Financial Services Guide ('FSG')

Issue date: 15 December 2021

The provider of the services described in this Financial Services Guide is Stockspot Pty Ltd (ACN 163 214 319) as Authorised Representative (AR No. 453421) of Sanlam Private Wealth Pty Ltd (ABN 18 136 960 775) AFSL Number: 337927. 

This document

The purpose of this Financial Services Guide (“FSG”) is to help you make an informed decision about the services we offer. This FSG is an important document that explains how we provide financial services to you. You should read this FSG carefully before using our services. It is intended to give you sufficient information to decide whether to obtain financial services from us.

In this document you will find information about:

  • who we are
  • what financial services we provide and the products to which those services relate
  • what our responsibilities are and what type of advice we provide
  • how you can instruct us
  • what you can expect to pay for the financial services
  • what remuneration and other benefits may be paid to us, our employees or others
  • what to do if you have a complaint, and how it will be dealt with
  • for what purpose we use your contact data; and
  • how you can contact us.

This Financial Services Guide (FSG) is dated 15 December 2021 and is provided to you by Stockspot Pty Ltd ACN 163 214 319 (Stockspot, We, Our or Us) to inform you of the financial services we provide and to comply with our obligations as Corporate Authorised Representative (AR No. 453421) of Sanlam Private Wealth Pty Ltd (Sanlam). Sanlam holds an Australian Financial Services License (AFS Licence No. 337927) and has authorised the creation and distribution of this FSG. This FSG contains only general information about the services we offer.

You can contact Stockspot at:

Email: enquiries@stockspot.com.au

Postal address: PO Box R1573, Royal Exchange NSW 1225

Phone: (02) 8091 8090

You can contact Sanlam at:

Email: spw_compliance@sanlamprivatewealth.com.au

Postal address: Level 2, 33 York St, Sydney NSW 2000

Phone: (02) 8245 0500

About us

Our mission

Our mission is to make investing accessible for all Australians. We combine financial experience with industry leading strategies to deliver high-performing, low-fee investment portfolios.

Our guiding principles:

  • Passive investing (buying and holding investments) provides superior after-fee returns compared to active investing.
  • Low fees correlate strongly with better returns.
  • Diversification across broad asset classes, rather than individual shares or funds, spreads risk and results in steadier returns.
  • Rebalancing periodically and reviewing asset allocation keeps portfolios at desired risk levels.

What services are we authorised to provide?

Stockspot is an Authorised Representative (AR No. 453421) of Sanlam, which holds AFS Licence No. 337927. Stockspot is authorised by Sanlam to provide general and personal advice on and deal in the following classes of financial products to retail and wholesale clients (within the definition of the Corporations Act): Securities; Interests in Managed Investment Schemes including IDPS; Superannuation and Interests in Managed Investment Schemes limited to MDA Services. We are not authorised to include or provide custodial or depository services.

Stockspot is a representative of, and acts on behalf of, Sanlam. Stockspot does not act as a representative of any other licensee in relation to the services or products it provides.

The Stockspot website provides general information as well as advice about investing, Exchange Traded Funds (ETFs) and MDA Services. Where we provide general advice, that information or advice does not take into account your personal and financial circumstances, needs and objectives. Because of that you should consider the appropriateness of the advice with regards to your personal and financial circumstances before acting on that advice.

You can also apply for personal investment advice from Stockspot via the website. Stockspot will assess your personal circumstances and suitability for the Stockspot Model Portfolios which are offered as part of an MDA Service. If you are considered a suitable candidate you will be provided with an MDA Contract which includes a Statement of Advice and Investment Program and complies with Division 3 of Part 7.7 of the Corporations Act. The SOA and MDA Contract will be issued in digital format for you to review and sign if you would like to proceed with the advice and access our services. We will also email you a copy to the email address provided in your application.

We will also provide you with other relevant documents including PDS documents for any financial products we recommend and Service Agreements for any service providers.

Any personal advice we provide is valid for six (6) months from the date you take the Stockspot risk profile assessment. If you have not acted on this advice but wish to proceed after six (6) months, we will ask you to re-complete the risk profile assessment to ensure that we have collected the most relevant and up to date information about you.

More information on investing: For general information about investing (including a managed funds calculator to help you understand the effect of fees and different investment options) go to www.moneysmart.gov.au or visit Stockspot's website at www.stockspot.com.au

What is an MDA Service?

