Financial Services Guide

Version 12.0 - Current as at 2nd November 2026

The Financial Services Guide ('FSG') is an important document designed to assist you in deciding whether to use any of the services offered by 708 Capital Pty Ltd. It provides you with an understanding of what to expect from your interactions with us.

This FSG explains the services we can offer to you and the types of products we offer. lt also explains how we and our Authorised Representatives are remunerated for these services and includes details of our complaints handling procedures and how you can access them.

Who is 708 Capital Pty Ltd?

708 Capital Pty Ltd is the holder of an Australian Financial Services Licence (‘AFSL’) number 386279 and is authorised to provide the financial services detailed below. As a holder of an AFSL, 708 Capital Pty Ltd is required to comply with the provisions of the Corporations Act of 2001 which are administered by the Australian Securities and Investment Commission (‘ASIC’).

708 Capital Pty Ltd is an Australian registered Propriety Limited company with its ACN 142 319 202. Its Directors are Lawrence Buono; Matthew Lumb And Maximilian Ludowici. 708 Capital Pty Ltd’s principal place of business is at Suite 1.05 2-8 Elizabeth Street Paddington NSW 2021.

The Directors are authorised representatives of 708 Capital Pty Ltd. Details in relation to all our authorised representatives are contained in the attached Advisor Profiles.

What financial services can 708 Capital Pty Ltd and its authorised representatives provide?

708 Capital Pty Ltd is authorised to:
Provide general financial product advice only to Retail Clients and financial product advice to Wholesale Clients and to deal in the following financial products:

  • Basic deposit products;
  • Derivatives;
  • Interests in managed investment schemes including lnvestor Directed Portfolio Services;
  • Securities;
  • Superannuation;
  • Standard Margin Lending;
  • Underwriting an issue of securities

And for Wholesale Client only:

  • Managed Discretionary Accounts Services

Whilst 708 Capital Pty Ltd is authorised in its own right to provide the above-named services, 708 Capital Pty Ltd advisors may be authorised by 708 Capital Pty Ltd to provide all, or only some of those financial services. The products and services they are authorised to provide will depend on their experience and qualifications with respect to each product or service. Please refer to the Advisor Profile page for important information about your advisor.

General Advice

Unless otherwise specified the advice that we give you is General Advice only. The Advice we prepare or give you is done so without taking into account your personal and financial objectives or your financial situation or needs. It is up to you to consider the appropriateness of the advice to your financial needs and objectives before acting on the advice.

If the advice relates to the acquisition or possible acquisition of a financial product you should obtain a Product Disclosure Statement (PDS) (if any) for the relevant investments before making any decision.

No Advice

Is where you do not require any advice for the execution of your orders. We will not evaluate the merits of your orders or consider your personal or financial circumstances.

Personal Advice for Wholesale Clients Only
Is advice where we take into consideration your personal and financial objectives.

The effectiveness of Personal Advice is limited to the information provided by you. Without all necessary information the advice given to you may be inappropriate for your personal circumstances.

We are obliged by law to act in your Best Interests and provide appropriate advice irrespective of the type of financial services we provide you.

Statement of Advice ('SOA') - An SOA is not created when you open an account with us.

Product Disclosure Statement ('PDS') - this is a document that provides you with information about a financial product and the entity that issues the financial product (the issuer). We may provide you with a PDS about a financial product when:

  • we recommend that you acquire the financial product; or
  • we offer to issue, or to arrange to issue, the financial product to you.

The PDS must contain information about the financial products, for example its features, benefits, fees and associated risks to enable you to make an informed decision, whether or not to acquire it.

We are not required to give you a PDS where you are dealing in ASX listed equity securities and warrants.

How are any commissions, fees or other benefits calculated for providing the financial services?

708 Capital Pty Ltd is remunerated by retaining part of the brokerage you are charged on your contract note by CMC Markets or Netwealth Group Limited or other execution agents that we may use from time to time, ('herein collectively known as the Execution and Settlement Agent'). The Execution and Settlement Agent retains part of the brokerage and pays the balance to 708 Capital Pty Ltd. Remuneration is also received by 708 Capital Pty Ltd for certain products (such as margin lending products) in the form of commissions (including trailing commissions) paid by product providers.

708 Capital Pty Ltd receives its share of the brokerage, commission and fees from the Execution and Settlement Agent CMC Markets or other Agents that we use.

The Execution and Settlement Agent set out the fees, charges and benefits they receive in their FSG.

