The purpose of this Financial Services Guide (FSG) is to help you decide whether to use any of the financial services we offer. After reading this FSG, you will know:

• who we are
• what financial services and products we provide
• how we (and any other relevant persons) may be remunerated
• whether any relevant associations or relationships exist that may influence our advice
• details on how to get advice and give instructions
• how we protect your personal information
• how to access our internal and external complaints handling arrangements, and
• what we can do and what we expect from you.

Empower Wealth Financial Services Pty Ltd (ABN 61 144 731 644) is a Corporate Authorised Representative (CAR 377067) of Integrated Pathways Financial Services Pty Ltd (ABN 92 650 524 128), which is an Australian Financial Services Licensee (AFSL) (Licence No 536049). In this document Empower Wealth Financial Services Pty Ltd is referred to as ‘we’, ‘us’ or ‘our’.  

Our contact details are as follows:

Integrated Pathways Financial Services Pty Ltd have authorised the distribution of this FSG by Empower Wealth Financials Services Pty Ltd and their Representatives. When you receive personal advice, you will receive a Statement of Advice (SOA). An SOA will:

• explain the advice and the basis of the advice
• provide information about our remuneration (including commissions), and
• disclose any associations or relationships that could potentially influence us in providing the advice.

Once you have your SoA, any further ongoing personal advice that we may provide will be documented in either a further SoA or an RoA depending on the nature of the advice.

Copies of all advice documents will be retained on your client file and, if you have not already been provided with one, you may ask for a copy of these documents at any time.

General advice is based on the consideration of the investment merits of a product without taking into consideration whether the product is suitable for you personally. Such advice will be accompanied by a general advice warning referring to this.

We will also provide you with, or explain how to access, a product disclosure statement (PDS) issued by the product issuer for any financial product we recommend. The PDS contains information about the costs, benefits, risks and other features of the recommended financial product.

To help you make an informed decision, you should read this information before purchasing any recommended financial products.

We can offer financial services and advice that covers the following areas:

• Wealth creation, including advice on securities.
• Retirement planning, including superannuation
• and strategies for transitioning to retirement.
• Risk management and asset protection.
• Retrenchment and redundancy advice.
• Social security/Centrelink entitlements.

From these financial services, certain kinds of financial products may be recommended to you. We can provide advice and arrange transactions on the following classes of financial products:

• Superannuation and retirement savings account products
• Securities
• Managed investments (including an investor-directed portfolio service)
• Margin lending facilities (standard)
• Government debentures, stocks or bonds
• Deposit products
• Life insurance products including investment life and life risk.

We can only provide advice on financial products that are on Integrated Pathways Financial Services approved product list. The approved product list includes a large range of investment and insurance products for which the appropriate research and analysis has been undertaken.

Integrated Pathways Financial Services’ Authorised Representatives cannot advise you on, or influence you in favour of, a financial product which:

• is not on the approved product list, or
• any arrangement where your financial planner can make changes to your portfolio before obtaining your consent unless they are specifically authorised to do so,
  or
• is a product on which they are not authorised to provide advice

You can find details on the Australian Securities and Investment Commissions website at www.asic.gov.au

Should you have a need for products or services which are not listed above or require further specialist advice which we cannot, or are not authorised to provide, we will refer you to another qualified provider.

In the case of where you do not wish to receive our advice, we may deal on your behalf by carrying out your instructions. Where you do not obtain advice, you may face the risk that the financials product/s and or service you select may not fully consider your objectives, financial situation and or needs. In such instances, we may require you to sign a document that records your intention to seek advice from us for the particular financial product/s.

Your financial planner is a registered tax (financial) adviser or a registered tax agent. They are authorised to provide a tax service, where the advice is:

• provided in the context of the personal advice authorised by the Licensee, and
• part of the financial advice which interprets and applies the tax laws (including tax, superannuation and SMSF laws) to your personal circumstances.

Where tax agent services are provided (i.e. those services in relation to the preparation and filing of tax returns, and liaison with the ATO, etc.), these services constitute a separate business activity and are not provided under the Licensee’s AFSL. We are only responsible for advice relating to the financial products and services described in this FSG and our Approved Product List.

