Terms & Conditions

Reach AlternativesIM Ltd t/a Reach Alts (ACN 657 758 006)

Originally published: 1 January 2022

Version: 3.0

Last updated: 1 November 2025.

These terms and conditions (Terms) your use of:

(a) our public website at https://www.reachalts.com.au/ and any related landing pages, content or marketing materials; and

(b) our secure online investment platform at https://www.invest.reachalts.com.au/, once you have registered for an account.

In these Terms, Reach Alts, we, us and our means Reach Alternatives IM Pty Ltd (ACN 657 758 006)trading as Reach Alts.

1. About the Website and Platform

1.1. The public website at https://www.reachalts.com.au/ and any related landing pages, content or marketing materials (together, the Website) provide general information about Reach Alts, our business and our products and services, including private markets investment opportunities and related services (together, the Services).

1.2. The investor portal at https://www.invest.reachalts.com.au/ (and any replacement or additional URLs we notify to you) provides a logged-in environment (the Platform) where eligible users (Members) can, among other things:

(a) access detailed information about funds and investment opportunities, including information memoranda and other legal documents;

(b) submit information about their investment entity or structure;

(d) submit or manage investment instructions and related activities,

in each case subject to these Terms and any additional applicable terms and conditions referred to aspart of the process.

1.3. The Website contains general information only. Nothing on the Website is, or is to be construed as an offer, invitation, solicitation or recommendation to invest in, subscribe for or acquire any financial product and you must not treat it as such. Any summary of an investment, fund or opportunity on the Website is descriptive only and does not contain all of the information that may be material to an investment decision.

1.4. To view any information memoranda, product disclosures or other offer documents, application forms, trust deeds or other legal documents in relation to a fund or investment vehicle (Fund Documents), you must:

(a) create an Account on the Platform;

(b) accept these Terms as a Member;

(d) provide identity information for verification; and

(e) confirm that you satisfy the eligibility criteria set out in clause 4 (including that you are at least 18 years old and are a wholesale client),

and you will then be able to access the relevant Fund Documents via the Platform. However, we may refuse access for any reason.

1.5. Our funds and investment opportunities are offered only to persons who are“wholesale clients” (or otherwise not “retail clients”) within the meaning of sections 761G and 761GA of the Corporations Act 2001 (Cth) and any other applicable exemption. You must not attempt to open an Account or apply for an investment if you are a retail client or otherwise ineligible.

1.6. The information on the Website and Platform is of a general nature only and has been prepared without taking into account your objectives, financial situation or needs. You should seek independent financial, legal, tax and other professional advice and read the relevant Fund Documents in full before making any investment decision.

1.7. Any investment summarised on the Website or Platform is subject to investment risk, including possible delays in repayment and loss of income or capital. All investments carry risk, and there is typically a relationship between risk and return. Past performance is not a reliable indicator of future performance.

1.8. We use reasonable care in preparing the information on the Website and Platform but do not warrant that it is complete, current or free from error. Content is subject to change without notice. We do not guarantee that the Website orPlatform will be available, uninterrupted or error-free.

2. Other documents that apply

2.1. Depending on how you interact with us, other documents may apply in addition to these Terms, including:

(a) our Non-Disclosure Agreement (NDA) governing confidentiality of information you access through the Platform;

(b) our Privacy Policy;

(d) our Data Breach Notification Policy;

(e) the Fund Documents applying to any particular investment; and

(f) the Airwallex Terms applying to any embedded finance services you use (see clause 5).

2.2. If you invest in a fund or investment vehicle, your rights and obligations in relation to that investment are governed primarily by the applicable Fund Documents. To the extent of any inconsistency between these Terms and the Fund Documents in relation to your investment, the Fund Documents prevail.

2.3. If you use any embedded finance services provided by Airwallex or its regional banking or financial partners (Embedded Finance Services), your rights and obligations in relation to those services are governed primarily by the Airwallex Terms between you and Airwallex. To the extent of any inconsistency between these Terms and the Airwallex Terms in relation to the Embedded FinanceServices, the Airwallex Terms prevail.

