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About the company
What is Wholesum?
Wholesum is a financial services innovation company founded by Dr. Tanvir Uddin in 2023. The company, headquartered in Sydney, Australia strives to provide responsible financial services that address the needs of a diverse customer base.

Wholesum is the manager of the Wholesum Responsible Fund (”Fund”), a licensed wholesale fund management services. The Fund was launched in January, 2024 to provide a globally diversified ethical investment offering that connects investors to impact-focused investment opportunities.

For the Fund, Wholesum is the Corporate Authorised Representative (CAR 001307369) of Boutique Capital Pty Ltd (ACN 621 697 621, AFSL 508011).

What makes Wholesum different to other ethical investment funds?

Wholesum utilises a unique, proprietary combination of screening and assessment criteria to select its investment assets. Specifically, there are three key attributes that differentiate the Wholesum Responsible Fund (”Fund”) from other ethical investment funds:

Firstly, the Fund invests directly with purpose such that there are direct and indirect positive societal benefits that the Fund’s investments achieve. For example, investing into small and medium-enterprise and microfinance financing helps generate positive impact via reducing poverty or income inequality around the world.

Secondly, Wholesum applies a unique set of negative screening criteria. Wholesum strictly avoids investments into businesses or projects that are engaged in:

  • Tobacco
  • Alcohol
  • Financial services that practice conventional non Shari’ah finance activities
  • Immoral purposes
  • Gambling
  • Pork food products
  • Armaments and weaponry
  • Hotel and accommodation premises serving alcohol
  • Businesses deemed unacceptable by the Fund’s ethical investment advisors.

Thirdly, while most ethical funds only invest in listed assets (such as company stocks and bonds) in typically developed markets such as in Australia or the United States, Wholesum invests in a more diverse set of assets. For example, the Wholesum Responsible Fund invests in onshore and offshore secured and unsecured Debt, Equity, Listed / Unlisted Managed Funds, ETFs (exchange-traded funds), Crowdfunding Platforms, and Direct Unlisted Placements

Please refer to the investing page and relevant product disclosure documentation that will be made available on this website to learn more about Wholesum’s investing strategy and fund features.

What does the name Wholesum mean?
Wholesum is a play on the world “wholesome” and makes reference to finance through the word “sum”. Wholesum means beneficial and full of goodness. In line of Wholesum’s mission and brand identity, Wholesum endeavours to offer responsible investments that take into consideration the harms of certain economic activities (such as the alcohol industry and interest-bearing transactions) as well as promotes positive economic empowerment (such as financing small and medium-sized enterprises).
How is Wholesum regulated?
As an incorporated company, Wholesum is regulated by the Australian Securities and Investments Commission.

When Wholesum launches its inaugural fund, it will be registered under the Australian Corporations Act 2001 (Commonwealth). It will also be regulated by the Australian Securities and Investments Commission.

Who are Wholesum’s shareholders?

Wholesum has been established by a founder, Dr Tanvir Uddin, and with the backing of individual “angel” investors. These angel investors share Dr Uddin’s passion for responsible investing and his vision to support financial empowerment worldwide.

What is the current stage of the company’s formation and operations?
Wholesum is an Australian incorporated company, registered under the Australian Securities and Investments Commission.

Wholesum is currently undertaking diligence and selection of its legal and compliance vendors (including the Responsible Trustee and Australian Financial Services License Corporate Authorised Representative grantor) to establish and operate its registered management investment scheme.

When Wholesum launches its fund (targeted for late 2023), it will be open to retail, sophisticated and institutional investors.

About the Wholesum Responsible Fund
Is the Wholesum Fund licensed and regulated?

Yes, Wholesum is the Corporate Authorised Representative (CAR 001307369) of Boutique Capital Pty Ltd (ACN 621 697 621, AFSL 508011). The Australian Securities and Investments Commission (ASIC) oversees Australian financial services licensing. Our licensing certificate record can be access here.

As a wholesale fund, the Wholesum Responsible Fund is not registered with ASIC. Under the Corporations Act 2001 (Commonwealth), registration is only mandatory for retail managed investment schemes. The Corporations Act is the main law regulating business entities, securities and financial services in Australia.

How does one apply and participate in the Wholesum Fund?
The initial registration and any subsequent account changes or requests are all managed through Wholesum’s digital investor registry platform. The platform is powered by RegistryDirect and allows investors to undertake the following activities digitally:

  • Open an account
  • Apply to purchase units in the fund
  • Redeem their units and withdraw
  • Request distribution payouts
  • Amend their personal or bank details
  • Review fund performance and investor updates
  • Obtain contact details for the Trustee (Boutique Capital) and Fund Manager (Wholesum).

