Legal Information

Capital Connect Group Limited ("Capital Connect", "we", "us", or "our") is committed to protecting the privacy of individuals who interact with our website and services. This Privacy Policy explains how we collect, use, store, and disclose personal information in accordance with the Privacy Act 2020.

Information We Collect

We may collect personal information when you:

• Submit an enquiry or contact form on our website
• Request investor documentation or subscribe to fund communications
• Engage with us directly by telephone, email or in person
• Complete investor onboarding or identity verification procedures

Personal information collected may include your name, email address, telephone number, postal address, company name, and investment-related information necessary to administer your relationship with us.

Website Analytics and Cookies

Our website may use cookies and third-party analytics tools (such as Google Analytics) to collect anonymous information about how visitors interact with the site. This may include pages visited, time on site, and referring sources. This information is used in aggregate form to improve website performance and user experience. It does not identify individual visitors.

You may disable cookies through your browser settings; however, some site functionality may be affected.

Use of Personal Information

We use personal information for the purposes for which it was collected, including to:

• Respond to enquiries and provide information about our fund and services
• Administer investor applications and ongoing investor relationships
• Comply with legal obligations including under the AML/CFT Act 2009 and the FMCA 2013
• Send fund updates, reports, and distribution notices to existing investors
• Improve our website and communications

Data Storage and Security

Personal information is stored securely on systems based in New Zealand and/or with trusted third-party service providers who are contractually required to maintain appropriate data security standards. We take reasonable steps to protect personal information from unauthorised access, use, disclosure, or loss.

Third-Party Service Providers

We may share personal information with trusted service providers who assist us in operating our business, including legal advisers, accountants, technology providers, and fund administrators. These parties are required to handle your information in a manner consistent with this Privacy Policy and applicable law.

We do not sell, rent, or otherwise disclose your personal information to unrelated third parties for marketing purposes.

Your Rights

Under the Privacy Act 2020, you have the right to request access to personal information we hold about you, and to request correction of that information if it is inaccurate, incomplete, or outdated. To exercise these rights, please contact us at info@capitalconnect.co.nz.

We will respond to access and correction requests within a reasonable timeframe and in accordance with our obligations under the Privacy Act 2020.

Changes to This Policy

We may update this Privacy Policy from time to time. The current version will always be available on this website. Your continued use of our website following any update constitutes your acceptance of the revised policy.

By accessing and using the Capital Connect Group website at capitalconnectnz.com (the "Website"), you agree to be bound by these Terms of Use. If you do not agree to these terms, please cease use of the Website immediately.

Intellectual Property

All content on this Website, including but not limited to text, graphics, logos, images, and data, is the property of Capital Connect Group Limited and is protected by applicable New Zealand and international intellectual property laws. You may not reproduce, distribute, or otherwise use any content from this Website without our prior written consent.

Acceptable Use

You agree to use this Website only for lawful purposes and in a manner that does not infringe the rights of others. You must not:

• Use the Website in any way that may cause damage to or impair the availability of the Website
• Transmit any unlawful, defamatory, obscene, or otherwise objectionable content
• Attempt to gain unauthorised access to any part of the Website or its underlying systems
• Use the Website to transmit unsolicited commercial communications

Accuracy of Information

While we take reasonable care to ensure the information on this Website is accurate and current, we make no representation or warranty as to its completeness, accuracy, or fitness for any particular purpose. Information may be changed or updated without notice. You should not rely solely on information contained on this Website when making investment or financial decisions.

Limitation of Liability

To the maximum extent permitted by law, Capital Connect Group Limited excludes all liability for any loss or damage (including indirect, consequential, or special loss) arising from your use of or reliance on this Website or its content. This exclusion applies regardless of whether such liability arises in contract, tort, equity, or otherwise.

Third-Party Links

This Website may contain links to third-party websites. These links are provided for convenience only. Capital Connect Group does not endorse, control, or take responsibility for the content of any linked website. Access to any linked site is at your own risk.

Intended Audience

This Website is intended for wholesale investors as defined under the Financial Markets Conduct Act 2013. The content is not directed at retail investors and should not be accessed or relied upon by persons who do not meet the wholesale investor criteria under that Act.

Governing Law

These Terms of Use are governed by and construed in accordance with the laws of New Zealand. Any disputes arising in connection with these terms shall be subject to the exclusive jurisdiction of the New Zealand courts.

The information contained on this Website is provided by Capital Connect Group Limited for general information purposes only. It does not constitute financial advice, investment advice, legal advice, or any other professional advice. Nothing on this Website should be construed as an offer, invitation, solicitation, or recommendation to acquire or dispose of any financial product or to engage in any investment strategy.

Not a Regulated Offer

Capital Connect, and any other investment opportunities described on this Website, are not offered under a regulated offer or Product Disclosure Statement. These opportunities are available exclusively to wholesale investors as defined under the Financial Markets Conduct Act 2013 and have not been registered with the Financial Markets Authority.

No Reliance

You should not rely on any information contained on this Website as the basis for making an investment or financial decision. Before making any investment decision, you should seek independent legal, financial, and tax advice appropriate to your individual circumstances.

Forward-Looking Statements

Any statements on this Website that are not historical facts may be forward-looking statements. Such statements are based on current expectations and assumptions and are subject to risks and uncertainties that could cause actual outcomes to differ materially. Capital Connect Group makes no representation that any forward-looking statement will prove to be correct.