2.4. By using the Website or Platform, you acknowledge that our NDA (where applicable), Privacy Policy, Complaints Resolution Policy and Data Breach Notification Policy (and any other policy published on the Website or Platform from time to time) form part of the framework governing our relationship with you, and you agree to comply with them as applicable.

3. Acceptance of these Terms

3.1. By accessing or using the Website (including by browsing, downloading materials, viewing content or signing up to a mailing list), you agree to be bound by these Terms as a Website user and by our Privacy Policy.

3.2. By registering for, accessing or using the Platform, you:

(a) agree that these Terms apply to you as a Member in addition to their application to Website users;

(b) agree to comply with any additional terms presented to you at the time of registration, including our NDA and privacy notices;

(d) acknowledge that any investment you make via the Platform is governed by the relevant FundDocuments.

3.3. You may also accept these Terms by clicking “accept”, “I agree” or similar in the user interface, including when registering or logging into the Platform.

3.4. We may update these Terms from time to time by posting the updated version on theWebsite or Platform. If you are a Member, we may also notify you via the Platform or email. Your continued use of the Website or Platform after the updated Terms are posted constitutes your acceptance of the updated Terms.

4. Eligibility and Registration

4.1. To register for an account on the Platform (Account) and become a Member, you must:

(a) be an individual who is at least 18 years of age, or a duly authorised representative of a legal entity;

(b) be capable of entering into a legally binding contract with us;

(d) satisfy any other eligibility criteria or onboarding requirements from time to time.

4.2. During registration, or at any time afterwards as part of your use of the Platform, we may require you to provide information including (without limitation):

(a) full legal name;

(b) date of birth;

(d) email address and contact details;

(e) details of your investment entity or structure;

(f) information required to assess whether you are a wholesale client; and

(g) any other information we reasonably require.

You must ensure that all information you provide to us is true, accurate, current and complete, and you must notify us if any information changes.

4.3. As part of registration or first access to the Platform, you will be required to accept our NDA or other confidentiality terms. You must not access, use or disclose any information, documents or materials made available to you through the Platform (including any Information Memoranda, presentation, data room materials or Fund Documents) other than in accordance with those confidentiality obligations and these Terms.

4.4. You are responsible for maintaining the confidentiality and security of your login credentials (username, password, multi-factor authentication tokens and similar) and for all activities that occur under your Account. You must notify us immediately if you become aware of any unauthorised access to or use of yourAccount.

4.5. We may, in our discretion and subject to applicable law, refuse to register you asa Member, or suspend or terminate your Account, including where we cannot verify your identity, you do not meet eligibility criteria, we suspect fraud or misuse, or you breach these Terms.

5. Platform Services, Embedded Finance Services and Fees

5.1. In addition to making the Website available, we may provide the following services to Members via the Platform (Platform Services):

(a) providing access to information, data rooms and documentation in relation to investment funds and opportunities;

(b) facilitating the collection, review and management of information about you and your investment entity (including onboarding, KYC/AML and related compliance);

(c) providing tools and processes to support the establishment, operation and administration of your investment structure;

(d) integrating with Embedded Finance Services to allow you to move or hold money in connection with your investments; and

(e) processing, recording and displaying information about your investments, holdings and related activity,

among other activities, in each case as described on the Platform from time to time.

Embedded Finance Services

5.2. The Platform may make available or integrate with Embedded Finance Services provided by Airwallex Pty Ltd (ABN 37 609 653 312, AFSL 487221) or another Airwallex group member and/or their regional banking or financial partners. These may include, for example:

(a) opening and operating a wallet (a Connected Account) for you or your investment entity;

(b) receiving, holding, converting and paying funds; and

5.3. These services are provided by Airwallex and its financial partners, not by us. We do not issue, hold or deal in any stored value or other financial product provided by Airwallex.

5.4. To use Embedded Finance Services, you will be required to agree to the Airwallex Terms directly with Airwallex and/or its relevant partners. By using Embedded Finance Services via the Platform, you acknowledge and agree that:

(d) your rights and obligations in relation to those services are governed by the Airwallex Terms;

(e) any loss, claim or dispute arising from or relating to the Embedded Finance Services is a matter between you and Airwallex (subject to the Airwallex Terms and applicable law); and

(f) nothing in these Terms limits any rights you may have against Airwallex under the Airwallex Terms or at law.