708 Capital does not receive commissions or payments from product providers. We are Independent, Impartial or Unbiased when assisting clients. We meet the definition of ‘Independent’ as per s923A of The Corporations Act.

Your Advisor may be an employee of 708 Capital Pty Ltd. As a result, they receive a fixed salary volume based activity payments. At times the Directors of 708 Capital may pay bonus to staff for outstanding performance.

How can you transact with us?

You may place orders with your Advisor, either in person or by telephone. If you choose to use email, posted letter or facsimile for orders you must call your advisor to confirm such orders to avoid any confusion. Emails, facsimiles and letters can be delayed, mislaid or missed completely. We cannot accept liability for any unexecuted orders sent via these methods where they were unconfirmed by your advisor.

Your order will be executed and settled through our Execution and Settlement Agent, CMC Markets or another Agent that we may use. The method by which the Execution and Settlement Agent will accept your or 708 Capital Pty Ltd instructions, will be subject to the terms and conditions of trading between 708 Capital Pty Ltd, the Execution and Settlement Agent and you. This also provides your authorisation for 708 Capital Pty Ltd to open an account with the Execution and Settlement Agent (which will result in the opening of a bank account in the Execution and Settlement Agent's name, as trustee, which identifies you as a beneficiary). To use the sponsorship services, you will need to enter into a CHESS Sponsorship Agreement with 708 Capital Pty Ltd (which forms part of your account opening documentation with 708 Capital Pty Ltd) or to have an account established with Netwealth Group Limited. The Execution and Settlement Agent will provide instructions on your behalf to 708 Capital Pty Ltd.

Brokerage Rates

Brokerage rates are subject to negotiation by the client with the Advisor and may be a rate applicable to all transactions or a rate applicable to a single transaction.

The brokerage rate will be dependent on the type and level of service required and provided and the size and frequency of the transaction. Brokerage is payable on all local and international securities, options and warrant transactions and as a payment for services, such brokerage attracts GST.

As a guide, the minimum brokerage that a client will be charged may range between $100 and 2% of the transaction value plus GST. It is essential that clients discuss brokerage rates with their Advisor.

At times we can realise trading gains well above the market in general and it can be some multiple of the initial investment. On these occasions we may seek to apply a bonus brokerage amount to the trade. If we apply any brokerage above 2% we will first discuss this with and confirm that it can be applied.

Generally, the brokerage paid by you is shared by the Execution & Settlement Agent and 708 Capital Pty Ltd. 708 will use this brokerage payment to cover general operating expenses and will also be used to pay the salaries of its Advisors.

Initial Public Offering and New lssues

Clients are not usually charged brokerage in connection with subscriptions for shares in floats, new issues and placements. However, 708 Capital Pty Ltd may receive handling or placement fees, underwriting fees from the issuer. This fee will be disclosed in the prospectus or other documentation relating to the issue. lf an issuer offers any incentive then it will be disclosed to the client.

Example

lf you apply for $20,000 worth of securities in an initial public offering and the issuer is paying a 3% handling fee, then 708 Capital Pty Ltd will receive a $600 placement fee.

Cash Management

708 Capital Pty Ltd will receive a trailing commission ranging between 0 and 0.5% per annum, on the total funds invested. These may include funds lodged by you into your ANZ or Macquarie Cash Management Account or Netwealth Group Limited linked to your shares trading account with us.

Fail-Fees/Interest

These charges are detailed in the Execution and Settlement Agent's FSG. Suffice to say these fees will be passed onto you.

Self-Managed Superannuation Funds

We are happy to assist you with managing your Self Managed Superannuation Fund. However, before establishing an account with us and on an annual basis you should seek independent professional taxation and financial planing advice to ensure your Superannuation Fund is compliant and that share investments either current or planned are in line with the Superannuation Funds documented Investment Strategy. We do not offer personal advice for self-managed superannuation’s funds unless specifically requested.

Margin Lending Facilities

We are able to assist you in establishing a Margin Lending facility with a number of industry providers. However before doing so you will need independent professional taxation and financial planning advice to ensure that all of the risks associated with Margin Lending have been explained to you and that your financial goals can be met by entering into a Margin Lending facility. We do not offer personal advice for Margin Lending facilities. 708 Capital Pty Ltd may receive a non-volume trailing commission on the total funds borrowed by you from the margin lender. Any fees received by 708 Capital will be disclosed to you.

