Legal, Privacy & Compliance

Compliance

Last updated: 13 April 2026

Gallantree operates in a regulated environment and is committed to meeting the obligations imposed by Australian financial services law and related regimes. This page summarises the key compliance frameworks we maintain.

Regulatory framework

Gallantree's operations are governed by, among others:

• the Corporations Act 2001 (Cth) and Corporations Regulations 2001;
• the Australian Securities and Investments Commission Act 2001 (Cth);
• the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
• the Privacy Act 1988 (Cth) and Australian Privacy Principles;
• the Taxation Administration Act 1953 (Cth), including FATCA and CRS obligations; and
• ASIC regulatory guides applicable to AFS licensees and responsible entities.

Anti-money laundering and counter-terrorism financing

Gallantree has implemented an AML/CTF Program in accordance with the AML/CTF Act and the AML/CTF Rules. The Program includes customer identification and verification (KYC), ongoing customer due diligence, sanctions screening, transaction monitoring, suspicious matter reporting, staff training, and independent review. Before accepting a new investor, we are required to verify identity and, where relevant, beneficial ownership.

Sanctions

Gallantree complies with Australian sanctions laws administered by the Department of Foreign Affairs and Trade (DFAT) and, where applicable, sanctions imposed by other jurisdictions. We do not provide services to persons or entities subject to applicable sanctions.

Conflicts of interest

We maintain a Conflicts of Interest Policy that requires all directors, officers and employees to identify, disclose and manage actual or potential conflicts. Material conflicts relating to a particular product are disclosed in the offer document for that product.

Related party transactions

Any transaction between a Gallantree fund and a related party is undertaken on arm's length terms, is subject to independent review, and is disclosed in the fund's reporting in accordance with applicable law and the fund's constituent documents.

Whistleblower protections

Gallantree maintains a Whistleblower Policy consistent with Part 9.4AAA of the Corporations Act. Eligible whistleblowers can make protected disclosures about misconduct or an improper state of affairs, and are afforded the protections provided by law, including confidentiality of identity and protection from victimisation.

Record keeping and reporting

Gallantree maintains records of its financial services, client communications, transactions and decisions as required by law. As an ASIC-regulated AFSL licensee, Gallantree is not subject to APRA regulation. Regulatory reporting obligations (including to ASIC, AUSTRAC, and the ATO) are monitored and met by our Compliance team.

Governance and independent review

Our governance arrangements include a Board with independent oversight, dedicated Risk and Compliance functions, and periodic independent review of our AFSL obligations, AML/CTF Program and operational controls. Funds are supported by independent trustees, custodians, administrators and auditors.

Modern slavery

Gallantree is committed to identifying and mitigating the risk of modern slavery in its operations and supply chain, consistent with the principles of the Modern Slavery Act 2018 (Cth).