Interested investors can access either of the following links that apply to them as per our current promotional offers:

Which types of investors can join the Wholesum Fund?

As a wholesale investment fund, the Wholesum Responsible Fund only accepts accredited investors. This means, that sophisticated investors, professional investors, and large investors can invest in the wholesale fund as defined and regulated by the Corporations Act.

A high level overview of the qualifying requirements include:

  • Sophisticated investors qualify with $250k+ gross income or $2.5m net assets. They are certified by a qualified accountant.
  • Professional investors are experienced investors, financial institutions, or professional funds.
  • Large investors qualify with an investment of $500k or more.

The above qualification requirements apply to a range of investor types who can all invest in the Wholesum Responsible Fund including the following:

  • Individuals
  • Charities and non-profits
  • Small, medium and large businesses
  • Self-managed superannuation funds (SMSF)
  • Investment trusts
  • Financial institutions.

Depending on the entity’s circumstances, the organisation (such as a company or trust) and its controlling Director(s) may need to obtain an accountant’s certificate each to certify them as a sophisticated investor.

For more detailed information on the requirements and a template accountant’s certification form (here), visit the Wholesum Wholesale Investing page (here).

If you would like assistance with obtaining certification, unsure if you meet the requirements or would like to know more, drop us an email to hello@investwholesum.com to discuss your eligibility to join the Fund.

Can investors outside Australia invest in the Wholesum Fund?

Yes, the fund is available to investors worldwide. There may be additional requirements to qualify as a wholesale investor as well as passing Anti-money Laundering / Know Your Customer (AML/KYC) checks.

Should you like to discuss your eligibility or learn more, please email us at hello@investwholesum.com.

What are your target returns and the historical performance of your portfolio?

The Wholesum Responsible Fund’s strategy is to achieve the greater of:

  • 3% above Australian Consumer Price Index (measured over an annual basis), or
  • 8%.

The target is net of management fees.

The historically modelled portfolio (that is based on the actual historical performance of the underlying investment positions), has been on average ~11%.


Note past performance is not a guarantee of future performance. All investing carries risk.

For further information, see the Information Memorandum (here) or contact us at hello@investwholesum.com.

What is the minimum and maximum investment amounts and balances?
The minimum to join the Fund is $25,000 AUD. There is no maximum investment amount. If an investor invests $500,000 AUD in one go, they do not require any wholesale investor certification.

Investors can subsequently top-up their investments if they wish only a monthly basis with a minimum of $2,000 AUD. Investors must always retain a minimum $5,000 AUD balance to keep their account open.

Promotion offer

Investors who open an account with a balance of $100,000 AUD is entitled to a 25% management and performance fee discount. To access this offer, please join using this digital application link (here).

When is the minimum and maximum duration that one must keep their money in the Fund?

The minimum lock-in period for investment units is 6 months. An investor may request an earlier redemption for an early exit fee. As an open ended Fund, there are no maximum term limits for the Fund. However, under law, the Fund must end after 80 years, less 1 day.

The early exit fee is:

  • 1.5% of the redemption value, if the redemption of units occurs within the first 3 months of application, or
  • 1% of the redemption value, if exiting after 3, bit before 6 months.
What are your fees?
Promotional Fees

As of 13 January 2024, management and performance fee rebates (discounts) are available to early access investors, non-profits / charities and large value investors:

To discuss eligibility, please contact us at hello@investwholesum.com. You can also directly apply using the following specific application links for each promotional investor type.

Standard Fees

There are 4 appliable fees in the Wholesum Responsible Fund. The other applicable fees and the standards rates are outlined in the table below:


1 All fees are expressed as a percentage of NAV of the Fund excluding accrued fees. 2 These are expressed as a percentage of your redemption amount.

For more information, please consult the Information Memorandum (here).

Should you have any questions or wish to discuss investing in the Wholesum Responsible Fund, email us at hello@investwholesum.com.

When can I withdraw my funds?

There is a 6 months lock in, after this the funds can be withdrawn. There is a minimum redemption of $1 000 and the redemption has a monthly frequency.

Which entity, company or institution types can invest in the Wholesum Fund?

Organisations including charities and non profits, small and medium sized businesses, and large corporations are able to invest in the the Wholesum Fund.

How does one register and participate in the Wholesum Fund?

The initial registration and any subsequent account changes or requests are all managed through Wholesum’s digital investor registry platform. The platform is powered by RegistryDirect and allows investors to undertake the following activities digitally:

  • Apply to purchase units in the fund
  • Redeem their units and withdraw
  • Request distribution payouts
  • Amend their personal or bank details
  • Review fund performance and investor updates

Interested investors can use the platform through a dedicated Wholesum link.

