Important Information

This Privacy Policy sets out the policies of Alceon Group Pty Ltd, its related bodies corporate and all of its authorised representatives (as that term is defined in the Corporations Act 2001), excluding those wholly owned subsidiaries and authorised representatives that have adopted separate privacy policies and which are published on their respective websites, (together “Alceon Group”, “us”, “we”, “our”), on dealing with personal information. We recognise the importance of your privacy and understand your concerns about the security of your personal information. We are committed to protecting any personal information about you that we hold. This Privacy Policy explains what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important.

This Privacy Policy applies to personal information that may be collected by us or submitted to us through the Alceon website or via any other means of collection. “Personal information” means information that allows you to be identified, for example, your name, contact details, online identifiers (including your IP address), or your financial information (such as your bank account details).

Application of privacy laws

Alceon is required to comply with the Australian Privacy Principles (APPs) set out in the Privacy Act (1988).

Collecting personal information

We only collect personal information that is necessary for our functions and activities, which includes developing and promoting our services and complying with our legal and regulatory obligations.

Generally, we collect personal information you voluntarily provide to us when you visit our website, call us, inquire about our services, apply to become an investor, or otherwise engage our services. The personal information we collect depends on the nature of your interactions with us. For example, we may collect personal information such as your name, address, and contact details when you submit an online inquiry about our services, call us, or send us an email. We may collect additional personal information if you request a service that requires us to collect such information, for example, your financial details such as tax file numbers and credit related information.

If you create an account on our website or investor portal, we may collect your login credentials or similar security information.

We may also collect personal information about individuals seeking employment with Alceon.  This may include name, address, contact details, curriculum vitae and tax file number.

We automatically collect certain information when you visit, use or navigate our website. This information may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website and other technical information.  This information is primarily needed to maintain the security and operation of our website, and may be used for our internal analytics and reporting purposes.

We may also collect your personal information indirectly from third parties or other sources like public databases, or marketing partners, for legitimate purposes including for the purpose of providing our services to you.  These third parties may include:

• Financial planners;
• Accountants;
• Lawyers; and
• Other Australian Financial Services Licence (AFSL) holders.

While we take great care to protect your personal information on our website or sent via email, unfortunately no data transmission over the internet can be guaranteed to be 100 per cent secure.  Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from us online.  This is particularly true for information you send to us via email.  We have no way of guaranteeing that information is protected in transit.  Once we receive your information, we make our best effort to ensure its security in our possession.  If you are concerned about providing personal or confidential information online, you may prefer to contact us by telephone or mail.

Where you provide us with personal information about someone else you must have their consent to provide their personal information to us in accordance with this Privacy Policy.

Cookies

Like many websites, when you visit our website our server may attach a small data file known as a “cookie” to your hard drive.

Cookies are pieces of information that may be transferred to your computer’s memory when you visit a website for record keeping purposes. Most internet browsers are set to accept cookies.  However, if you do not wish to receive any cookies you may set your internet browser to refuse cookies or to notify you when a cookie is sent. (Each browser is different so check the “Help” menu of your browser to learn how to change your cookie preferences).

We may use cookies to provide us with aggregate information on how people use our website and to help us know what they find interesting and useful on our website.

Use of personal information

We collect, hold and use personal information for a variety of business purposes including to:

• provide you with products, services and investment opportunities and to manage our relationship with you;
• contact you, for example, to respond to your queries or complaints, to request feedback from you, or if we need to tell you something important or provide you with a product, service or an update relating to an investment opportunity;
• provide you with information about changes to our terms, conditions or policies;
• confirm that the details on an evidence of identity document you or someone on your behalf provides us match records held by the government authority that issued it;
• conduct marketing and provide you notification of social functions;
• comply with our legal obligations and assist government and law enforcement agencies or regulators, such as those relating to taxation, anti-money laundering and counter-terrorism financing.

Where we and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, we will only do so in accordance with your marketing preferences. You can opt-out of our marketing emails at any time by following the instructions within the email or by contacting us using the details provided at the end of this policy.

