Gembroker Vulnerable Customer Statement 

Discover information and resources on our Vulnerable Customers page, dedicated to providing support and assistance for those in need within our modern wealth platform and AI assistant.


At Gembroker, 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.

Definition of Vulnerable Customers

A vulnerable customer is identified as an individual who, owing to personal circumstances—whether permanent or temporary—may face a disadvantage when engaging with financial services providers. The categorization of vulnerability encompasses four primary areas:

  1. Health: Conditions affecting day-to-day tasks, including mental or physical disabilities, illness, or injury.
  2. Life Events: Instances such as bereavement or job loss.
  3. Resilience: Low ability to withstand financial or emotional shocks, exemplified by low or unstable income, overindebtedness, or unemployment.
  4. Capabilities: Limited knowledge of financial matters or confidence in managing money (financial capability), as well as low capability in other relevant areas such as literacy or digital skills.

Our Commitment

To ensure the well-being of vulnerable customers, we have established the following principles:

  1. Staff Training: Our team undergoes continuous training to recognise signs of vulnerability and respond with empathy and understanding.
  2. Clear Communication: We prioritise clear and accessible communication, avoiding technical jargon and offering multiple communication methods to suit individual preferences.
  3. Risk Assessment: Regular risk assessments are conducted to identify and monitor potential vulnerabilities among our customer base.
  4. Supportive Measures: When identified, vulnerable customers may be provided with additional support, including customised assistance tailored to their needs.

How to Notify Us

If you believe you may be a vulnerable customer or are aware of any vulnerability, please inform us promptly. You can contact our dedicated support team at

External Support

Depending on your circumstances, external support is available from organisations such as:

  1. Citizens Advice Bureau - Free Budgeting Advice
  2. Mental Health Foundation
  3. Work and Income 
  4. Ministry of Health - Gambling harm
  5. Blind Citizens NZ - Visually impaired

Privacy and Confidentiality

We respect the privacy and confidentiality of our customers. Any information regarding vulnerability will be handled with the utmost sensitivity and will only be shared with explicit customer consent or if legally required.

At Gembroker, we are committed to fostering an environment that prioritises the well-being and equitable treatment of all our customers, recognising and addressing vulnerabilities with diligence and respect.


We are committed to providing clear, accurate, and timely information to our clients about our products and 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.

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.