Where we outsource tasks associated with the implementation or management of your holdings, such as to Executing Brokers, we will ensure that due skill and care is taken in choosing suitable service providers by executing Service Agreements to monitor the service levels and to review the ongoing performance of these outsourced functions.

You may provide specific instructions to your financial planner by letter, email, telephone, fax or other means as agreed.

The fees and services that you will pay will be set out in a Statement of Advice. Generally, there are options in the way that you can pay for the services we provide and you can discuss the option that best suits your circumstances with your financial planner. The options are:

General advice

We may charge you a fee for any general advice we provide to you. That fee may be either a fixed fee or based on the amount of hours it takes us to prepare and provide you with the general advice. The amount of these fees usually ranges from $2,200 to $4,950 but may exceed this range in complex cases. Details of the fee will be agreed with you beforehand. You may request information about these fees within a reasonable time after receiving this FSG but before you are provided with any general advice.

Personal advice

We will charge you a fee for any personal advice we provide to you. That fee may be either a fixed fee or based on the amount of hours it takes us to prepare and provide you with personal advice. The amount of these fees usually ranges from $2,200 to $4,950 but may exceed this range in complex cases. These fees will be agreed with you beforehand and will be disclosed in a SoA or RoA which will be provided to you.

Ongoing fees

Our ongoing fees depend on the ongoing service that we provide to you. They are typically charged as a percentage based on the value of your portfolio of between 0.60% and 1.05% per annum.  The amount of ongoing fees will depend on your total assets under management and other factors such as the complexity of your portfolio, the regularity of reviews and any additional services we are providing.

Any ongoing fees will be agreed with you in our service agreement.

Brokerage fees

We do not charge you for brokerage but brokerage fees may be payable to third parties who execute transactions on your behalf.

The services and fees will be set out in the SoA or RoA that we provide to you.

Insurance commissions

We receive a one-off upfront commission when you take out an insurance policy we recommend.  The upfront commission will be up to 66% of the first year’s annual premium.

We also receive an ongoing commission payment of up to 22% of the annual premium for as long as you continue to hold the policy.

For example, for an insurance product with an annual premium of $2,000, where the issuer pays us an upfront commission of 66%, we will receive $1,320. The issuer will pay us 22% of the annual premium as ongoing commission for as long as you hold the product. Assuming an annual premium of $2,000, this equates to $440 per year.

You will be advised of the exact amount of these commissions in the SoA or RoA.

Our representatives are paid a base salary and, based on a balanced scorecard approach, a bonus and do not receive commissions from product issuers.

We may also receive additional benefits by way of sponsorship of educations seminars, conferences or training days. Details of any benefits received above $100 will be maintained on a register which is available to you on request.

We may pay a referral fee to an external third-party associate where they refer you to us as a client. The referral fee is usually between $110 and $330. Specific details of any referral fee paid will be disclosed to you in your SoA or RoA.

We provide financial services on behalf of Integrated Pathways Financial Services to you, and will act in your best interests.

Empower Wealth Financial Services, including its shareholders, have no financial interest in any financial product providers with who it deals with. No directors or executive officers of Empower Wealth Financial Services act in a similar capacity within the business of another financial product provider. In the event that we develop any relationship with financial product providers and receive any monetary or other benefits, our usual disclosure principles will apply.

Our representatives may recommend investments in shares that they hold or may hold in the future. You will be advised where a conflict of interest may exist and how the conflict will be managed.

In relation to the personal financial advice and product advice provided to you, we are under an obligation to act in your best interests (i.e. the best interests duty). Within the subject matter of the advice provided to you, we must ensure that:

• the scope of the advice considers all the issues and meets your objectives, financial situation and needs (including your tolerance for financial risk)
• if the scope of the advice changes, the change is consistent with your objectives, financial situation and needs
• we consider whether or not to provide advice that recommends a specific product or whether you should dispose of a product or do nothing.

The advice that your financial adviser provides will always be provided to you in writing in the SOA, unless it is further ongoing advice in which case it will generally be in the form of an ROA, as outlined earlier.

