Fire Equipment Options

Requirements Loaded

Compound requirements document: LOADED (/home/ed/base/projects/Max Storage/.claude/knowledge/integration/legal-compliance.md, last updated 2026-04-01).

Key constraints extracted from compound requirements:

---

Phase 1 Budget: ~$2,000

The guidance budget is approximately $2,000 for fire equipment including extinguishers and signage. Sprinklers are explicitly excluded from Phase 1 (would trigger BWoF). All costs below are in NZD inclusive of GST (15%).

---

Options

Option A: ABE Extinguishers Only -- Minimum Legal Compliance

Spec summary

• 12 x 4.5kg ABE dry powder extinguishers: one per internal bay (standardised across both large boat/caravan bays and small household goods bays)
• 3 x 9kg ABE dry powder extinguishers: two at opposite ends of the boat storage side of the building externally, one on the household goods side
• Total: 15 extinguishers
• Each extinguisher mounted on a purpose-made bracket at handle height 0.9--1.5m above floor
• Each extinguisher must be unobstructed and visible at all times
• One NZS 4503:2005 compliant Blazon/ID sign at each extinguisher location (15 signs)
• No detection, no suppression, no alarm panel

Placement against the 15m Class B travel distance rule

Enclosed boat/caravan bays are approximately 11m deep x 4m wide. One 4.5kg ABE mounted at the bay entry ensures no point in the bay is more than 11m from an extinguisher -- well within the 15m Class B maximum. The 15m rule is satisfied by bay-level placement. External 9kg units provide first-attack capability outside the bays.

No smoking / no naked flames signage

This is required under both compound requirements (induction signage obligation) and fire risk management best practice. These signs are not NZS 4503 specified-system signs -- they are general prohibition notices and do not trigger any regulatory classification.

Requirements compliance

Does this trigger BWoF?

NO. Portable fire extinguishers are explicitly not a Specified System under the Building Act 2004. Installing extinguishers alone does not create a compliance schedule entry or a BWoF obligation. This is confirmed in both the compound requirements document and the Tier 1 fire requirements document.

Phase 1 cost (NZD incl. GST)

Note: Source pricing is derived from fireextinguishersonline.co.nz 2024/2025 data (excl. GST) converted to GST-inclusive. This range exceeds the $2,000 Phase 1 budget envelope. See budget discussion below.

Budget discussion

The $2,000 guidance budget is tight when an IQP commissioning visit is included. Two approaches to stay closer to budget:

1. Purchase extinguishers and signs directly online (Fire Extinguishers Online, nationwide free delivery) at the lower end of the price range, and have Ultrafire (Tauranga) supply and install the brackets and perform the IQP initial inspection as a combined visit. This reduces the equipment-purchase margin and may bring the total closer to $2,400--$2,600 incl. GST.

1. Request a full-supply-and-install quote from Ultrafire Protection (Tauranga). A single-supplier quote for 15 extinguishers, brackets, signs, and IQP commissioning may produce a better total price than piecemeal purchasing. Supplier quotes should be obtained before committing -- see Open Questions.

The $2,000 budget is realistic for equipment-only (extinguishers, brackets, signs) if the IQP visit is treated as a small additional cost. The IQP visit is legally required; it cannot be deferred.

Annual inspection cost estimate

• Annual IQP inspection and service: approximately $35--$80 per extinguisher
• 15 extinguishers x $55 average = $825/year (incl. GST estimate)
• 5-yearly hydraulic test: approximately $23--$46 per unit x 15 = $345--$690 every 5 years

Phase 2/3 upgrade path

Phase 2: Add standalone smoke detectors per bay (see Option C). These must be standalone units with no interconnection between bays and no panel -- confirm with Rotorua Lakes Council that the chosen unit does not constitute a Specified System before purchasing. Estimated additional cost: $600--$1,200 for 12 standalone battery-operated units.

Phase 3: If aggregate stored goods value justifies it, obtain a fire engineering assessment and install a wet pipe sprinkler system (NZS 4541:2020). Budget $18,500--$55,000+ depending on water supply availability. This will trigger BWoF and annual IQP compliance obligations.