How long after registering in the Fund app can one start investing?

For domestic users, 3 business days are required and for overseas users, 7 business days are required before investing.

When will the Wholesum Fund launch?

The fund will launch for wholesale investors in Q4 (October), 2023.

About Wholesum’s responsible investments
What does the Wholesum Fund invest in?

Wholesum allocates funds from investors into a range of onshore and offshore investment assets. These include secured and unsecured Debt, Equity, Listed / Unlisted managed or mutual funds, Exchange-traded funds (ETFs), Crowdfunding Platforms, and Direct Unlisted Placements into companies or projects. To achieve its impact focus, the Fund allocates up to 80% of funds into small and medium-sized enterprises and microfinance.

The Fund takes into consideration ethical and Shari’ah compliance, and the Fund will target at least 60% assets (based on the net asset value of the Fund) that align with Environmental, Social and Governance (ESG) criteria and / or generate what we consider to be a positive direct and / or indirect societal impact.

You should read the important information about the investment strategy under the section titled “Investment Strategy” in the Information Memorandum (here).

For further information about Investing with Wholesum, see here or email us at hello@investwholesum.com.

How do you select the assets to invest in?

Our goal is to select a portfolio that truly resonates with our clients’ values, spearheads ethical / Shari’ah compliance and strives to achieve positive societal impact.

To achieve this mission, the Fund implements a balanced, style-agnostic strategy that combines passive allocation and active rebalancing to achieve its target returns with moderate risk through a 5-year market cycle. Active management involves rebalance of tradeable asset classes in the portfolio in a disciplined manner to ensure the portfolio conforms to the target asset allocation and achieves the target return.

The asset selection process follows three steps:

  1. Asset manager or direct company or project selection
    Wholesum collaborates with specialist asset managers and evaluates their historical performances, investment strategies, governance, and risk management as part of our rigorous selection process.
  2. Ethical and Shari’ah compliance negative screens
    Next, Wholesum applies negative screens to remove any non-compliant investments. Where Wholesum partners with an underlying investment manager, we make sure they have suitable ethical and Shari’ah governance systems in place to ensure that our investments with them are compliant with our mandate.
  3. ESG and positive impact screens
    Finally, Wholesum prioritises investments that meet Environment, Social and Governance (ESG) criteria and /or generate a direct or indirect positive societal impact from among the investment options that pass steps 1 and 2 above. As per the Information Memorandum, the Fund must maintain at least 60% of its net asset value in investments that meet ESG and positive impact criteria.

For more information about the negative (ethical and Shari’ah compliance) and positive (societal impact) screens, see the detailed FAQ on responsible and ethical investing (here).

Other considerations

While all assets must comply with our ethical and Shari’ah compliance requirements, we select Exchange Traded Funds (ETFs) and cash/short-term debt that are not necessarily targeting ESG and positive societal impact. The ETF and cash/short-term debt investments are tactically selected for liquidity purposes so we can quickly pay out redemption and distribution requests from investors.

What makes your investments ethical and Shari’ah compliant?
The Wholesum team applies a rigorous process to select responsible and ethical investments into the Wholesum Responsible Fund.

Negative screens are used to exclude investments from the investable universe because they conflict with our investment principles on ethical and Shari’ah-compliance.

Read more…

How does your fund fulfill ESG and positive impact investing standards?

The Fund will target at least 60% of assets (based on net asset value of the Fund) that align with Environmental, Social and Governance (ESG) criteria and / or generate what we consider to be a positive direct and / or indirect societal impact.

Read more…

Who are your fund management and service providers? [disabled]

As one of the most regulated business activities under Australian law, Wholesum contracts with a number of reputable and highly-experienced fund service providers to ensure ongoing compliance with financial services regulations.

The table below outlines the key parties that Wholesum has appointed and their role in the funds management process.

Read more…

What risk management procedures are in place to protect investor funds?

There are three core risk management mechanisms that Wholesum applies to its investment activities.

Risk management via asset diversification strategies

Wholesum seeks to diversify the investment assets across a number of parameters. Wholesum diversifies the holdings of assets based on a range of factors that could affect fund performance.

Read more…

Is the Wholesum Fund Shari’ah-compliant / Islamically-certified? [Disable]

Yes! Wholesum invests 100% of assets in Shari’ah compliant assets.

How do your investments generate positive societal impact? [draft]

Wholesum invest in locations, companies, and projects that drive positive social outcomes such as job creation and poverty reduction.