Fees

5.5. We may charge fees for Platform Services and other services we provide to you or your investment entity (Platform Fees). The nature and amount of Platform Fees, and how they are calculated and paid, will be described in the relevant Fund Documents, Airwallex Terms, fee schedules, application forms or other written agreement or disclosure we provide to you.

5.6. Where you have opened an Airwallex Connected Account and have agreed (including via the Platform or an application form) that Platform Fees may be collected from that wallet or account, you:

(a) authorise us to instruct Airwallex to debit Platform Fees from that wallet or account and to pay those amounts to us or our nominees; and

(b) acknowledge that Airwallex will process those debits as your payment service provider under the Airwallex Terms.

Standing authorisations

5.7. In addition to clause 5.5, you irrevocably authorise us (and any trustee, responsible entity, general partner or manager of a fund or investment vehicle you invest in via the Platform) to instruct Airwallex to debit from your Airwallex Connected Account, and to pay to us or the relevant fund, vehicle or service provider (as applicable), any amounts that are payable by you or your investment entity in connection with your use of the Platform or any investment made via the Platform. This includes, without limitation:

(a) capital contributions, capital calls and other amounts you have committed to contribute under the relevant Fund Documents; and

(b) any fees, costs, charges, expenses, interest, indemnities, taxes or other amounts that you owe to us or to any relevant fund, vehicle or service provider under the Fund Documents, these Terms or any other applicable agreement.

5.8. You must ensure that there are sufficient cleared funds in your Airwallex ConnectedAccount to enable these debits to be made.

5.9. Where an amount that is due and payable under clauses 5.5 - 5.7 is denominated in a different currency to the currency standing to the credit of your Airwallex Connected Account, you authorise us to instruct Airwallex to:

(a) convert all or part of the balance of your Airwallex Connected Account into the required currency using the foreign exchange services provided under the Airwallex Terms; and

(b) debit the converted amount (and any associated fees and charges) from your Airwallex Connected Account and pay it to us or the relevant fund, vehicle or service provider (as applicable).

5.10. You acknowledge that any foreign exchange conversion will be carried out in accordance with the Airwallex Terms, that exchange rates may change and that you bear the risk of any currency fluctuations, fees and charges associated with such conversions.

5.11. For the avoidance of doubt, Reach Alts collects a fee in relation to any foreign exchange conversion carried out in the Airwallex Connected Account, including in relation to clauses 5.9 - 5.10. Those fees are disclosed in the Airwallex Terms and in the fee schedule.

Withdrawal of funds

5.12. If at any time:

(a) there are amounts that are due and payable (or that we reasonably believe will shortly become due and payable), or any amounts committed but uncalled in relation to an investment you have in one of our funds or investments on Platform, by you or your investment entity under the Fund Documents, these Terms or any other applicable agreement; or

(b) there are instructions in progress to debit your Airwallex Connected Account under clause 5.5 - 5.8,

we may refuse to process any instructions for withdrawal from your Airwallex Connected Account, and:

(a) place a hold or restriction on withdrawals or transfers from your Airwallex ConnectedAccount; and/or

(b) ring-fence an amount up to the total of the relevant actual or anticipated obligations,

until those obligations are satisfied or arrangements acceptable to us have been made for their satisfaction. You acknowledge that it may mean you cannot withdraw or transfer some or all of the funds in your Airwallex Connected Account while those obligations remain outstanding.

Sweeping

5.13. You acknowledge and agree that, to facilitate capital calls, deposits, withdrawals, payment of Platform Fees and other amounts, foreign exchange conversions and the funding or redemption of investments, we may instruct:

(a) Airwallex, its banking or financial partners and/or our other payment service providers to transfer funds from your Airwallex Connected Account to one or more sweep, settlement, trust or omnibus accounts (which may be in the name of us or ourTrustee, or Airwallex) and then to the ultimate beneficiary account; and

(b) Airwallex and any relevant service provider to carry out such transfers, including temporary sweeps into and out of those accounts, in connection with transactions initiated or authorised by you, or as otherwise permitted under these Terms, the Fund Documents and the Airwallex Terms.

