Lemmi Ltd Financial Advice Provider Disclosure
LEMMI LICENCE
Lemmi Limited (FSP1007014 trading as Lemmi) is licensed to operate its financial advice services through a full class 3 Financial Advice Provider (FAP) license effective from 20 August 2024. This license is issued by the Financial Markets Authority, and does not currently contain any conditions that limit or restrict our activities.
LEMMI ADVICE
We are licensed to provide financial advice services both digitally via the Lemmi Web App and through in person interaction with nominated representatives and financial advisers. We provide guidance on your risk profile (investor personality) and use this as a basis to provide financial advice as to the achievability of the goals you may set. Achievability is a factor of your goal amount, risk, timeframes, financial resources and savings capacity. We only provide advice on investments products issued by New Zealand Investment Portfolio Limited (NZIPM is a related company to Lemmi). Lemmi will provide you with information and resources to help keep you on track towards your goal through the Lemmi Web App. If you would like to work through financial advice matters in person online with a Lemmi adviser, you may do so. Charges may apply for in person advice depending on your Lemmi service level. Lemmi will make available stand-alone financial advice modules, including but not limited to retirement planning, insurance and KiwiSaver reviews and financial health checks or reviews.
LEMMI DUTY OF CARE
We, and anyone who gives financial advice on our behalf, have duties under the Financial Markets Conduct Act 2013.
We are required to:
• Give priority to your interests
• Exercise care, diligence, and skill in providing you with advice
• Meet standards of competence, knowledge and skill set by the Code of Professional Conduct for Financial Advice Services
• Meet standards of ethical behaviour, conduct and client care set by the Code of Professional Conduct for Financial Advisers
This is only a summary of the duties that we have. More information is available by contacting us, or by visiting the Financial Markets Authority website www.fma.govt.nz
LEMMI FEES
Lemmi will provide financial advice services through the Lemmi Web App for a fixed month fee depending on your selected level of Lemmi Service. These fees will be payable at the beginning of each calendar month by deduction from your investment account balance. You will be provided with sufficient notice in writing prior to any changes in this ongoing fee. You may cancel your Lemmi service at any time by closing your investment portfolio. Those Lemmi clients with an NZIPM investment portfolio greater than specified service minimums may receive ongoing and ad hoc financial advice from our internal nominated representatives at no additional charge. If any charges do apply, these will be disclosed to you prior to your acceptance of the offer of additional advice services. Lemmi’s nominated representatives are salaried employees of Lemmi Ltd and do not receive any form of commission. You may receive advice from a contracted financial adviser who we may engage to act on our behalf. At times, there may be additional professional service fees or commissions payable when implementing this advice. Any fees or commissions will be disclosed to you as part of the advice process.
These fees are separate and additional to any custody, administration, or fund management fees charged by NZIPM.
HOW LEMMI MANAGES CONFLICTS OF INTEREST
We follow an advice process that ensures that we put your interests first.
Our advice and recommendations aim to help you achieve your goals as effectively as possible, based on your circumstances and what is important to you. We take all reasonable steps to make sure our advice isn’t materially influenced by our own interests or the interests of any other party associated with giving you advice.
Our nominated reps and financial advisers undergo regular training on how to manage conflicts of interest. We undertake compliance checks and a review of our compliance programme regularly and make improvements on an ongoing basis.
As stated above, Lemmi will disclose additional incentives and commissions it may earn in providing you with financial advice recommendations.
Because we only provide advice on NZIPM products, there is a conflict of interest because NZIPM, as manager and issuer of the financial products we advise you on, is a related company to us. Lemmi’s advice services and systems are also in part paid for via the NZIPM annual fund charge for the fund(s) you are invested in.
We manage this conflict by clearly explaining that we only advise on NZIPM products.
LEMMI PRIVACY STATEMENT
This Privacy Statement outlines Lemmi Limited’s (Lemmi) practices with respect to information collected from clients who engage our services and must be read in conjunction with Lemmi’s Web Privacy Policy, which covers both website and service interactions with Lemmi Ltd.
We collect personal information from you, including relevant information about your:
names
contact information
dates of birth
proof of identification and address
sources of funds and wealth
earnings and expenses
investments and debts/mortgages
insurance policies
asset ownership, trusts and estate planning
personal circumstances that may influence your financial position, goals and objectives
We collect your personal information to:
• Be used by Lemmi and any of their related entities, your Financial Adviser, or by other service providers to Lemmi, for the purposes of enabling Lemmi to recommend, arrange and manage your financial plan, and to contact you in relation to your financial plan;
• Comply with any laws in New Zealand or overseas applicable to Lemmi or the products or services (including investment portfolios) that Lemmi provides to you;
• Provide to a New Zealand or International Revenue or Taxation Service, the FMA, any of Lemmi’s related entities or other government authority to help Lemmi comply with laws and regulations in New Zealand or overseas.
• For the purposes set out above we may transfer personal information to parties located in other countries (some of which may not have an equivalent level of data protection laws as those in New Zealand). Before transferring any personal information to an overseas recipient, we take steps that are reasonable in the circumstances to ensure the overseas recipient complies with the principles contained in New Zealand's privacy laws or is bound by a substantially similar privacy scheme unless you consent to the disclosure or it is otherwise required or permitted by law. Lemmi will provide you (on request) with the name and address of any entity to which information has been disclosed;
Providing personal information is optional. If you choose not to provide certain personal information, we may be unable to offer you our services.
We keep your information safe by storing it in secured filing systems and only allowing our staff and relevant outsource providers to access this information. We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies disclosed to you and which you are required to comply with to be able to receive the services.
You have the right to ask for access to any personal information we hold about you, and to ask for it to be corrected if you think it is wrong. To make a request, you can contact us at clientcare@lemmi.co.nz. Your request will be dealt with in accordance with New Zealand's privacy laws.
The accuracy of the information we hold about you is important. Please advise us if your personal information changes to help in ensuring that the information we hold is up to date, complete and relevant.
We reserve the right to revise this privacy statement, or any part of it, from time to time. Please review this privacy statement periodically for changes.
LEMMI COMPLAINTS PROCEDURE
Should you have any questions, concerns or wish to make a complaint, we are only too happy to discuss this and try to resolve the issue as quickly and as amicably as possible.
Lemmi has both an internal complaints process and an independent dispute resolution service for you to access.
To send a complaint through to Lemmi please email clientcare@lemmi.co.nz and the team will get onto it asap! Please provide as much information as possible to help clarify the nature and source of your complaint.
If we cannot resolve the matter to your satisfaction, then we would refer you to our external disputes resolution service, the Insurance and Financial Services Ombudsman Scheme (IFSO). There is no fee charged to you by the IFSO to investigate a complaint. You may reach the IFSO by emailing info@ifso.nz or calling 0800 888 202.
The IFSO will provide you with an explanation of their services and the disputes handling process. Further details of the scheme can be found at www.ifso.nz