You will then be removed from the marketing email list. However, we may still need to send you service or administrative related emails that are necessary for the administration and use of our services or your account.

We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For more information, see the section entitled ‘Cookies’ above.

We may also use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our website, products, services, marketing and your experience.

Disclosure of Personal Information

To make sure we can meet your specific needs and for the purposes described in ‘Use of personal information’, we may need to share your personal information with others.  We may share your information with other organisations for any purposes for which we use your information.

We may share and disclose your information in the following situations:

• Other AFSL holders or authorised representatives.We may disclose your information to other AFSL holders or authorised representatives that act as a trustee or custodian, or are a responsible entity in respect of a transaction you are investing in.
• Compliance with Laws.We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts, fund accounting, tax and legal consultants and other compliance reporting bodies, if you are an investor. We may allow selected third parties to use tracking technology on the website, which will enable them to collect data about how you interact with the website over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Privacy Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the website. These companies may use information about your visits to our website and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
• We may share your information with our affiliates, which include our related bodies corporate and authorised representatives (as those terms are respectively defined in the Corporations Act 2000), joint venture partners and other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
• Professional advisers, banks, financiers and insurers. We may share your information with professional advisers, banks, financiers (and their professional advisers, security trustees or agents) and insurers where they have a need to know for ‘know your client’ and/or anti-money laundering purposes.
• Document Verification Service providers. We may, with your consent, share your information with our Document Verification Service provider to confirm that the details on an evidence of identity document you have provided us match records held by the government authority that issued it and whether such details are still valid and not expired or cancelled.
• With your Consent. We may disclose your personal information for any other purpose with your consent.

International transfers of your information

We may disclose and store your personal information with our database provider, which hosts our information in the US.  In those circumstances we will ensure that the transfer of your personal information is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place to ensure that any third party is committed to protecting your privacy and complying with a law or scheme which has the same or similar effect as the APPs.

Security, accuracy and storage of your personal information

Irrespective of whether personal information is stored electronically or in hard copy form, we follow strict procedures to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure. We use a number of physical, administrative, personnel and technical measures to protect your personal information.

It is important that we use only your correct information, as such we would ask that if you find our information to be out-of-date or inaccurate could you please advise us, using the contact details set out below, so that corrections can be made.

We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.

Other websites linked to our site

From time to time our website may provide links to third party websites or third party websites may link to our website.  These linked sites are not under our control and we are not responsible for the conduct of companies linked to our website.  Before disclosing your personal information to any other website, you should examine the terms and conditions for using these websites and the privacy policies applicable.

Personal information of minors

We do not knowingly solicit data from or market to children under 18 years of age.  By using the website, you represent that you are at least 18 years old or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the website or our services.  If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records and deactivate any account that has been created using that information.  If you become aware of any data we have collected from children under age 18, please contact us using the contact details below.

Changes to our privacy policy

From time to time it may be necessary for us to review and revise our privacy policy.  We reserve the right to change our privacy policy at any time and to notify you by publishing an updated version of the policy on the Alceon Group website at www.alceon.com.au.

Feedback, Queries and Complaints

We have established an internal process for handling customer feedback, queries and complaints (including matters involving compliance with privacy laws).  This resolution mechanism is designed to be fair and timely to all parties and is free of charge.  If you have a query about Alceon Group’s handling of your personal information, you should submit it in writing to the address specified below.  You will typically receive a letter or email from us within seven days which sets out an overview of how your query will be responded to.  We aim to resolve your query within 28 days of receipt.

You may access or request correction of the personal information that we hold about you by contacting us. There are some circumstances in which we are not required to give you access to your personal information. In most circumstances, we will not charge you a fee to access your personal information. If you make excessive or unfounded requests however, we may charge you a reasonable fee.

We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date, complete, relevant and not misleading.