5.14. Any such sweeps or temporary transfers do not change your beneficial entitlement to the underlying funds (except to the extent that those funds are validly applied to amounts you owe under these Terms, the Fund Documents, the Airwallex Terms or any other applicable agreement).

5.15. We and/or Airwallex (or its banking or financial partners) may receive and retain any interest, rebate or other benefit arising from the operation of such sweep or settlement arrangements, to the extent permitted by Applicable Laws and the relevant Fund Documents and fee schedules.

Closure of an account

5.16. You may request the closure of your Airwallex Connected Account by notifying us in writing, in accordance with the Airwallex Terms. If you do so, we may require you to satisfy any outstanding fund commitments or other obligations (including Platform Fees and any other amounts payable to us or a relevant fund or service provider) via another arrangement or using another permitted payment method.

5.17. We may suspend, restrict or otherwise limit some or all of the Platform Services and Embedded Finance Services at any time in accordance with these Terms, theFund Documents and the Airwallex Terms.

6. Identity Verification and DVS

6.1. We may verify your identity (and that of your investment entity and beneficial owners) as part of our registration, login, data room access and onboarding processes, and on an ongoing basis, including to:

(d) comply with anti-money laundering, counter-terrorism financing and other regulatory requirements; and

(e) manage fraud and financial crime risks.

6.2. For identity verification, we may engage GBG ANZ Pty Ltd (ABN 67 111 307 361) (GBG) as our information match agent, and GBG may use the Australian Government’s DocumentVerification Service (DVS) and other sources. Where we use the DVS, the identification information you provide to us (for example, details from your driver licence, passport, birth certificate or Medicare card) may be disclosed to GBG and to the relevant government agency or record holder so that they can confirm whether the information you have provided matches their records.

6.3. The DVS and the relevant agency or record holder use the information you provide only for the purpose of confirming whether the details match their records.They do not provide us with a copy of your underlying government record.Instead, we receive a result indicating, for example, that the details matched, did not match or that an error occurred.

6.4. By submitting your identification information to us (including via the Website, the Platform or any third-party interface we use), you:

(a) confirm that you are authorised to provide that information; and

(b) expressly consent to us and GBG collecting, using and disclosing your information as described in this clause 6, in our Privacy Policy and in any additional notices provided to you, for the purposes of verifying your identity, managing our relationship with you and complying with our legal and regulatory obligations.

6.5. If you do not wish for your identity to be verified using the DVS, you must contact us before completing registration or any application. We will discuss alternative ways to verify your identity. These alternatives may be less convenient, may take longer and may limit or prevent your access to certain parts of the Platform or our ability to accept you (or your investment entity) as an investor.

6.6. Further information about the DVS and how it protects your privacy is available on theAustralian Government’s ID Match website (currently www.idmatch.gov.au).

7. Your Obligations

7.1. You must use the Website and Platform only for lawful purposes and in accordance with these Terms and any applicable policies and laws.

7.2. You must ensure that all information you provide to us (including as part of registration, onboarding, investment applications and ongoing reporting) is true, accurate, current and complete, and promptly update it if it changes.

7.3. You must not:

(a) allow another person to use your Account;

(b) share your login credentials with anyone else; or

7.4. You may not download, copy, reproduce or distribute information, documents or materials from the Website or Platform (including any IMs, presentations, data room materials or other confidential information) except:

(a) where expressly permitted by us in writing; or

(b) to the extent strictly necessary for you and your professional advisers to assessor manage a potential or existing investment, and subject always to our NDA and confidentiality obligations.

7.5. You must not (and must not attempt to):

(a) interfere with or disrupt the operation of the Website or Platform, or the servers or networks that host them;

(b) introduce any viruses, malware or other harmful code;

(c) use automated tools (including bots, crawlers or scrapers) to access or interact with the Website or Platform, except as expressly permitted; or

(d) use the Website or Platform in a way that infringes any third-party rights or breaches any law.

