Consumer Protection

Consumer Protection and Information and Data Security Policy and Procedures Statement for Maddition Limited, Gembot Limited and Gembroker NZ Limited.


At Maddition and our related entities (Gembot Limited and Gembroker New Zealand Limited), we are committed to protecting our clients' interests and ensuring that our investment services and platform are safe, reliable, and secure. We strive to maintain the highest standards of consumer information and data protection and applicable regulatory compliance. This policy outlines our commitment to consumer, information and data  protection and the procedures we have in place to achieve this.

Please note that Maddition is a holding company and does not directly offer any services to consumers, however is the ultimate beneficiary of our subsidiaries which are Gembot Limited and Gembroker New Zealand Limited.


We are committed to providing clear, accurate, and timely information to our clients about our services. We will disclose information about the risks associated with investing, the fees and charges that apply, and any conflicts of interest. We will ensure that the information is presented in plain language and is easily accessible to our clients.

Additionally, we will provide ongoing disclosure to our clients, including regular statements and reports on the performance of their investments. We will provide clear and understandable information about the fees and charges that apply and will disclose any material changes that may affect the client's investment. Clients will be informed of their rights to access their information and make changes to their investments as necessary. 


We have implemented comprehensive policies and procedures to staunchly guard against the misuse of our services for money laundering or terrorism financing. Rigorous customer due diligence is a cornerstone of our approach, encompassing meticulous identity verification and a thorough assessment of each client's risk profile. Our commitment extends to continuous transaction monitoring, enabling us to promptly identify and report any suspicious activities to the pertinent authorities. This unwavering dedication to robust protocols ensures the integrity and security of our services.

Anti-Money Laundering (AML) and Countering Financing of Terrorism (CFT)

We have policies and procedures in place to prevent our services from being used for money laundering or terrorism financing. We will conduct customer due diligence, including verifying the identity of clients and assessing their risk profile. We will monitor transactions and report suspicious activity to the relevant authorities.

Dispute Resolution

We have a process for resolving disputes with clients, including internal dispute resolution procedures and access to an external dispute resolution scheme. We will provide clear information to clients about their rights and options for resolving disputes and will respond to complaints in a timely and effective manner. We will cooperate with our external dispute resolution scheme to ensure that disputes are resolved fairly.

If we cannot resolve your complaint, or if we fail to provide you with a reasonable response within 40 working days of your lodging the said complaint, you can contact Financial Dispute Resolution Service, a Financial Ombudsman Service and our external independent dispute resolution provider.

Financial Dispute Resolution Service provides a free, independent dispute resolution service that may help investigate or resolve any l client’s complaint where we have not been able to resolve the complaint to your satisfaction.

You can contact  Financial Dispute Resolution Service by:


Calling (locally) 0508 337 337

Calling (international) +64 4 381 5047

Completing a complaint form on their website here:

You can also write to them at: FDRS, Free Post 231075, P O Box 2272, Wellington, 6140, New Zealand.

All complaints, their resolutions, and communication records will be documented and maintained in accordance with regulatory requirements.

Client Money Handling

We will hold client money in a separate account on trust to protect it to comply with all relevant obligations including the Financial Market Conduct Act broker obligations which are there to ensure client funds remain segregated and secure from day to day operations or an insolvency event. We will maintain appropriate systems and controls to ensure that client money is properly accounted for and independently audited. To ensure we have good conduct with clients we will provide regular statements and transparently communicate where any fees or conflicts may apply.

Information and Data Security 

We will implement robust information security measures to protect the confidentiality, integrity, and availability of customer data. This includes:

  • Data encryption: Sensitive data such as customer information and financial transactions will be encrypted both in transit and at rest.
  • Access controls: Access to customer data will be restricted to authorized personnel only. We will implement strong authentication mechanisms and role-based access controls.
  • Network security: We will have a secure network architecture that includes firewalls, intrusion detection and prevention systems, and regular vulnerability assessments and penetration testing.
  • Incident response: We will have an incident response plan in place to quickly detect, respond to, and recover from security incidents. This will include procedures for notifying clients and regulatory authorities in the event of a breach.
  • Physical security: We will aim to secure our physical infrastructure with access controls, surveillance, and environmental controls to protect against theft, damage, or unauthorized access.
  • Employee training: We will provide regular training to our employees on information security best practices and the importance of safeguarding customer data. We will conduct background checks on all employees who have access to customer data.
  • Vendor management: We will ensure that our vendors and third-party service providers comply with our information security policies and procedures. We will conduct due diligence on all vendors and regularly monitor their security controls.

We will regularly review and update our consumer protection and information security policies and procedures to ensure that they remain effective and in line with best practices. We will provide regular training to our employees on these policies and procedures and ensure that all stakeholders are aware of our commitment to consumer protection and information security.

All internal stakeholders are required to sign off on this Consumer Protection and Information and Data Security Policy Policy to acknowledge their commitment to maintaining the highest standards of consumer protection and information security.

Fair Trading Commitment

As our valued customer, it's essential to understand our commitment to fair trading principles under New Zealand's Fair Trading Laws. We prioritise transparency and integrity, ensuring that the information provided about our  services is accurate and honest. Deceptive practices, false representations, and misleading conduct are strictly prohibited. Our staff are continually made aware of our commitments through training and awareness programmes to ensure effective monitoring is in place.   We focus on clear and accessible terms and conditions to assist in our clients understanding of how our service operates. These obligations aim to foster a fair and ethical marketplace, promoting honest dealings and empowering you to make informed decisions. Please be aware that any non-compliance may have legal consequences, emphasising the importance of embracing these fair trading principles as part of our customer terms and conditions. 

We prioritise transparent and responsible communication with our customers. All marketing and customer communications are managed to ensure clarity, accuracy, and compliance with relevant regulations, including New Zealand Fair Trading Laws. Our commitment is to provide you with information that is, to the best of our knowledge  truthful, unbiased, and aligned with the values of integrity and fairness. Our team adheres to a robust set of guidelines to maintain the highest standards in marketing practices, delivering content that supports you to make well-informed decisions. If you have any specific concerns or inquiries about our marketing and customer communications, our dedicated support team is readily available to address them promptly and comprehensively.

Vulnerable Customers

At Maddition, we recognise the diversity of our customer base, understanding that certain individuals may be more vulnerable than others due to personal circumstances. It is our steadfast commitment to treating vulnerable customers fairly and ensuring that they receive the same level of service as all our valued clients. Further information with regards to how we address our vulnerable customers can be found here.