An MDA Service is a managed investment scheme and a facility for making a financial investment that has the following key features:

  • You give to the MDA Provider, i.e. Sanlam, access to money or money's worth (client contributions);
  • Sanlam, as the MDA Provider, and Stockspot, as the MDA Manager, has the discretion to invest in financial products using your contributions without prior reference to you for each transaction;
  • You agree with Sanlam and Stockspot that assets derived directly or indirectly from your contributions are managed as a discrete portfolio belonging to you; and
  • You have an understanding that you will derive benefits from the MDA service, including benefits from Sanlam's and Stockspot's expertise in investment selection and other services offered as part of the MDA service.

Rather than being part of a large pool of money and/or investments, your portfolio is owned by you and managed for you pursuant to the Investment Program included in your SOA and MDA Contract.

You are always the direct legal and beneficial owner of the investments which are registered in your name.

In order to access this service, you agree to give to the MDA Provider (Sanlam) authority to act on your behalf in selecting and appointing an MDA Manager and overseeing the services provided to you including MDA Management, Execution, Cash Management, Reporting and Audit. Stockspot will be the appointed MDA Manager for the MDA Service it offers to you via Sanlam. As the appointed MDA Manager, it is Stockspot’s responsibility to make investments on your behalf according to an agreed Investment Program. In developing the Investment Program, we will apply our principles of diversification and risk management to meet your investment requirements. With an MDA Service, not only will you be the beneficial owner of the portfolio, but you will enjoy owner benefits and will have the ability to see the exact composition and value of your portfolio at any time (via our secure online service).

To find out more information about the structure of the MDA Service offered by Sanlam, please read the MDA Guide and the MDA Contract we provide to you.

Stockspot (the MDA Manager) will be responsible for reviewing the Investment Program included in the SOA once every 13 months.

Where your relevant personal circumstances have changed you will be responsible for informing either Sanlam or Stockspot. Stockspot will review the Investment Program and MDA Contract to ensure it remains suitable for you.

What is the MDA Contract?

In order to provide you with MDA services you need to open an MDA. To open an MDA you must enter into an “MDA Contract” with Sanlam before the MDA service can be provided.

The MDA Contract will include an Investment Program that is prepared in accordance with the requirements in Division 3 of Part 7.7 of the Corporations Act (ie. provision of personal advice to retail clients and Statement of Advice) and Division 2 of Part 7.7A of the Corporations Act (ie. best interest obligations). The Investment Program will contain the following information:

  • The nature and scope of the discretions Sanlam (and any person authorised by Sanlam in the MDA Contract) will be authorised and required to exercise under the MDA Contract and any investment strategy that is to be applied in exercising those discretions;
  • Any significant risks associated with the MDA Contract;
  • The basis on which Sanlam considers the MDA Contract to be suitable for you; and
  • Warnings about the MDA Contract, such as:
    • It may cease to be suitable for you if your relevant circumstances change; and
    • It may not be suitable for you if you have provided Sanlam with limited or inaccurate personal information about your relevant circumstances.

A word of warning on risk

It is important to understand that, even with a sensible diversified investment strategy and appropriate time horizon, investing always involves some risk.

The financial performance of the Stockspot Model Portfolios may be influenced by a variety of general domestic and international economic factors and business conditions, which are outside the control of Stockspot. These include (but are not limited to) changes in the inflation rate, commodities prices, exchange rates, interest rates, government fiscal, monetary and regulatory policy, natural disasters, health pandemics and acts of terrorism.

Stockspot may employ certain strategies that depend upon the reliability and accuracy of the analytical investment processes. To the extent such investment processes (or the assumptions underlying them) do not prove to be correct, your Stockspot Model Portfolio (or chosen Stockspot Sustainable Portfolio) may not perform as anticipated, which could result in losses. Please carefully read the risks summarised in the MDA Contract, the PDS documents for each ETF, and the Terms and Conditions issued by the Third Party Service Provider and Cash Account provider.

No guarantee can be given in respect of the future earnings of the MDA Service or the capital appreciation of your investments within the MDA. The price of investments that Stockspot has purchased on behalf of you can fall and rise over time. There are risks associated with the underlying investments within the MDA, which are outlined in the relevant PDS for each ETF. You should carefully consider the risks of each ETF before deciding to invest in this MDA.

