Disclosures
Important Disclosure for Australian Resident participants
GSIL and GS Inc Disclosure
If the Workplace Solutions Services you receive from us in connection with your Company Share Plan do not include a brokerage account, your service provider is [Global Shares Ireland Limited (“GSIL”) / Global Shares Inc (GS Inc)]. The services provided by [GSIL / GS Inc] relate to your access to and use of the Participant Portal (as more particularly set out in the participant terms and conditions). These services are administrative in nature and [GSIL / GS Inc] is not a financial services provider. However, the services you receive may be considered to include “dealing by arranging” under subsection 766C(2) of the Corporations Act 2001 of Australia (the “Act”) which requires an Australian Financial Services Licence (“AFSL”). [GSIL / GS Inc] does not hold an AFSL and has received an exemption from the Australian Securities and Investments Commission from the requirement to do so for the provision of its services.
GSESL and GSFS Disclosure
Your Workplace Solutions brokerage account is provided to you by [Global Shares Execution Services Limited (“GSESL”) / Global Shares Financial Services Inc. (“GSFS”)]. Under the Corporations Act 2001 of Australia (the “Act”), the provision of financial services to Australian residents generally requires the provider to hold an Australian Financial Services Licence (“AFSL”) unless an exemption is granted by the Australian Securities and Investments Commission (“ASIC”). [GSESL / GSFS] does not hold an AFSL covering the financial services it provides to you but has received an exemption from ASIC from the requirement to do so. The following is an overview of the services [GSESL / GSFS] is permitted to provide to you under the terms of the exemption and relates to shares acquired or received by you by virtue of your participation in your employer’s share plan:
(i) general financial product advice under section 766B of the Act – [GSESL / GSFS] will provide information to you relating to the services it provides to you in connection with your acquisition or disposal of shares you receive from your employer’s share plan. This information is not intended to influence you to buy or sell your shares. [GSESL / GSFS] is not providing financial product advice but the information you receive may constitute general financial product advice under Australian law, for which [GSESL / GSFS] has an exemption. You should consider seeking independent advice before making financial decisions;
(ii) dealing by arranging under subsection 766C(2) of the Act – [GSESL / GSFS] can arrange for you to acquire or dispose of shares you receive from your employer’s share plan. The arrangement will be initiated by you and will be executed through a registered broker-dealer authorized and regulated under [US / Malta] regulatory requirements or other sufficiently equivalent regulatory requirements to provide these services;
(iii) issuing a financial product under subsection 766C(1) of the Act – [GSESL / GSFS] can arrange for the issuance of a foreign exchange contract by a third party in order to convert share sale proceeds from a foreign currency to Australian Dollars (AUD); and
(iv) custodial services under section 766E of the Act – [GSESL / GSFS] will custody your shares but will not charge you custody or account maintenance fees, it will hold your shares as custodian of record with sub-custodians who are authorized and regulated under [ Malta / US] or equivalent regulatory requirements.
[GSESL / GSFS] may only provide services covered by the ASIC exemption and is not otherwise authorised to provide financial services within the jurisdiction of Australia.