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 either Global Shares Ireland Limited (“GSIL”) or Global Shares Inc (GS Inc), as more particularly set out in your participant terms and conditions. The services provided by GSIL or 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 neither GSIL nor GS Inc is 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 or GS Inc]do 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 either Global Shares Execution Services Limited (“GSESL”) or Global Shares Financial Services Inc. (“GSFS”), as more particularly set out in your participant terms and conditions. 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 or GSFS do 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 or 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 or 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 or GSFS is not providing financial product advice but the information you receive may constitute general financial product advice under Australian law, for which GSESL and 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 or 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 or Maltese (as applicable) 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 or 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 or 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 Maltese / US (as applicable) or equivalent regulatory requirements.
GSESL and GSFS may only provide services covered by the ASIC exemption and is not otherwise authorised to provide financial services within the jurisdiction of Australia.