Social Media Community Guidelines

Trivian Capital Management Pty Ltd

Our Commitment to You

At Trivian Capital Management Pty Ltd, we are committed to creating a trusted, safe, and engaging online community where we can share insights about growth-stage venture capital and private equity opportunities, market developments, and industry perspectives. These comprehensive guidelines ensure that our social media platforms remain professional, compliant, and valuable for all participants.

Trivian Capital Management Pty Ltd is a Corporate Authorised Representative (Representative Number: 001306338) of Pursuit Capital Pty Ltd (ACN 136 717 283), the holder of Australian Financial Services Licence (AFSL 339211). As such, we are subject to strict regulatory requirements that govern our communications and interactions.

1. Introduction and Scope

1.1 Application of Guidelines

These guidelines apply to all interactions on Trivian Capital's official social media accounts across all platforms, including but not limited to:

·       Facebook

·       LinkedIn

·       Twitter/X

·       Instagram

·       YouTube

·       TikTok

·       Any future social media platforms we may join

1.2 Legal Framework

Our social media activities must comply with:

·       Australian Financial Services laws and regulations

·       Australian Securities and Investments Commission (ASIC) guidance

·       Privacy Act 1988 (Cth)

·       Competition and Consumer Act 2010 (Cth)

·       Corporations Act 2001 (Cth)

·       Platform-specific terms of service and community standards

1.3 Content Monitoring and Recording

·       Our social media channels are monitored during business hours (8:30 AM - 5:30 PM AEST, Monday to Friday)

·       Some content may be recorded for compliance, training, and service improvement purposes

·       We respond to queries and comments within 24-48 hours during business days

·       Emergency or urgent matters should be directed to our direct contact channels

2. Community Standards

2.1 Be Safe - Protecting Your Security and Privacy

Personal Information Protection:

·       Trivian Capital will NEVER request personal, financial, or sensitive information through social media platforms

·       Do not share personal details including:

o   Bank account numbers or financial details

o   Tax file numbers

o   Home addresses or personal contact information

o   Investment amounts or portfolio details

o   Passwords or login credentials

o   Identity document details

·       Be aware that all public posts are visible to everyone and may be archived or shared

·       Use private messaging only for initial contact; detailed discussions should move to secure channels

Security Best Practices:

·       Verify our official accounts by checking for verification badges

·       Be cautious of impersonator accounts or fake profiles

·       Report suspicious accounts or fraudulent activity immediately

·       Never click on suspicious links or download files from unverified sources

·       If you receive unsolicited investment opportunities claiming to be from us, contact us directly to verify

2.2 Be Respectful - Fostering Professional Discourse

Communication Standards:

·       Treat all community members with respect, courtesy, and professionalism

·       Engage constructively in discussions about investment topics, market trends, and business insights

·       Acknowledge diverse perspectives and investment philosophies

·       Use appropriate, professional language at all times

·       Stay on-topic and contribute meaningfully to discussions

Prohibited Behavior:
We have zero tolerance for:

·       Discriminatory language or behavior based on race, gender, religion, nationality, age, sexual orientation, or disability

·       Harassment, bullying, or intimidation of any kind

·       Threatening, abusive, or offensive language

·       Personal attacks or ad hominem arguments

·       Trolling, deliberate disruption, or inflammatory content

·       Impersonation of other individuals or organizations

2.3 Be Fair - Maintaining Market Integrity

Prohibited Activities:

·       Sharing false, misleading, or deceptive information about investments, companies, or market conditions

·       Posting spam, repetitive content, or automated messages

·       Intellectual property violations or copyright infringement

·       Posting content that could manipulate markets or mislead investors

·       Sharing insider information or material non-public information

·       Link baiting or directing traffic to inappropriate sites

·       Promoting illegal activities or unregulated investment schemes

Fair Dealing Principles:

·       Base investment discussions on factual information and credible sources

·       Disclose any potential conflicts of interest in your comments

·       Acknowledge when expressing personal opinions versus sharing factual information

·       Respect proprietary information and commercial confidentiality

3. Financial Services Compliance

3.1 General Advice Disclaimer

Important Notice: All content shared on our social media platforms is general information only and does not constitute personal financial advice. This information:

·       Has not been prepared taking into account your personal objectives, financial situation, or needs

·       Should not be relied upon as the sole basis for investment decisions

·       May not be suitable for your particular circumstances

3.2 Professional Advice Requirements

Before making any investment decisions:

·       Obtain and carefully read all relevant Product Disclosure Statements (PDS)

·       Consider Supplementary Product Disclosure Statements (SPDS) where applicable

·       Seek independent financial, legal, and taxation advice

·       Assess whether any investment aligns with your risk tolerance and investment objectives

·       Consider the suitability of any investment strategy for your circumstances

3.3 Investment Warnings and Disclaimers

Risk Disclosures:

·       All investments carry risk, including the potential for capital loss

·       Past performance is not indicative of future performance

·       Investment values can fluctuate, and you may receive back less than invested

·       Different investment strategies carry different risk profiles

·       Diversification does not guarantee against loss

3.4 No Personal Recommendations

·       We do not provide personal investment recommendations through social media

·       Content shared is for educational and informational purposes only

·       Any discussion of investment opportunities represents general market commentary

·       Individual investment suitability must be assessed through formal advice channels

4. Content Guidelines and Moderation

4.1 Acceptable Content

We welcome and encourage:

·       Questions about our investment philosophy and approach

·       Discussions about market trends and industry developments

·       Educational content about venture capital and private equity

·       Constructive feedback about our content and services

·       Sharing of relevant industry news and insights

·       Professional networking and relationship building

4.2 Content We Will Remove

Posts will be removed if they contain:

·       Personal attacks, defamatory, or discriminatory content

·       False, misleading, or deceptive information

·       Solicitation of personal information

·       Promotion of competing investment services

·       Spam, repetitive, or off-topic content

·       Profanity, explicit language, or inappropriate imagery

·       Links to malicious websites or downloads

·       Confidential or proprietary information

·       Content that violates platform terms of service

4.3 Moderation Process

·       Content is reviewed regularly by our qualified compliance team

·       Inappropriate content will be removed promptly

·       Users may be warned before content removal where appropriate

·       Repeated violations may result in blocking or banning

·       Serious violations will be reported to relevant authorities

·       Appeals can be made through our official contact channels

5. Platform-Specific Considerations

5.1 LinkedIn

·       Professional networking and business-focused discussions

·       Industry insights and thought leadership content

·       Company updates and team announcements

·       Educational content about investment management

5.2 Facebook and Instagram

·       Community building and engagement

·       Behind-the-scenes content and company culture

·       Educational content in accessible formats

·       Event announcements and updates

5.3 Twitter/X

·       Real-time market commentary and news sharing

·       Quick insights and industry observations

·       Engagement with industry leaders and peers

·       Link sharing to detailed content

5.4 YouTube and Video Content

·       Educational webinars and presentations

·       Market analysis and commentary videos

·       Due diligence process explanations

·       Portfolio company spotlights (with appropriate permissions)

6. Regulatory Compliance and Risk Management

6.1 ASIC Compliance

Our social media activities comply with:

·       Information Sheet 269 (Discussing financial products and services online)

·       Regulatory Guide 234 (Advertising financial products and services)

·       Australian Privacy Principles

·       Design and Distribution Obligations

6.2 Content Approval Process

·       All content is reviewed by qualified compliance personnel

·       Investment-related content receives additional legal review

·       Market-sensitive information is carefully evaluated

·       Regular compliance training for all team members

6.3 Record Keeping

·       All social media interactions are archived for compliance purposes

·       Records are maintained in accordance with regulatory requirements

·       Compliance monitoring reports are generated regularly

·       Audit trails are maintained for all content decisions

7. Intellectual Property and Third-Party Content

7.1 Copyright and Trademark Respect

·       All content shared respects intellectual property rights

·       Proper attribution is provided for third-party content

·       Permission is obtained before sharing proprietary materials

·       Fair dealing provisions are carefully observed

7.2 User-Generated Content

·       Users retain ownership of their original content

·       By posting, users grant us permission to share and reference their content

·       We may feature user content in our marketing materials with permission

·       Users are responsible for ensuring they have rights to content they share