Contact details

If you have any questions or feedback about privacy, or the way in which we handle your personal information or if you wish to access any personal information you may contact us in the following way:

The Privacy Officer Alceon Group Pty Ltd Level 26, 1 O’Connell Street Sydney NSW 2000
Telephone: 02 8023 4000 Email: [email protected]

You can also contact the Office of the Australian Information Commissioner if your complaint is about your privacy.

Office of the Australian Information Commissioner

Phone: 1300 363 992

Mail: Office of the Australian Information Commissioner
GPO Box 5218,
Sydney NSW 2001

Updated June 2020

1. Purpose of this policy

Alceon is committed to upholding the highest standards of integrity, fairness and ethical conduct.

Employees and others working closely with Alceon will often be the best source of information when things are not quite right. This policy is an important element in detecting corrupt, illegal or otherwise undesirable conduct at Alceon.

Creating a supportive environment where people feel safe to speak up underpins Alceon’s culture. When people do not speak up, this undermines the culture and exposes Alceon to risks. The Alceon board encourages speaking up about concerns of wrongdoing. There are various measures in place to ensure no one is discouraged from speaking up or disadvantaged or victimised for doing so.

The purpose of this Policy is to:

• explain how to speak up by reporting concerns about wrongdoing;
• outline what protections a person who reports wrongdoing will receive; and
• outline Alceon’s processes for dealing with reports of

In this policy Alceon means Alceon Group Pty Ltd, its related bodies corporate and controlled entities.

2. Raising concerns at Alceon

There are a number of ways to raise concerns at Alceon, depending on the circumstances and the seriousness of the issue.

2.1 Speaking to peers or managers

Often day to day issues can be resolved between employees through open and authentic conversation, as part of normal team dynamics. Employees can escalate to their manager if they are concerned about an issue or want support to resolve an issue. Alceon encourages employees to continue to feel empowered to raise issues in this way.

2.2 Raising personal work-related grievances

Personal work-related grievances are not within the scope of this policy and should be addressed directly with the employee’s manager in the first instance. Personal work-related grievances relate to an employee’s current or former employment and tend to have implications for them personally. Examples include:

• an interpersonal conflict between the employee and another employee;
• a concern about the behaviour of an employee;
• a decision relating to an employee’s engagement, transfer or promotion;
• an employee’s terms and conditions of employment;
• matters relating to an employee’s performance or discipline-related decisions; or
• a decision relating to the termination of

Speaking up about potential wrongdoing under this policy

There may be times when an employee is not comfortable raising concerns about a wrongdoing with their manager and a formal report should be raised under this policy. This is available to employees and others with reasonable grounds to suspect wrongdoing in relation to Alceon. Reporting suspected wrongdoing under this policy will enable Alceon to protect those who report from victimisation or detriment as a result of making a report. These highlighted concepts are explained in the sections below.

3. Who may make a report

Anyone with information about potential wrongdoing relating to Alceon is encouraged to report their concerns under this policy.

This includes individuals who are or have been in relation to Alceon:

• an employee, officer or contractor;
• a supplier of services or goods to Alceon (whether paid or unpaid) including their employees; and
• a relative, dependant or spouse of any of the above

4. What to report

Any concerns of wrongdoing should be reported. This means any misconduct or improper state of affairs or circumstances in relation to Alceon.

Examples of wrongdoing may include:

• breach of laws or regulations;
• criminal activity including theft;
• serious breach of Alceon’s code of conduct or conflict of interest policies;
• offering or accepting a bribe;
• dishonest or unethical behaviour;
• financial fraud or mismanagement;
• falsifying financial or corporate reporting;
• insider trading;
• unauthorised use of Alceon’s confidential information;
• improper use of Alceon’s physical or intellectual property;
• failure to comply with, or breach of, legal or regulatory requirements;
• conduct endangering health and safety or causing damage to the environment; and
• deliberate concealment of any of the

There is an expectation that anyone reporting a wrongdoing has reasonable grounds to suspect the information they are disclosing is true, but there will be no penalty if the information turns out to be incorrect. Those reporting should provide the information upon which their suspicion is based, but need not have all the details or have conducted their own investigation.