Your privacy

We are committed to safeguarding your privacy and the confidentiality of your personal information. We will only collect personal information from or about you, which is relevant to the financial services we provide to you. We will limit the release of personal information and will share information only when necessary to administer your account or when required to by law. If you have been referred to 708 Capital by a third party, we may be required to share your information with the referring party pursuant to an agreement that we enter into with them. This information may include but not limited to trading activity, size and frequency; commissions generated and what products are traded. We maintain strong security controls to ensure that the personal information in our files and computers is protected.

708 Capital abides by the Australian Privacy Principles which is a part of the Privacy Amendments (Enhancing Privacy Protection) Act 2012, which amends the Privacy Act of 1988. A full copy of our privacy policy is available on request.

As a result of the Anti-Money Laundering and Counter-Terrorism Financing Act there is now more onus on us to collect more information about you especially when we first establish an account for you. This information is kept by us and is reviewed by our Execution and Settlement Agent who establishes a bank account for you.

You have the right to correct your personal information and obtain access to it.

Complaints

lf you are not happy with the service you receive from 708 Capital Pty Ltd, you are entitled to lodge a complaint. In the first instance, contact 708 Capital Pty Ltd and advise us of your complaint.

You may contact us on 02 9112 2500 or write to us at:
The Compliance Manager
708 Capital Pty Ltd
Suite 1.05 2-8 Elizabeth Street
Paddington NSW 2021

lf you are still not satisfied with the resolution of any complaint, you may refer your complaint to the Australian Financial Complaints Authority (AFCA), of which 708 Capital Pty Ltd is a member. AFCA can be contacted at:

Australian Financial Complaints Authority

GPO Box 3, Melbourne VIC 3001
Telephone: 1800 931 678
Facsimile: (03) 9613 6399
Email: info@afca.org.au
Web: www.afca.org.au

You may also make a complaint to ASIC via their free call lnfoline on 1300 300 630.

Compensation arrangements

We hold a professional indemnity insurance policy suitable for our business. This seeks to ensure that we are able to compensate you if you suffer any loss as a result of the service we (or any of our representatives) provide which is in breach of certain legal obligations to you. These arrangements satisfy the requirements set out under section 912B of the Corporations Act.

The policy includes coverage for claims made in relation to the conduct of representative/employees who no longer work for us but who did at the time of the relevant conduct.

Advisor Profiles

Matthew Lumb (Graduate Diploma of Financial Planning)

Investment Adviser
Director | 708 Capital Pty Ltd - Authorised Representative No. 268288

Matthew has been an investment advisor for over two decades and has been instrumental in assisting high net wealth, ultra-high net wealth and family groups manage their wealth.

The opportunity to assist families in protecting and growing their wealth, is something he sees as a great privilege and takes pride in the meaningful impact he has made improving the financial livelihood of his clients.

Matt offers high-net-worth and family office clients with comprehensive wealth management services. These include financial planning, portfolio construction, estate and succession advice, asset allocation strategies that include access to private equity, alternatives, equities, and debt capital markets.

Matt is widely-regarded as a leading wealth manager in the country.

On the 18th January 2011, 708 Capital Pty Ltd was granted an AFSL 386279 of which Matthew is a Director.

Matthew is remunerated by way of a base salary plus a performance based bonus arrangement

Matthew is authorised to provide product advice and deal in the following financial products:

  • Securities;
  • Investments in Managed Investment schemes including IDPS;
  • Basic deposit products;
  • Derivatives Level 2;
  • Superannuation;
  • Standard Margin Lending and
  • Managed Discretionary Accounts.

Larry Buono (Bachelor of Economics)

Investment Adviser
Director | 708 Capital Pty Ltd - Authorised Representative No. 297286

Larry has been an investment advisor for over two decades with industry experience predominantly servicing high net worth clients and self-managed superannuation funds.

Prior to wealth management, Larry was involved in offshore banking in Hong Kong and Russia involving specialised commercial financing, loan syndication and equities trading.

Following his return to Australia, Larry commenced a career in wealth management. Throughout his advisory career, Larry has navigated many different market cycles including several major global market downturns. Using this experience and a passion for client service and the resources sector, Larry has helped many clients improve their financial situation over time.

Larry predominantly assists high-net-worth clients with portfolio construction, estate and succession advice and asset allocation strategies.

On the 18th January 2011, 708 Capital Pty Ltd was granted an AFSL 386279 of which Larry is a Director.

Larry is remunerated by way of a base salary plus a performance based bonus arrangement

Larry is authorised to provide product advice and deal in the following financial products:

  • Securities;
  • Interests in Managed Investment schemes including IDPS;
  • Basic deposit products;
  • Derivatives Level 2;
  • Superannuation;
  • Standard Margin Lending and
  • Managed Discretionary Accounts.

