Ownership.

1. Purpose

This internal policy records the intended separation between:

• South Nadus Holdings Pty Ltd — Australian parent company; and
• Kiwi Rewards Club Limited — New Zealand operating subsidiary.

2. Ownership

South Nadus Holdings Pty Ltd owns the shares in Kiwi Rewards Club Limited as recorded in the New Zealand Companies Register.

3. Operating Responsibility

Kiwi Rewards Club Limited should ordinarily be responsible for the New Zealand operating business, including memberships, customers, merchandise sales, promotions, payments, partner/supplier contracts, support, refunds, prizes, privacy obligations and NZ regulatory compliance.

4. Parent Company Role

South Nadus Holdings Pty Ltd may provide ownership capital, strategic oversight, technology, IP, management services, shared personnel, finance support, marketing support and other group services. Material intercompany arrangements should be documented.

5. Separate Legal Personality

Kiwi Rewards Club Limited must be treated as a separate legal entity. Avoid unnecessary commingling of bank accounts, customer funds, contracts, invoices, tax records, liabilities, accounting records and corporate approvals.

6. Banking and Payments

Where commercially practical, KRC customer revenue should settle to an account held for Kiwi Rewards Club Limited and payment-provider accounts should identify Kiwi Rewards Club Limited as the merchant/legal entity.

7. Contracts

New Zealand customer and operating contracts should normally be entered into by Kiwi Rewards Club Limited.

8. Intellectual Property

Document whether material KRC IP is owned by Kiwi Rewards Club Limited, South Nadus Holdings Pty Ltd and licensed to KRC, or another group entity.

9. Privacy and Data

Kiwi Rewards Club Limited should ordinarily be the primary New Zealand privacy-facing entity. Parent access must be treated as group-company disclosure and managed under applicable privacy law.

10. Promotional Activities

Where KRC Limited conducts a New Zealand sales promotion scheme, it should ordinarily be identified as promoter, maintain the promotion records, control the entry ledger and bear or contract the prize obligation.

11. Corporate Approvals

Material promotions, high-value prizes, banking, borrowing, major supplier contracts, related-party agreements, dividends, significant IP transactions, litigation and regulatory matters should be approved at the correct entity level.

12. Accounting and Tax

Maintain separate books and records for each entity. Intercompany funding, service charges and transfers should be documented and reviewed by an AU/NZ cross-border accountant.

13. Public Disclosures

Customer-facing surfaces (footer, About, marketing) identify Kiwi Rewards Club Limited only.

Parent/shareholding is disclosed in Help Centre pages (this page and the Privacy Policy):

14. Review

Review this policy when ownership, group structure, jurisdiction, IP ownership, payment flows or tax/legal advice materially changes.

15. Corporate Contact Routing

• Corporate administration, Companies Office, IRD, banking and supplier administration: admin@kiwirewards.club
• Legal notices: legal@kiwirewards.club
• Privacy matters: privacy@kiwirewards.club
• Customer support: support@kiwirewards.club
• Promotions and winner administration: promotions@kiwirewards.club

The admin@ address is an internal operational address and should not be published as a general customer contact unless required for a specific purpose.