Gembroker Transparency Statement

This is NOT a disclosure for financial advice but is intended to provide you with transparency about how we operate.

Disclosure Statement - Financial Service Provider


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)

To comply with the Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) legislation in New Zealand, Maddition is committed to maintaining the highest standards of transparency and integrity in all our operations. As part of our regulatory obligations, we are required to collect and verify certain information about our customers to mitigate the risks associated with money laundering and terrorist financing. This may include personal identification details, proof of address, and source of funds documentation. By using our Platform, customers acknowledge and consent to the collection and processing of such information for AML/CFT compliance purposes. We assure our customers that all data collected will be handled securely and in accordance with applicable privacy laws. Should you have any questions or require further clarification regarding our AML/CFT procedures, please do not hesitate to contact our Compliance Team. 

Fees and Expenses

Gembroker charges fees for specific services, clearly outlined on our Pricing Page. From stock and ETF trade fees to a subscription offering (Gembot Private), all applicable fees are transparently communicated to avoid any surprises.

In Plain Language: We are upfront about our fees, ensuring transparency in all transactions.

Our current fee schedule is as follows:

  1. Stock and ETF Trade Fees - 0.4% maximum with fees as low as 0.2% of order value
  2. Interest on Cash Balances - A 50/50 revenue share with Alpaca of all cash held in USD
  3. Payment for Order Flow - A 50/50 revenue share with Alpaca
  4. Spread on Crypto Transactions 0.75% - a 50/50 revenue share with Alpaca
  5. Foreign Exchange for $NZD Deposits and Withdrawals - 1% - a 50/50 revenue share with
  6. Subscription offering for Gembot Private which enables users access cheaper transactions and other premium services and features

Visit Pricing Page

Conflicts of Interest, Commissions or Other Incentives

Gembroker's affiliations, including being wholly owned by Maddition Limited and utilising Gembot Limited's technology, are transparently disclosed in the Gembroker New Zealand Limited Terms and Conditions.  Alpaca Securities LLC, our broker-dealer partner, provides the trading infrastructure.

In Plain Language: We maintain transparency in all aspects, and if any conflicts arise, we will communicate and manage the conflict promptly.

Complaint Handling and Dispute Resolution

If for any reason you are not satisfied with our financial services, you should notify us directly in the first instant via email [email protected].

If the matter is not resolved to your satisfaction, or you do not wish to raise it with us directly, you can make a complaint through the following channels:

  1. By mail at [email protected]
  2. In writing to the Complaints Manager, Gembroker NZ Limited, Level 8, 23 Customs Street East, Auckland 1010
  3. In person at our office
  4. Or by telephone 0212236249 to our Complaints Manager

All complaints received will be considered in accordance with our internal complaints handling process.

We will acknowledge receipt of the complaint within 2 working days of receipt.

We will aim to respond to your complaint at the earliest possible time, but no later than 14 working days from receipt of such a complaint.

To facilitate the effective investigation, we may reach out directly to you to seek additional information.

We will contact you via email or in writing to let you know the outcome of our investigation into your complaint.

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, our external independent dispute resolution provider.

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

You can contact  Financial Dispute Resolution Service by:

Emailing [email protected]

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.

In Plain Language, we have a very simple complaint escalation and resolution process with independent parties involved.  Should you not be happy with our processes, you are most welcome to escalate this with the Financial Dispute Resolution Service at any time.