a funds transfer has been sent, it is extremely difficult to cancel it. An attempt to recall the funds transfer can be made but will be subject to further
fees charged by the banks involved. Those charges will be passed onto you and
are out of our control. If you believe you have instructed us to send a funds
transfer in error, notify us immediately. It is much easier to halt a transfer in
transit than one that has already been received by the beneficiary bank.
We reserve the right to cancel any contract immediately in circumstances set
out in our terms and conditions. Those circumstances include (but are not
limited to) your insolvency, non-payment or late payment, or for a breach by
you of our terms and conditions.

19. TAX IMPLICATIONS
Using foreign exchange contracts can create tax implications. We are not
authorised to provide you with taxation advice. Accordingly, you should
discuss any taxation questions you may have with your tax adviser before using
our products or services.

20. WHAT ARE OUR DIFFERENT ROLES?
We are the product issuer. This means that we provide the facility you use to
transfer money and do not act on behalf of anyone else.
We are also the service provider. Our representatives can give you general
advice and help you use the money transfer service. This role is undertaken
on behalf of the product issuer.

21. WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT?
If you are not satisfied with any aspect of the service that has been provided
by us, you are entitled to complain. We have established procedures to ensure
that all enquiries and complaints are dealt with. Please contact us at:
Phone: (02) 9262 3248
Email address: enquiries@sevenoakscapital.com.au
Postal address: Suite 108, Level 13, 365-377 Kent Street, Sydney NSW 2000, Australia

22. PRIVACY
The privacy of your information is very important to us. We have practices
which include the secure storage of personal information and safeguards
against the accidental release of personal information.
You will be required to provide us with certain information to enable us to
comply with our obligations under Australia’s Anti-Money Laundering/Counter
Terrorism Financing laws. We handle all information provided to us in accordance with our Privacy Policy.

23. TELEPHONE RECORDINGS OF CONVERSATIONS
Any telephone conversations you have with us will be recorded. This is
standard market practice. Recorded conversations are retained for a limited
period and are usually used where these is a dispute and for staff training and
monitoring persons. You will need to advise us if you do not wish to be recorded.