8. User Content and Communications

8.1. If you upload, submit or otherwise provide any content or materials to us via theWebsite or Platform (User Content), you:

(a) grant us a non-exclusive, worldwide, royalty-free licence (including the right to sublicense) to use, reproduce, modify and communicate the User Content for the purposes of operating the Website and Platform, assessing and managing investments, complying with legal obligations and otherwise providing theServices; and

(b) warrant that you have all necessary rights to grant this licence and that our use of the User Content in accordance with these Terms will not infringe any third-party rights.

8.2. We may (but are not obliged to) monitor, review, remove or disable access to any User Content that we consider, in our discretion, to be unlawful, inappropriate, misleading or in breach of these Terms.

8.3. You consent to us contacting you via email, the Platform, SMS, telephone or other electronic means using the contact details you provide, including for:

(a) providing information about your Account, investments and the Platform;

(b) sending notices and disclosures required by law; and

You may opt out of marketing communications at any time by using the unsubscribe facility in our emails or contacting us.

Intellectual Property

8.4. All intellectual property rights in the Website, the Platform and their contents (including text, graphics, logos, trade marks, icons, images, audio and videoclips, software and the underlying source code), other than User Content and third-party content, are owned or licensed by us or our licensors.

8.5. We grant you a limited, non-exclusive, non-transferable, revocable licence to access and use the Website and Platform, and to view and use their content, solely for your personal or internal business purposes in connection with assessing or managing investments via the Platform and in accordance with theseTerms, the NDA and the Fund Documents.

8.6. Except as expressly permitted in these Terms or as required by law, you must not reproduce, distribute, adapt, modify, create derivative works from, publish or otherwise use any part of the Website, Platform or their contents without our prior written consent (and, where applicable, the consent of our licensors).

9. Privacy and Data

9.1. We handle personal information in accordance with our Privacy Policy, which is available on the Website. By using the Website or Platform, you consent to our collection, use and disclosure of personal information as described in theseTerms and our Privacy Policy.

9.2. If you use Embedded Finance Services, we will share certain personal information and other data about you and your investment entity with Airwallex and its related bodies corporate, and they will share certain information with us. This may include:

(a) your name, contact details and date of birth;

(b) know-your-customer and anti-money laundering information;

(d) wallet or account identifiers; and

(e) transaction and instruction information,

as reasonably required for us and Airwallex to provide our respective services, manage our relationships with you and comply with applicable laws.

9.3. We may also use and disclose personal information collected in connection with theWebsite, Platform, DVS, GBG and Airwallex in the ways described in our Privacy Policy, including for related secondary purposes that are permitted under privacy laws (for example, to manage fraud and financial crime risks, manage disputes and respond to regulators).

10. Disclaimers – No Offer, No Advice, Risk

10.1. Content on the Website and Platform does not constitute an offer, invitation, solicitation, recommendation or advice to invest in any product or to use any service. Any decision to invest must be made solely on the basis of the relevant Fund Documents and your own inquiries and advice.

10.2. Unless expressly stated otherwise, any financial product advice provided via the Website or Platform is general advice only. It does not take into account your objectives, financial situation or needs. You should consider whether it is appropriate for you and seek independent advice before acting on it.

10.3. The Website and Platform may contain information, tools, content and links provided by third parties (including fund managers, administrators, Airwallex and other service providers). We do not endorse, and are not responsible for, the accuracy, completeness or suitability of any third-party content or services, except to the extent required by law.

10.4. We do not guarantee the performance of any investment, or the repayment of capital or any particular rate of return. Any forward-looking statements are predictive in nature and based on assumptions and subject to risks and uncertainties outside our control. All investments carry risk, and you may lose some or all of your capital.

11. Limitation of Liability

11.1. Nothing in these Terms excludes, restricts or modifies any consumer guarantees, rights or remedies conferred on you by the Australian Consumer Law or any other applicable law that cannot be excluded, restricted or modified by agreement.

11.2. To the maximum extent permitted by law, we exclude all liability for:

(a) any loss or damage (including consequential or indirect loss, loss of profit, loss of opportunity or business interruption) arising out of or in connection with your use of, or inability to use, the Website or Platform;

(b) any errors or omissions in any content on the Website or Platform; and

(c) any acts or omissions of Airwallex or other third-party service providers, including in relation to Embedded Finance Services.

