Debt Equity Invest Pty Ltd

Fiduciary Responsibility & Ethical Alignment

Debt Equity Invest Pty Ltd (DEI) operates as a Corporate Authorised Representative (CAR) under the Australian Financial Services Licence (AFSL) of Newport Private Wealth Pty Ltd (NPW). In that role, DEI    adopts and applies NPW’s Code of Ethics, Standards of Professional Conduct and Asset Manager Code as    the  baseline for its own conduct.

DEI commits to:

• Acting in good faith and loyalty – placing client interests ahead of its own and making all investment decisions with a clear focus on long-term investor outcomes.

• Maintaining integrity and transparency – ensuring that all strategies described on the DEI website and in investor documentation are consistent with executed agreements, Information Memoranda and mandates, and that they fairly represent expected risks, timelines and return objectives.

• Identifying and disclosing conflicts of interest – where any related-party arrangements, capital stack positions, fees or other relationships could give rise to a conflict, DEI provides clear, written disclosure so that investors can make fully informed decisions.

All public communications, including website content, are prepared to reflect a true, fair and not misleading view of the investment opportunities and structures being described.

Privacy, Confidentiality & Use of Information

DEI respects the privacy and confidentiality of all investors and prospective investors and operates in line with NPW’s Privacy Policy and the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).

In practice this means:

• Confidential handling of personal information – any personal information collected (such as contact details, identification and financial information) is used only for providing financial services, managing investor relationships and meeting regulatory obligations.

• Secure storage and limited access – DEI applies appropriate security measures to protect personal information from unauthorised access, modification or disclosure. Information is only shared with third parties where required by law, where it is necessary to deliver the agreed services, or with the individual’s consent.

• Responsible use of third-party data – any third-party market data, research or commentary used in DEI materials is either publicly available or appropriately licensed and is presented in a way that does not compromise confidentiality obligations to NPW or to clients.

• Consent for testimonials or case references – where investor testimonials or case examples might reasonably identify an individual or entity, DEI obtains consent before publication, in line with NPW’s privacy and disclosure expectations.

Regulatory Alignment & Website Disclaimers

DEI structures all website content to be consistent with its status as a CAR under NPW’s AFSL and with the requirements of the Corporations Act 2001 (Cth) and ASIC guidance.

Key principles include:

• General information, not personal advice – information on the DEI website is prepared as general information for wholesale and sophisticated investors. It does not take into account any person’s specific objectives, financial situation or needs.

• Advice and product disclosure – where financial product advice or offers are made, they are delivered through appropriate documents (e.g. IMs, term sheets, application forms) with the required warnings and disclosures, not solely via website content.

• Clear website disclaimers – the site states that:

  • content is for information only and is not personal advice;

  • any target returns are objectives only, not forecasts or guarantees; and

  • investment in the strategies described involves risk, including the potential for loss of capital.

Branding, Attribution & Relationship with NPW

DEI is transparent about its regulatory relationship with NPW and about the respective roles of each entity.

On its website DEI:

• Clearly states that Debt Equity Invest Pty Ltd is a Corporate Authorised Representative of Newport Private Wealth Pty Ltd (AFSL 451820), including the relevant CAR number and corporate details.

• Tim Carter (ARN: 001 301 711), 

• DEBT EQUITY INVEST PTY LTD ACN: 667 892 024 AFSL (CAR) No: 001303488

• Clarifies functional roles, for example:

  • NPW, as AFSL holder and trustee/manager (where applicable), provides the licensed framework and compliance oversight;

  • DEI acts as investment manager and capital structuring specialist within that framework.

• Uses NPW’s name, AFSL reference and any logos only in accordance with NPW’s branding and licence conditions and does not imply endorsement beyond the authorised representative relationship.

Risk Disclosure & Performance Representation

Consistent with NPW’s ethical standards, DEI is explicit about risk and careful with any discussion of performance or return objectives.

Website content therefore:

• Provides prominent risk disclosures – including that investments are not bank deposits or capital-guaranteed, values can fluctuate, liquidity may be limited, and there is a risk of partial or total capital loss.

• Clarifies the nature of return targets – any stated yields, IRR targets or distribution objectives are described as targets only and are subject to market, project and counterparty risks.

• Avoids misleading performance impressions – DEI does not present hypothetical or historical performance in a way that could be misconstrued as a promise of future results and clearly states that past performance is not a reliable indicator of future performance.

Fiduciary Governance & Investment Management Practice

Within NPW’s licensed framework, DEI positions itself as a fiduciary-minded investment manager and capital partner.

DEI’s practice includes:

• Diligent investment process – thorough due diligence, scenario analysis and risk assessment before recommending or implementing any strategy.

• Conservative capital structuring – preference for asset-backed exposures, clear ranking in the capital stack, defined exit pathways and structural protections for investors.

• Ongoing monitoring and reporting – providing regular updates to investors on project progress, financial performance, material risks and any changes to strategy, consistent with NPW’s expectations around disclosure and communication.

• Ethical leadership – led by an executive team that emphasises integrity, stewardship and long-term value creation, DEI seeks to align its conduct with both the letter and the spirit of NPW’s codes and policies.

Summary Statement for Website Use

When DEI describes its role and responsibilities on its website, it does so on the basis that:

• Investor interests are placed ahead of DEI’s own commercial interests.

• All statements are consistent with NPW’s Codes, the Privacy Policy and AFSL obligations.

• Risks, conflicts, roles and relationships are clearly disclosed.