Max Ludowici (Bachelor of Business)

Investment Adviser
Director | 708 Capital Pty Ltd - Authorised Representative No. 345375

Max commenced his finance career as a resources and commodities analyst with a mid-tier Wealth Manager in 2009 before becoming a Financial Advisor in 2010.

Max has gained significant experience in commodities biased investing in a variety financial markets and cycles. Max has a focus on both wealth management and corporate finance, servicing both domestic and international clients and companies with a specialty focus on metals and mining.

Max left the financial services industry for 3 years, working as General Manager of Operations for a mining engineering business and orchestrated the acquisition of this business by a European-based market leader.

Driven by a strong understanding of macroeconomic and secular trends, Max works closely with corporate and individual clients to provide strategic investment advice and drive successful outcomes for stakeholders.

On the 18th January 2011, 708 Capital Pty Ltd was granted an AFSL 386279 of which Max is a Director.

Max is remunerated by way of a base salary plus a performance based bonus arrangement

Maxis authorised to provide product advice and deal in the following financial products:

  • Securities;
  • Interests in Managed Investment schemes including IDPS;
  • Basic Deposit Products;
  • Derivatives level 1;
  • Superannuation;
  • Managed Discretionary Accounts.

Nicholas Worrall (Bachelor of Business)

Investment Adviser
708 Capital Pty Ltd - Authorised Representative No. 319258

Nick has close to two decades of experience as an investment advisor. An early career in accounting has given Nick strong foundational skills in industry and stock industry analysis.

Nick is known for his dedication to client service with significant experience in portfolio management and asset allocation. Nick is focused on developing long-term, purposeful, and successful relationships with his clients who draw on his considerable experience to help them navigate the financial markets.

Nick has a track record of successfully identifying counter-cyclical market opportunities both locally and abroad to generate outperformance for his clients returns.

Nick is renumerated by way of a base salary plus a performance based bonus arrangement.

Nick is authorised to provide product advice and deal in the following financial products:

  • Securities;
  • Interests in Managed Investment schemes including IDPS;
  • Basic Deposit Products;
  • Derivatives level 2;
  • Superannuation and;
  • Standard Margin Lending
  • Managed Discretionary Accounts.

Will Lumb (Bachelor of Commerce, Graduate Diploma of Financial Planning)

Investment Adviser
708 Capital Pty Ltd - Authorised Representative No. 1317400

Will joined 708 in his penultimate year of university and has progressed through the business, commencing as a Dealer’s Assistant before advancing to Associate, Associate Adviser and, most recently Investment Adviser.

Will brings a disciplined and considered approach to portfolio construction, with particular expertise in alternative investments, including zero-beta strategies, private equity, private credit and hedge funds. He maintains a strong focus on broader macroeconomic trends and their influence on investment markets, asset allocation and portfolio positioning.

Will also possesses outstanding stakeholder engagement skills which underpin his ability to build trusted client relationships and articulate investment strategies and market developments with clarity to his clients.

Will is remunerated by way of a base salary plus a performance based bonus arrangement.

Will is authorised to provide product advice and deal in the following financial products:

  • Securities;
  • Interests in Managed Investment schemes including IDPS;
  • Basic Deposit Products;
  • Managed Discretionary Accounts.

Sam Fogarty (Bachelor of Commerce)

Investment Adviser
Authorised Representative No. 1257153

Sam has more than a decade of private wealth experience. Prior to wealth advisory, Sam founded and successfully exited several private businesses in the education sector giving him strong in-field experience running business operations.

Having developed a passion for financial markets and assisting individuals and families achieve their financial objectives, Sam decided to focus on wealth management. Sam has a keen interest in overlaying macroeconomic trends and investment opportunities. Sam offers his clients a dedicated suite of wealth management services including portfolio construction and asset allocation strategies.

Combined with his extensive industry network and proven track record of consistent returns for his clients, Sam has a strong following in the wealth management space.

Sam is remunerated by way of a base salary plus a performance based bonus arrangement.

Sam is authorised to provide product advice and deal in the following financial products:

  • Securities;
  • Interests in Managed Investment schemes including IDPS;
  • Basic Deposit Products;
  • Managed Discretionary Accounts.

708 Capital Pty Ltd is an Australian Financial Services Licensee
AFSL No. 386279
Street/Postal: Suite 1.05 2-8 Elizabeth Street Paddington NSW 2021