The operating performance of the MDA Service may also be impacted by industry risk factors. These factors are outside the control of Stockspot. Such factors include (but are not limited to) increased compliance costs and variations in legislation and government policies.

To counter the potential impacts of industry risk, all Stockspot Model Portfolios are constructed on a direct-ownership basis. This means that you, as the investor, do not have counterparty risk. Regardless of the status of Stockspot or its suppliers, you, as the full legal and beneficial owner of your investments, separately hold your investments under your own unique Holder Identification Number (HIN). You can use your HIN to check your holdings at the share registries.

For further details about the potential risks involved with investing through an MDA Service we refer you to Sanlam's FSG.

Getting to know you

In order to offer personal advice to you, we need to understand your financial needs, objectives and risk profile.

This enables us to advise on an investment strategy that is appropriate and relevant to your situation.

It will take into account your objectives, financial situation and needs (relevant personal circumstances) as provided by you in the Stockspot application process.

To determine the right investment strategy for you, we have a comprehensive risk profile assessment that asks a series of questions on your:

  1. Goals
  2. Investment timeframe
  3. Cash flow needs
  4. Current high interest debt
  5. Your comfort with risk

We won't pass on your personal financial information to third parties unless you give us permission so please complete the survey as accurately as possible. The information you provide us determines the advice and recommendations we provide to you. If you provide incorrect or incomplete information our advice may not be appropriate for your circumstances.

Based on the information provided on your risk profile, financial circumstances and objectives, if appropriate, Stockspot will recommend an Investment Program including a Stockspot Model Portfolio. Our services are not appropriate for everyone so if your personal circumstances are outside the scope of our expertise we will instead advise you to contact an appropriate specialist financial adviser.

If we do suggest a Model Portfolio, the underlying Investment Strategy for the Model Portfolio will be included in the Investment Program which forms part of the MDA Contract and is included in the Statement of Advice we give to you during the application process. You may also have the option to choose a Sustainable version of the Stockspot Model portfolios.

Please read the contract carefully because it explains the basis for our recommendations and details the services we offer. If you agree to the SOA and Investment Program and wish to enter into the MDA Contract you will be asked to digitally sign the MDA Contract to access our services.

We retain all MDA Contracts for as long as you are our client and for at least seven years after you have closed your account. You may request a replacement copy of your MDA Contract at any time within that period. If you decide that our services aren’t what you were after, you are welcome to terminate your MDA Contract and our services at any time. There are no exit fees payable by you for withdrawals from your Stockspot account.

Your privacy

The privacy of your personal information is of significant importance to us. We value your trust and aim to help you manage and build wealth over the long term. The protection of your personal information is a vital part of this relationship. We will not disclose your information to any third parties unless we are required to do so under the law. You can find out more about our Privacy Policy on our website:

https://www.stockspot.com.au/legal/privacy-policy/

What other disclosure documents and statements will I receive?

In addition to this Financial Services Guide, you may also receive from Stockspot;

  • An MDA Contract
  • Our MDA Guide
  • Client Service Agreements from any third party service providers
  • Statement of Advice (SOA) that sets out the personal advice we are providing, including any recommendations we offer along with our rationale for our recommendations and information about any fees, commissions, associations or relationships which might influence the provision of that advice.
  • Product Disclosure Statements (PDS’s) where we have recommended ETFs. The PDS includes information about the ETF products so that you can make an informed decision whether to acquire them. These also include any relevant terms, significant risks and costs associated with the ETFs.

Where you maintain the advice relationship with us, a Statement of Advice may not be provided for further advice situations provided that your circumstances and the basis of the advice are not significantly different. However, we are required to keep a record of the advice. You may request a copy of the Record of Advice (“ROA”) we keep up to 7 years after the advice was given.

How can I instruct Stockspot?

Apply for our services

You can apply for our MDA services by agreeing to and electronically signing your personalised MDA Contract. Upon receipt of your information we will need to verify your identity as part of our Know Your Client (KYC) and Anti-Money Laundering (AML) obligations.

Make an investment

To make an investment you will need to deposit funds into your Stockspot cash account. Stockspot will use these funds to invest into your Model Portfolio, and endeavor to invest within one business day of the funds being received. You can top up your investment by depositing funds into your Stockspot cash account in the same way.

Select your active account

You can select where new deposits will be invested. Choose either your Stockspot Model Portfolio or Stockspot Savings. Manage your active account settings in 'Transfer Money - Deposit Funds'.