8. Crisis Management and Emergency Procedures

8.1 Reputation Management

·       Negative feedback is addressed promptly and professionally

·       Factual corrections are made when necessary

·       Senior management involvement for significant issues

·       Legal consultation for serious allegations or threats

8.2 Security Incidents

·       Immediate response to account compromise or impersonation

·       Clear communication about security breaches or fake accounts

·       Coordination with platform providers for account recovery

·       User notification of relevant security issues

9. Contact and Escalation Procedures

9.1 General Inquiries

For questions about these guidelines or our social media policies:

Kevin O'Hara
Managing Director
Email: kevin@triviancapital.com
Phone: +61 435 767 530
LinkedIn: https://www.linkedin.com/in/kevino23/

9.2 Compliance Concerns

For regulatory or compliance-related matters:

·       Email: kevin@triviancapital.com

·       Mark subject line: "Social Media Compliance Inquiry"

·       Response within 24 hours during business days

9.3 Emergency Contact

For urgent security or reputation matters:

·       Phone: +61 435 767 530

·       Email: kevin@triviancapital.com with "URGENT" in subject line

10. Enforcement and Consequences

10.1 Progressive Enforcement

1.      First Violation: Warning and content removal

2.     Second Violation: Temporary restriction from commenting

3.     Third Violation: Permanent ban from all our social media platforms

4.     Serious Violations: Immediate permanent ban and potential legal action

10.2 Serious Violations

Immediate enforcement action for:

·       Threats of violence or harm

·       Sharing of illegal content

·       Attempts to defraud other users

·       Systematic harassment campaigns

·       Market manipulation attempts

11. Education and Resources

11.1 Financial Literacy

We regularly share educational content about:

·       Investment principles and strategies

·       Risk management techniques

·       Due diligence processes

·       Regulatory changes affecting investors

·       Market analysis methodologies

11.2 Industry Insights

Regular content covering:

·       Venture capital and private equity trends

·       Portfolio company developments

·       Geographic market analysis

·       Sector-specific investment opportunities

·       Economic and market commentary

12. Annual Review and Updates

12.1 Guidelines Review

These guidelines are reviewed annually or more frequently if:

·       Regulatory requirements change

·       New platforms are adopted

·       Significant compliance issues arise

·       Industry best practices evolve

12.2 Community Feedback

We welcome feedback on these guidelines through:

·       Direct messages on our social platforms

·       Email to kevin@triviancapital.com

·       LinkedIn private messages

·       Formal letters to our business address

Contact Information

Trivian Capital Management Pty Ltd

Kevin O'Hara
Managing Director

Address: Level 4, 52 Philip Street, Sydney NSW 2000, Australia
Phone: +61 435 767 530
Email: kevin@triviancapital.com
Website: https://www.triviancapital.com/
LinkedIn: https://www.linkedin.com/in/kevino23/

Important Legal Information

Corporate Authorised Representative: Trivian Capital Management Pty Ltd is a Corporate Authorised Representative (Representative Number: 001306338) of Pursuit Capital Pty Ltd (ACN 136 717 283), the holder of Australian Financial Services Licence number 339211.

General Advice Warning: Any general advice provided on our social media platforms has been prepared without taking into account your objectives, financial situation or needs. Before acting on any general advice, you should consider the appropriateness of the advice having regard to your own objectives, financial situation and needs. We recommend that you obtain professional advice before making any decision in relation to your particular requirements or circumstances.

Privacy and Confidentiality: The information contained in our communications is confidential and is intended solely for the addressee. If you are not the intended addressee, you must not disclose or use the information in any way. Trivian Capital Management Pty Ltd and their related entities and each of their respective directors, officers and agents believe that the information contained in our communications has been obtained from reliable sources. No warranty is made as to the accuracy of the information, and to the maximum extent permitted by law, Trivian disclaims all liability for any loss or damage which may be suffered by any recipient through relying on anything contained in our communications.

Document Version: 1.0
Issue Date: February 2025
Next Review Date: February 2026
Approved by: Kevin O'Hara, Managing Director

These guidelines are designed to create a safe, compliant, and valuable social media environment for all participants. We reserve the right to update these guidelines as necessary to reflect regulatory changes, platform updates, or community needs. By participating in our social media communities, you agree to abide by these guidelines and the terms of service of the respective social media platforms.