Conflict of Interest Statement - Equity Crowdfunding

The attached disclosure is not general or personal advice and is presented without taking into consideration any specific person’s objectives, financial situation or needs. It is disclosure for the purposes of better understanding the service we offer and the actions we may take. Investors should, before acting on information, consider the offer document, general risk warning and likelihood of liquidity, having regard to their personal objectives, financial situation or needs. We recommend investors obtain financial advice specific to their situation before making any financial investment decision.

Billfolda is the first equity crowdfunding platform in Australia to accept payment in equity as part of that service to issuers and investors, with some obvious implications for both, like making sure that all funds raised are remitted to the company. That said, it does put us into potential conflict with investors in regards to the sale of those shares. Our commitment and priorities are attached here to help mitigate that conflict and provide notice of our intentions. Our first priority is to retail investors, who will be locked out of any secondary market due to requirements of the Corporations Act for 12 months. Billfolda is an wholesale investor so technically that lock in period does not apply to us, however we agree to never trade during this period, unless compelled by large events such as;

• A takeover offer;
• Trade sale;
• A condition of share ownership in a company’s constitution;
• A corporate reconstruction of Billfolda and its related parties;
• Falling below the statutory Surplus liquid funds (SLF) requirement for our AFSL, and
• The 33% requirement*

Secondly there are cashflow considerations*, like the tax bills Billfolda has to pay. Yes that’s right, Billfolda will be treated as having received income on the funds raised even though we have not kept any of the money (we have an asset in the shares instead).

As such, all investors must be aware that from time to time we will be open to sell up to 33.33% of the shares Billfolda holds as a result of offers made on the platform, and that may happen at any time after they are acquired.

Finally, and with the assumption of a secondary market, the balance of shares Billfolda holds may be traded after the above conditions are met.

Should this policy change, a copy of the updated policy will be made available on Billfolda’s website (Billfolda.com) one month before the change takes effect.

For further information please see our financial services guide (FSG)