5.  False or misleading reports

Any false reports made, where the person reporting is intentionally misleading or knows the information is not true, will be considered a serious matter that could result in disciplinary action, including potential termination of employment. The protections under this policy or the applicable law in Australia will not be available for deliberate false reporting.

6. How to make a report

Reports should be made or via Alceon’s compliance officer:

Melanie Hedges – [email protected]

This will enable Alceon to best protect the confidentiality of the report and the reporter’s identity. More information on protecting identity is contained in section 7.

Those reporting should provide as much information as possible, including details of the wrongdoing, people involved, dates, locations and other related information.

Concerns can also be reported in person to one of the following “eligible recipients”:

• any other member of Alceon’s executive team
• a member of Alceon’s board
• any other eligible recipient listed in Annexure A

Those not wanting to reveal their identity can make an anonymous report. However, providing the reporter’s name when reporting wrongdoing will make it easier for Alceon to investigate the concern raised. For example, the context in which wrongdoing was observed is likely to be useful information. Employees and others who report wrongdoing are protected by Alceon including maintaining confidentiality of the reports and the identity of the reporter. The law in Australia contains additional whistleblower protections, which are summarised in Annexure 1. Accordingly, anyone reporting should feel confident that their identity will remain confidential.

Where no name is provided, Alceon will assess the disclosure in the same way as if identity had been revealed, and any investigation will be conducted as best as possible in the circumstances. However, an investigation might not be possible unless sufficient information is provided.

7. Alceon’s commitment to those who report wrongdoing

7.1 Alceon’s commitment

Alceon is committed to protecting and supporting people who report a potential wrongdoing under this Policy. This includes:

• protection of the identity of a reporter;
• making sure that those who report do not suffer detriment as a result of speaking up; and
• offering those who report appropriate protections based on their circumstances, the nature of the potential wrongdoing and the people involved.

7.2 Protecting a reporter’s identity

When reporting wrongdoing, the reporter’s identity, and any information that Alceon has as a result of the report that is likely to lead to identification, will only be disclosed if:

• the person reporting gives consent for Alceon to disclose that information;
• Alceon considers such disclosure should be made to:
  • Australian Securities & Investments Commission, the Australian Federal Police or the Commissioner of Taxation;
  • a Commonwealth authority or a State or Territory authority for the purpose of assisting the authority perform its functions or duties;
• a lawyer for legal advice or representation in relation to whistleblower laws; or
• in the case of information likely to identify the person reporting, it is reasonably necessary to disclose the information for the purposes of an investigation, and all reasonable steps are taken to prevent someone from discovering the reporter’s

7.3 Preventing victimisation and detriment to whistleblowers

Alceon will not tolerate any detrimental conduct against anyone on the basis of reporting or being suspected of reporting a wrongdoing, including conduct against that person’s colleagues, employer (if a contractor) or relatives.

Examples of detrimental conduct include the following:

• discrimination, detriment or damage to a person’s reputation;
• harassment, intimidation or retaliation;
• a demotion or dismissal; or
• threats of any of the above, including implied

Any person involved in detrimental conduct may be subject to disciplinary action including termination of employment or engagement. Alceon has the right to refer any person that has engaged in detrimental conduct to law enforcement authorities for further investigation.

7.4 Protecting reporters from detriment

The measures provided to protect those who report will depend on the risks present, based on the nature of the wrongdoing and people involved. Protections may include the following, at Alceon’s discretion:

• assigning a whistleblower support officer as a confidential contact to discuss any concerns following the making of the report;
• monitoring and managing the behaviour of other employees;
• relocating or revising the reporting lines of employees;
• offering a leave of absence or arranging flexible working while a matter is investigated; and
• rectifying any detriment that has been

8. Investigations

Alceon takes all reports of potential wrongdoing seriously. All reports will be assessed and, based on the nature and circumstances of the disclosure, a decision made as to whether an investigation is required. For example, reports of potential wrongdoing of a minor nature that can be resolved informally will typically not require the same level of response as disclosures involving a large-scale and complex investigation.