Transfer money

You can transfer money between your Stockspot Model Portfolio and Stockspot Savings from the 'Transfer Money - Move Money' section of the Stockspot investment dashboard. Keep in mind that this may involve selling some of your investments and realising capital gains or losses. We recommend you seek advice from your tax agent about the tax consequences first.

Make a withdrawal

Withdrawal requests can be made in the 'Transfer Money' section of the Stockspot investment dashboard. To receive a cash payment from your Stockspot account, you are required to nominate a bank account in the same name as your account for funds to be transferred into. Withdrawals take four to five business days. This is in line with the ASX T+2 settlement period for investments. Once the funds clear they are transferred to your linked account the next business day. There are no additional costs to sell your investments.

Withdrawal requests received prior to 10am Monday-Friday are usually processed the same day.

Withdrawal requests received after 10am Monday-Friday or on weekends are processed the next business day.

Stockspot does not charge any fees for full or partial withdrawals.

Update your profile

You can notify us of any change in your personal situation, risk profile or circumstances by updating your profile in the 'Investment profile' section of the Stockspot investment dashboard. We recommend you keep your profile up to date and let us know about any changes as soon as possible.

Opt out

You can opt out of our services at any time by making a full withdrawal request. The process takes 4-5 business days for the funds to arrive in your linked bank account. There are no brokerage or exit fees payable for full withdrawals from your Stockspot account.

Asset Transfers

If you are transferring to another adviser or service you must notify Stockspot in writing:

https://www.stockspot.com.au/contact-us/

There is an administration fee of $30 per holding for Off-Market Transfers and HIN transfers out of Stockspot. There is no cost for selling your investments directly via the Stockspot dashboard.

Small portfolios under $10,000

For portfolios under $10,000, Stockspot will 'phase-in' the investments gradually in order to effectively manage risk versus return for smaller portfolios. During the phase in period, the portfolios are well diversified with exposure to growth and defensive investments.

We recommend that you aim to build your portfolio to $10,000 as soon as possible (ideally within 12 months) to ensure that you enjoy the full diversification benefits.

Who provides services under this MDA Service?

MDA Provider Sanlam Private Wealth Pty Ltd, (AFS License number 337927) is the MDA Provider.
Sanlam Private Wealth provides integrated wealth management solutions for individuals and their families, trusts, charities and corporates in the UK, South Africa, Western Europe and Australia.
MDA Manager Stockspot Pty Ltd (AR number 453421) has been authorised as MDA Manager and is responsible for managing your account pursuant to this Investment Program.
Stockspot is Australia's first and largest automated investment adviser and fund manager.
See www.stockspot.com.au for more information about Stockspot
Adviser Stockspot Pty Ltd (AR number 453421) is your Adviser. Stockspot is responsible for:
  • Providing personal advice to you regarding this MDA Service;
  • Reviewing the MDA Service when your relevant personal and financial circumstances change to assess whether or not it continues to be suitable for you; and
  • Conducting an annual review of the Investment Program and assessing whether or not it continues to be suitable for you.
Stockspot is Australia's first and largest automated investment adviser and fund manager.
See www.stockspot.com.au for more information about Stockspot
Third Party Service Provider OpenMarkets is an ASX retail broking service provider
See important documents about OpenMarkets
Client Contract (trading T&C's)
Financial Services Guide
Privacy Policy
Client Cash Account Providers For cash accounts opened after 15/09/2021 your funds are held in a trust account (Trust Account) with Australia and New Zealand Banking Group Limited ABN 11 005 357 522 (ANZ) by OpenMarkets.
For cash accounts opened before 15/09/2021 your funds are held in a Cash Management Account (CMA) with Macquarie Bank Ltd (AFS License number 237502)
VIX Verify ID verification services
AWS Secure server
KMB Business Advisers and Chartered Accountants Audit services

Details of associations or relationships

In order to provide our services as an Adviser and MDA Manager, Stockspot has relationships with Sanlam (the MDA Provider and AFS License holder), Third Party Service Providers, Cash Account Providers and Portfolio auditing services (as outlined above). Stockspot and Sanlam have chosen these external service providers because they are the most suitable for this MDA. The commercial relationships Stockspot and Sanlam have with external service providers in no way conflicts with the provision of financial services to you.