No Warranty

Capital Connect Group makes no warranty, express or implied, regarding the accuracy, completeness, or currency of information on this Website. All information is subject to change without notice.

This Website and all investment opportunities described herein are intended solely for wholesale investors as defined under the Financial Markets Conduct Act 2013 (FMCA).

Definition of Wholesale Investor

Under the FMCA, a person qualifies as a wholesale investor if they meet one or more of the following criteria:

• They are an investment business or entity acting in the course of its investment activity
• They meet the investment activity criteria, having carried out two or more transactions of at least NZD 1,000,000 each in the preceding two years
• They have net assets of at least NZD 5,000,000 as certified by a chartered accountant or other eligible certifier
• They invest a minimum of NZD 750,000 in a single transaction
• They are a government agency, registered bank, or other qualifying large entity under the FMCA

Not a Regulated Offer

The investment opportunities described on this Website are not offers to the general public and are not made under a regulated offer, Product Disclosure Statement, or any other disclosure document required under the FMCA. These opportunities are exempt from such requirements pursuant to the wholesale investor exemption under the FMCA.

Important

If you are not a wholesale investor, you should not access, rely upon, or act on any information contained on this Website. Capital Connect Group reserves the right to decline any application from a person who does not meet the wholesale investor criteria.

Investing involves risk. Before making any investment decision, you should carefully consider the risks involved and seek independent professional advice tailored to your circumstances.

Capital at Risk

The value of your investment may go down as well as up. You may receive back less than the amount you invest. Capital Connect Group does not guarantee the return of capital or any particular rate of return.

Returns Are Not Guaranteed

Any target, projected, or indicative returns described in our materials are forward-looking estimates based on current assumptions and market conditions. They do not represent a guarantee of actual returns. Actual returns may be lower than indicated, or no returns may be received at all.

Past Performance

Past performance is not a reliable indicator of future performance. Historical returns, track records, or case studies referenced in our materials should not be relied upon as a guide to future outcomes.

Liquidity Risk

Investments in private credit funds such as Capital Connect are illiquid. There is no guaranteed active secondary market for interests in the fund, and your capital may be locked up for a period. Redemption is subject to the terms of the applicable Limited Partnership Agreement.

Credit and Counterparty Risk

The fund is exposed to the credit risk of individual borrowers. Borrower default, adverse changes in the value of security assets, or deterioration in economic conditions may result in losses to the fund.

Regulatory and Legal Risk

Changes in legislation, regulation, or tax treatment may adversely affect the fund or your investment. Capital Connect Group is not responsible for such changes and cannot predict their impact.

This risk warning does not describe all risks associated with an investment in Capital Connect Group funds. You should review the Information Memorandum and Limited Partnership Agreement carefully and seek independent advice before investing.

Capital Connect Group Limited is committed to full compliance with the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) and associated regulations.

Our Obligations

As a reporting entity under the AML/CFT Act, Capital Connect Group is required to:

• Conduct customer due diligence (CDD) on all investors and counterparties
• Verify the identity of investors and, where applicable, their beneficial owners
• Monitor transactions on an ongoing basis for suspicious activity
• Report suspicious transactions to the New Zealand Police Financial Intelligence Unit as required
• Maintain records in accordance with the requirements of the AML/CFT Act

Investor Identity Verification

Before accepting any investment, Capital Connect Group will conduct identity verification and due diligence procedures. Prospective investors will be required to provide:

• Government-issued photographic identification (e.g. passport or driver licence)
• Proof of residential or registered address
• For entities, corporate documentation including certificate of incorporation, beneficial ownership information, and authorised signatory details
• Source of funds and source of wealth information where required

Politically Exposed Persons

Capital Connect Group applies enhanced due diligence to investors who are, or are associated with, politically exposed persons (PEPs) as defined under the AML/CFT Act. Additional verification and approval steps will apply in such cases.

Non-Compliance

Capital Connect Group reserves the right to decline, suspend, or terminate any investment relationship where AML/CFT obligations cannot be satisfied, or where there is reasonable concern about the source of funds. We are required by law to report certain matters to authorities and cannot notify affected parties of such reporting.

For enquiries regarding our AML/CFT procedures, please contact us at info@capitalconnect.co.nz.

Capital Connect Group is committed to dealing with all complaints promptly, fairly, and transparently. We take all feedback seriously and view complaints as an opportunity to improve our services.

How to Make a Complaint

If you have a complaint about Capital Connect Group, our services, or any investment-related matter, please contact us in the first instance by:

• Email: info@capitalconnect.co.nz
• Post: Capital Connect Group, Harbourview Building, Level 7, 152 Quay Street, Auckland 1010

Please include your full name, contact details, a clear description of your complaint, and any supporting information or documentation.

Our Response Process

• We will acknowledge receipt of your complaint within 2 business days
• We will investigate your complaint thoroughly and keep you informed of progress
• We aim to provide a substantive response within 20 business days of receipt
• If the matter is complex and requires additional time, we will notify you and provide a revised timeframe

Resolution

If we are unable to resolve your complaint to your satisfaction through our internal process, you may wish to seek independent advice or refer your complaint to an appropriate external body. Capital Connect Group will cooperate fully with any such process.

Records

We maintain a register of all complaints received and our responses. This register is reviewed regularly to identify trends and areas for improvement.