Any investigation will be conducted in a timely, fair and objective manner, and independent from any persons to whom the report relates. Investigations will generally be overseen by the compliance officer. Other people, including employees or external advisers, may also be asked to assist or run the investigation.

Where possible, the person reporting the wrongdoing will be informed how Alceon is responding to their report, including whether an investigation will be conducted.

9. Fair treatment of persons involved

Unless there are confidentiality or other reasons not to do so, employees who are the subject of a report of wrongdoing will be informed of the matters raised in the report at an appropriate time, and will be given a chance to respond to any allegations made against them. They will also be advised of the outcome of any investigation.

10. Internal reporting

The Alceon board will receive a summary of reports made under this policy at least quarterly. The summary will not identify individual reporters.

11. Availability of this policy

Alceon will ensure that all employees have access to and are informed about this policy.

12. Review of this policy

This policy will be reviewed regularly. In particular, within the constraints of confidentiality and any other legal restrictions, the review will consider the fairness of the investigations undertaken, any consequences for people who have reported wrongdoing and compliance with this policy generally. The review will consider whether the policy is operating effectively and whether any changes are required.

Annexure A: Legal protections provided to whistleblowers in Australia

1.When legislative protections may apply

The law in Australia protects certain persons (including current and former employees and suppliers, as well as their relatives and dependants, and associates of Alceon) who make a disclosure qualifying for protection (“protected disclosure”) to certain people.

Alceon encourages reporting of concerns of wrongdoing under its whistleblower policy. The law in Australia offers the same protections if making a protected disclosure to certain other persons in some cases. Details of those persons to whom a protected disclosure can be made are set out below in section 2 of this Annexure.

Protections and remedies available to those who make a protected disclosure are set out in section 3 of this Annexure. A protected disclosure that does not follow the Alceon whistleblower policy will still attract the legal protections under applicable Australian law.

2. Protected disclosures

To be a “protected disclosure” information must relate to “disclosable matters” and be made to “eligible” persons or organisations. Examples of the type of information and eligible recipients are outlined in the following table:

A “personal work-related grievance” is not a protected disclosure, except if:

• it concerns detriment to a discloser because they have made, are suspected of making or could make a report of wrongdoing; or
• it is made to a legal practitioner for the purposes of obtaining legal advice or legal representation in relation to the operation of the law about whistleblowers.

A complaint is not a “personal work-related grievance’” and would be a protected disclosure if it:

• has significant implications for an entity regulated under the law (e.g. Alceon) that do not relate to the discloser;
• concerns conduct, or alleged conduct, in contravention of specified corporate and financial services laws, or that constitutes an offence punishable by 12 months or more imprisonment under any other Commonwealth laws;
• concerns conduct that represents a danger to the public or financial system; or
• concerns conduct prescribed by the

The law also protects certain disclosures made in “emergency” and “public interest” situations, in which case disclosures can be made to additional recipients.

3. Specific protections and remedies

The Australian law provides protections if a “protected disclosure” is made, including that:

• the discloser is not subject to any civil, criminal or administrative liability for making the disclosure (other than for making a false disclosure);
• no contractual or other remedy may be enforced or exercised against the discloser the basis of the disclosure; and
• in some limited circumstances (e.g. if the disclosure has been made to a regulator such as ASIC), the information provided may not be admissible in evidence against a discloser in criminal proceedings or in proceedings for the imposition of a penalty, other than proceedings in respect of the falsity of the information.

Except as provided above, the protections under Australian law do not grant immunity for any misconduct a discloser has engaged in that is revealed in their disclosure.

Compensation and other remedies may also be available through the courts for loss, damage or injury suffered because of a disclosure or if Alceon failed to take reasonable precautions and exercise due diligence to prevent detrimental conduct.