Stockspot does not receive any financial incentives from external service providers or the ETF issuers. Any rebate Stockspot receives on cash amounts invested with the cash account providers will be rebated to you. Stockspot does not pay commissions to third parties.

Conflicts of interest disclosure

Sanlam, Stockspot, employees thereof and individuals at “arms length” to Stockspot and Sanlam may also hold MDAs with Sanlam.

Should Stockspot become aware of any other conflict of interest or association that might impact its ability to act in the Client's best interest, it will immediately inform the client of such conflict or association and or fully disclose details within the Statement of Advice (SOA).

Dispute resolution

Stockspot provides a dispute resolution service to all of its clients. This obligation is a key tenet of the consumer protection principles of the Australian Financial Services Licensing system. If you have a complaint about any services you should:

  1. Contact Stockspot by phone or email to explain your situation and concerns. Stockspot will do everything possible to resolve your issue promptly;
  2. If this does not resolve your issue, put your complaint in writing addressed to the Compliance Manager, Sanlam at spw_compliance@sanlamprivatewealth.com.au where it will be objectively considered and discussed with you and Stockspot with a view to be settled as soon as possible to your satisfaction; and
  3. If an issue has not been resolved to your satisfaction, you can lodge a complaint with the Australian Financial Complaints Authority, or AFCA. AFCA provides fair and independent financial services complaint resolution that is free to consumers.

Website: www.afca.org.au

Email: info@afca.org.au

Telephone: 1800 931 678 (free call)

In writing to: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001

Professional Indemnity Insurance

In accordance with Regulatory Guide RG126 and Section 912B of the Corporations Act 2001, Sanlam has Professional Indemnity Insurance in place, which covers the work done by its representatives including Stockspot.

Fee Disclosure

Did you know? Small differences in investment performance and fees and costs can have a substantial impact on your long-term returns.

For example, total annual fees and costs of 2% of your investment balance rather than 1% could reduce your final return by up to 20% over a 30 year period (for example, reduce it from $100,000 to $80,000). You should consider whether features, such as investment performance or use of an MDA Service are appropriate for you.

To find out more: If you would like to find out more, or see the impact of the fees based on your own circumstances, the Australian Securities and Investments Commission (ASIC) website (www.moneysmart.gov.au) has a managed funds fee calculator to help you check out different fee options.

The following information shows fees and other costs that you may be charged. These fees and costs may be deducted from your account, from the returns on your investment or from the funds and assets held in your MDA.

Neither Sanlam nor Stockspot provide tax advice and you should obtain advice from an accountant or other professional tax adviser in relation to the application of tax legislation.

You should read all the information about fees and costs because it is important to understand their impact on your investment.

The arrangement between Sanlam, Stockspot and you is governed by the terms and conditions of the MDA Contract. The following tables set out the fees and costs for this MDA.

Type of fee or cost Amount How and when paid
Fees when your money moves in or out of the managed investment product
Establishment fee
The fee to open your investment
Nil N/A
Contribution fee
The fee on each amount contributed to your investment
Nil N/A
Withdrawal fee
The fee on each amount you take out of your investment
Nil N/A
Exit fee
The fee to close your investment*
Nil N/A
Management costs
MDA Service Fee¹
The fees and costs for managing your investment
Bronze: $5.50 per month
All other memberships: up to 0.055% per month of your investment balance, excluding money invested in Stockspot Savings (fees quoted inc. GST – further details provided in table below)
Calculated based on the average of your starting and ending account balance at the 15th of each month, and debited before the end of each month
Service fees
Switching fee
The fee for changing investment options
Nil N/A
Performance Fee¹
The fee on new net profit within a month
Nil N/A
Transaction Fees¹
The fees charged by the Third Party Service Provider for the provision of dealing services
Nil N/A
¹This fee includes an amount payable to an adviser.

*Refer to administration fees (below) for more information on broker-to-broker transfers

Not less than thirty days' notice will be given by Sanlam or Stockspot to you of changes to the terms and conditions of the fees and charges set out under MDA Fees.

MDA Service Fee

The MDA Service Fee is charged on a tiered basis determined by your investment balance. No fee is charged on money invested into Stockspot Savings.