11.3. To the extent that our liability cannot be excluded but can be limited, our total liability to you arising out of or in connection with the Website, Platform,Services or these Terms is limited, at our option, to:

(a) in the case of services, the re-supply of the services or payment of the cost of having the services supplied again; or

(b) in any other case, the amount of AUD $1,000.

11.4. You acknowledge that you use and rely on the Website, Platform and any information provided at your own risk, and that you are responsible for your investment decisions and for obtaining your own professional advice.

12. Termination and Suspension

12.1. You may terminate your use of the Website at any time by ceasing to access it. You may request closure of your Account by contacting us in writing, subject to any outstanding obligations relating to your investments and any requirements under the Fund Documents or law.

12.2. We may suspend or terminate your access to the Website or Platform (in whole or in part) immediately by notice to you if:

(a) you breach these Terms, the NDA or any applicable policy;

(b) we reasonably suspect fraudulent or unlawful activity;

(d) we cease to operate the Website or Platform.

12.3. Termination of your access to the Platform does not, of itself, terminate or affect any investment you hold. Your rights and obligations in relation to any investment continue to be governed by the relevant Fund Documents.

12.4. If your membership of the Platform is suspended or terminated:

(a) this does not in itself terminate your Airwallex Connected Account, which continues to be governed by the Airwallex Terms;

(b) we may stop initiating new instructions to Airwallex on your behalf and may notify Airwallex that you are no longer a Member.

(c) If your Airwallex Connected Account is suspended or terminated, or if Airwallex ceases to provide Embedded Finance Services in relation to the Platform, some Platform Services may no longer be available or may be provided in a different way.

12.5. Clauses which by their nature are intended to survive termination (including clauses relating to confidentiality, privacy, intellectual property, limitation of liability and dispute resolution) continue in force after termination.

13. Complaints and Dispute Resolution

13.1. If you have a complaint about the Website, Platform, Services or these Terms, you should contact us using the details on the Website. We will handle complaints in accordance with our Complaints Resolution Policy.

13.2. If a dispute arises out of or relates to these Terms, the parties must first attempt to resolve the dispute in good faith by negotiation.

13.3. If the dispute is not resolved within a reasonable period (typically 20 Business Days) after it arises, either party may propose that it be referred to mediation administered by a recognised mediation provider. The mediator’s role is to facilitate negotiations; the mediator does not have authority to determine the dispute.

13.4. Nothing in this clause prevents a party from seeking urgent interlocutory or injunctive relief from a court of competent jurisdiction at any time.

14. Governing Law, Jurisdiction and Independent Advice

14.1. These Terms are governed by the laws of New South Wales, Australia. The parties submit to the non-exclusive jurisdiction of the courts of New South Wales and the courts entitled to hear appeals from them.

14.2. The Services offered by Reach Alts are intended to be viewed and used by persons in Australia. If you access the Website or Platform from outside Australia, you are responsible for ensuring that your use complies with the laws of your jurisdiction.

14.3. You acknowledge that:

(a) you have had the opportunity to obtain independent legal, financial and tax advice in relation to these Terms and any investment; and

(b) you understand that the provisions of these Terms are fair and reasonable in the circumstances.

15. General

15.1. Subject to clause 2, these Terms constitute the entire agreement between you and us in relation to your use of the Website and Platform and supersede any prior agreements, understandings or representations.

15.2. You must not assign or transfer your rights or obligations under these Terms without our prior written consent. We may assign or transfer our rights or obligations under these Terms without your consent, provided that such assignment does not materially adversely affect your rights.

15.3. If any provision of these Terms is found to be invalid or unenforceable by a court of competent jurisdiction, that provision is severed and the remainder of theTerms continue in full force and effect.

15.4. No failure or delay by us in exercising any right under these Terms constitutes a waiver of that right, and no single or partial exercise of any right precludes any other or further exercise of that or any other right.

15.5. In these Terms:

(d) the singular includes the plural and vice versa; and

(e) a reference to “including” means “including without limitation”.

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