Status: DRAFT — prepared from the current codebase and the confirmations users already accept at onboarding. It must be reviewed by legal counsel and the AFSL holder before publication. Items in [square brackets] must be confirmed.
Effective date: [DD Month YYYY]
Last updated: [DD Month YYYY]
These Terms of Use (“Terms“) govern your access to and use of the ImpactX platform (the “Platform“), which is operated by Digital Finance CRC Limited (ACN 652 335 405) (“ImpactX“, “we“, “us“, “our“) as Corporate Authorised Representative No. [x] of Vellum Australia Pty Ltd (ACN 605 190 369, AFSL No. 482051) (the “AFSL Holder“).
When you complete account set-up and tick the confirmation boxes, or when you use the Platform, you agree to these Terms and to our Privacy Policy. If you do not agree, do not use the Platform.
1. Definitions
| Term | Meaning |
|---|---|
| Adviser | A user who has chosen the “Financial Adviser” persona and uses the Platform to evaluate opportunities for wholesale clients. |
| Attested | A label on a KPI showing that an independent party has checked it, as described in the Impact Room. |
| Break Even | The part of the ImpactX assessment that checks whether an issuer’s positive impact is cancelled out by harm elsewhere. |
| Content | All information, data, text, metrics, documents, images and materials on the Platform. |
| Data Room | The part of a Listing that holds documents supplied by the Issuer. |
| Five Capitals | ImpactX’s framework of Financial, Human, Intellectual, Social and Spiritual capital, used to describe how an opportunity relates to a family’s wider goals. |
| Impact Certification | ImpactX’s assessment of an opportunity’s impact claims against its published framework. It covers impact claims only. |
| Impact Room | The disclosure section of a Listing. It sets out the Theory of Change, KPIs, Positive Pursuits and the status of independent checks. |
| Issuer | The company, fund or other entity offering the investment opportunity described in a Listing. |
| Listing | An investment opportunity shown on the Platform. |
| Persona | Your chosen way of using the Platform (Investor/Family Office or Financial Adviser). It changes what content you see, not what you are permitted to access. |
| Positive Pursuits | ImpactX’s set of 24 impact objectives, grouped into themes, which Listings are screened against. |
| Theory of Change | An Issuer’s explanation of how its activities lead to the impact it claims. |
| Wholesale Client | A wholesale client within the meaning of sections 761G and 761GA of the Corporations Act. |
| You / User | The person who accepted an invitation and set up an account, and, where relevant, the entity that person represents. |
2. Legislative references
These Terms refer to, and are to be read with, the following laws:
- Corporations Act 2001 (Cth) (“Corporations Act“), in particular Chapter 7 (financial services), s 761G and s 761GA (wholesale and retail clients) and s 766B (financial product advice).
- Australian Securities and Investments Commission Act 2001 (Cth).
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the AML/CTF Rules.
- Privacy Act 1988 (Cth) and the Australian Privacy Principles.
- Competition and Consumer Act 2010 (Cth), Schedule 2 (Australian Consumer Law).
- ASIC Regulatory Guides [RG 36, RG 175, RG 244 — legal to confirm the list].
3. Pilot status
This is a pilot version of the ImpactX platform. No financial services are provided in this test environment.
While the Platform is labelled a pilot:
- Content, including Listings and portfolio pages, may be incomplete, illustrative or demonstration data.
- Features may change, be withdrawn or be unavailable without notice.