The following tables outlines the tiered structure:

MDA Service Fee - Tiered Fee Structure
An all inclusive fee based on your average account balance each month.
Bronze 0% for the first 6 months, then $5.50 per month (Incl. GST)
New clients investing $10,000 or less
Silver 0.055% per month or 0.66% p.a (Incl. GST)
For account balances between $10,001 - $49,999
Automated rebalancing and dividend reinvestment
Gold 0.055% per month or 0.66% p.a. (Incl. GST)
For account balances between $50,000 - $199,999
Access to Stockspot Themes for portfolio customisation
Automated rebalancing and dividend reinvestment
Platinum 0.044% per month or 0.528% p.a. (Incl GST)
For account balances between $200,000 - $1,999,999
Access to Stockspot Themes (for portfolio customisation)
Automated rebalancing and dividend reinvestment
Diamond 0.033% per month or 0.396% p.a. (Incl GST)
For account balances of $2M+
Automated rebalancing and dividend reinvestment
Access to Stockspot Themes (for portfolio customisation)
Dedicated Investment Adviser

This fee is paid to Sanlam and automatically deducted from your Client Cash Account each month

Example of MDA Fees

The following table provides an example of how the fees and costs within the Sanlam MDA can affect your investment over a one year period.

EXAMPLE BALANCE OF $20,000 WITH NO CONTRIBUTIONS DURING THE YEAR
MDA Service Fee 0.055% (incl GST) per month
Annualised rate is 0.66% p.a. (incl. GST)

Total fees payable to Sanlam on a $20,000 portfolio would be $11 per month (incl GST) (approximately $132 p.a.)

  • ● Portfolio implementation, execution, ongoing review and management;
  • ● All portfolio rebalancing;
  • ● Audit and Compliance of the MDA Service;
  • ● Portfolio reporting accessed via www.stockspot.com.au

The following table provides an example of how the fees and costs within the Sanlam MDA can affect your investment over a one year period. The example assumes a balance of $20,000 at the beginning of the year with a contribution of $10,000 during the year.

EXAMPLE BALANCE OF $20,000 AND $10,000 CONTRIBUTION DURING THE YEAR
MDA Service Fee 0.055% (incl GST) per month
Annualised rate is 0.66% p.a. (incl. GST)

If you had an investment of $20,000 at the beginning of the year and you put in an additional $10,000 in 6 months, you would be charged a fee of $11 per month (for the first 6 months) and $16.50 per month thereafter (based on your account balance).

This equates to 0.66% of your portfolio balance per year (incl GST) and includes:

  • ● Portfolio implementation, execution, ongoing review and management;
  • ● All portfolio rebalancing;
  • ● Audit and Compliance of the MDA Service;
  • ● Portfolio reporting accessed via www.stockspot.com.au

Additional explanation of fees and costs

MDA Service Fee

The MDA Service Fee is calculated based on the average of your starting and ending account balance at the 15th of each month, and debited before the end of each month from your Stockspot Client Cash Account. Fees are automatically debited from the cash balance in your account.

When you lodge a full withdrawal request, the Management Fee will be calculated on the average balance in your account for the month on pro-rata basis and deducted from the account prior to the account closure being processed and finalised.

The Management Fee is quoted inclusive of GST.

Transaction fees

There are no transaction fees applicable to this MDA Service. Brokerage costs are included in the MDA Service Fee.

ETF management fee

ETF management fees are charged by each fund issuer and included in the traded unit price. On a portfolio-weighted basis the ETF management fees are typically 0.27% to 0.30% per year for Stockspot Model Portfolios. ETF management fees for the Stockspot Sustainable portfolios range from 0.34% to 0.47% per year. ETF management fees for the Stockspot Themes range from 0.04% to 0.74% per year.

Administration fees

There is an administration fee of $30 per holding for Off-Market Transfers and HIN transfers out of Stockspot. There is no cost for selling your investments directly via the Stockspot dashboard.

Remuneration or other benefits received by Sanlam’s Representatives and Authorised Representatives

Directors, Employees and Representatives of Sanlam receive salaries, bonuses and other benefits from Sanlam.

External service providers to this MDA Service including Execution, Cash Management, Reporting, Audit and Compliance Services are paid from the fees collected by Sanlam. Once all these costs have been deducted, Stockspot receives net fees collected by Sanlam.

Stockspot receives 100% of the fees that are collected by Sanlam under this MDA contract less the licensing fee it pays Sanlam.

Staff remuneration and benefits

Stockspot staff are remunerated based on salary (including bonuses) and may be shareholders of Stockspot so participate in profits earned in relation to the Stockspot business.