You have the right not to tell us information about yourself, however, if you still require your financial adviser to provide you with financial product advice, then the SoA will contain a specific warning that draws your attention to the risks of not providing full information about yourself. This warning will state that if you do not provide your financial adviser with accurate and complete information relating to your personal circumstances, then the advice you receive may not meet your intended objectives because your financial adviser has not been able to determine whether the advice is appropriate.

Therefore, before acting on any advice you receive, you should consider the appropriateness of the advice and carefully read the warnings contained in the SOA before making any decisions as a result of the advice provided.

In all cases, when your financial adviser provides you with an SOA and a recommendation to acquire a financial product is included, an investment report or PDS for that financial product will be provided to you.

It is important that you read and understand this document before implementing any recommendation made in the SOA. Your financial adviser will readily explain any part of this document that you do not understand.

If you don’t wish to receive our advice, we may still act on your instructions to deal in financial products. However:

• you face the risk that the financial product you select may not be appropriate for you, and
• we may require you to sign a document that records your intention not to seek advice from us for the particular financial product(s).

In order to meet our obligations to act in your best interests (i.e. under the Best Interests Duty) we will request that you provide us with details of your personal objectives, current financial situation and needs, and any other relevant information so that we can offer you appropriate advice.

You have the right not to tell us information about yourself, however, if you do not provide us with accurate and complete information relating to your personal circumstances, the advice you receive may not meet your intended objectives and you should make your own determination as to whether the advice is appropriate before proceeding.

Australian Privacy Principles apply to the collection of personal or sensitive information. This means that information provided by you in the course of receiving financial planning services must only be used:

• to provide you with information, products or services that you might reasonably expect or request,
• to fully understand or anticipate your needs during our relationship,
• to manage rights and obligations under any laws applying to the services provided, or
• to conduct research, or planning and marketing, which includes direct marketing, although you do have the right to specifically instruct that your details aren’t used for these purposes.

The type of information which will usually be requested will include details about your financial, taxation, health, employment and estate planning matters. This may include details relating to your partner or family members.

As a financial service provider, we have an obligation under the Anti-Money Laundering and Counter-Terrorism Finance Act 2006 to verify your identity and the source of any funds. This means that we will ask you to present identification documents such as passports and driver’s licence and we will retain copies of this information.

You are entitled to request access to your file for the purpose of reviewing and correcting the information held. However, you cannot access information where it would have an unreasonable impact on the privacy of another person or if the information is relevant to legal obligations or legal proceedings.

In providing services to you, from time-to-time we will disclose information about you to our Authorised Representatives and other professionals, including insurance providers, superannuation trustees, product issuers, as well as our service providers.

If your financial adviser leaves our Integrated Pathways Financial Services licence and starts to provide financial services under another licensee, your information may be transferred to the new licensee. You will be advised of any such transfer before it takes place.

The Licensee holds professional indemnity insurance in respect of the financial services we provide. This professional indemnity insurance complies with the requirements of the Corporations Act. The professional indemnity insurance covers all of the financial services we are authorised to provide to you.

If you have a complaint about a financial service provided to you, you should follow the steps outlined below:

1. Contact your financial adviser to discuss your complaint.
2. If your complaint is not satisfactorily resolved within seven days of raising it, you may contact Integrated Pathways Financial Services on 03 9326 8900, or put your complaint in writing and send it to:

Integrated Pathways Financial Services Pty Ltd
1^st Floor, 582 Queensberry Street
North Melbourne VIC 3051

If, after speaking with Integrated Pathways Financial Services and your financial adviser, your complaint is not resolved to your satisfaction, you can lodge your complaint with the Australian Financial Complaints Authority (AFCA). AFCA provides fair and independent financial services complaint resolution that is free to consumers.

Australian Financial Complaints Authority
GPO Box 3
Melbourne VIC 3001

Telephone:    1800 931 678 (free call)
Email:              [email protected]
Website:         www.afca.org.au

Integrated Pathways Financial Services is a member of this Complaints Resolution Service.

The Australian Securities and Investments Commission (ASIC) also has a toll free information line on 1300 300 630 which you may wish to use to make a complaint and obtain information about your rights.

Empower Wealth Financial Services Pty Ltd | FSG Version 2.0, dated 26 March 2024