NZ suppliers

• Ultrafire Protection Limited -- Tauranga-based, covers Bay of Plenty/Rotorua corridor, FPANZ member, 60+ years combined experience. Phone: 07 394 4439. Email: kris@ultrafire.co.nz. Recommended first contact for supply, installation, and ongoing IQP service contract.
• Wormald NZ (wormald.co.nz) -- National coverage, suitable for ongoing service contract if Ultrafire cannot service Hamurana.
• Fire Extinguishers Online (fireextinguishersonline.co.nz) -- Online supply only, nationwide free delivery, competitive pricing for direct purchase. Cannot perform IQP inspection -- supply only.

Risks

• Budget overshoot: Option A will likely cost $2,400--$2,600 incl. GST with IQP commissioning, not $2,000. The $2,000 envelope is achievable for equipment alone but not equipment plus IQP visit. Flag to Ed before purchasing.
• Relies entirely on human first response -- if a fire starts when the site is unattended, extinguishers offer no benefit until someone arrives. Total loss of bay contents is a realistic scenario for an overnight fire.
• ABE dry powder residue causes significant secondary damage to stored goods (boats, upholstery, electronics) even when the fire is controlled. Customers should be made aware.
• Upgrade to 9kg ABE for any internal bay where a customer stores a boat with a tank over 75 litres (the compound requirements specify open-air bays for boats with tanks over 75L -- but for any enclosed bay with a large tank, the fire suppression capability should match the fuel load).

---

Option B: ABE Extinguishers + Standalone Smoke Detectors Per Bay (No Panel, No Interconnection)

Spec summary

Everything in Option A, plus:

• 12 x standalone battery-operated smoke detectors, one per internal bay
• Units must be self-contained -- no wiring between units, no central panel
• The detector sounds a local alarm only (siren in the bay where smoke is detected)
• No monitoring contract, no dial-out capability in Phase 1
• Suitable units: Clipsal 755SMK (hardwired) or equivalent battery-operated photoelectric smoke detector (NZS 3580 compliant)
• Battery replacement approximately every 1--2 years (some units use 10-year sealed batteries -- prefer these for an unattended facility)

Requirements compliance

Does this trigger BWoF?

NO -- provided the detectors are truly standalone (battery-operated, no wiring to a panel, no interconnection between units). Standalone smoke detectors in individual bays do not constitute a fire alarm system under the Building Act 2004 Specified System definitions and do not trigger a compliance schedule or BWoF obligation.

IMPORTANT CAVEAT: If any unit is wired (rather than battery), or if the detectors are interconnected (even wirelessly through a hub), this assessment changes. The safe Phase 1 approach is battery-operated units with no wireless mesh or hub. Confirm the chosen unit type with Rotorua Lakes Council / a building consent authority before purchasing if there is any uncertainty about the specification.

Phase 1 cost (NZD incl. GST)

This exceeds the $2,000 Phase 1 budget envelope. It is a modest overshoot relative to the safety benefit. If budget must hold at $2,000, Option A is the correct Phase 1 choice and standalone detectors become the first Phase 2 addition.

Annual inspection cost estimate

• Same as Option A for extinguishers: ~$825/year
• Smoke detectors: battery replacement approximately $5--$10 per unit per year (sealed 10-year battery units effectively nil until year 10 replacement)
• No IQP obligation for standalone detectors
• Total annual cost: approximately $825--$950/year

Phase 2/3 upgrade path

Phase 2: Add dial-out capability via a standalone GSM communicator module attached to a single central detector or sounder -- this alerts Tom (SMS/call) when any bay detector activates without creating an interconnected system. Budget approximately $150--$300 for the GSM module. Still does not trigger BWoF if designed as a standalone dial-out, but confirm with Rotorua Lakes Council.

Phase 3: Full monitored fire alarm system (NZS 4512:2021) -- triggers Specified System, BWoF, and IQP obligation. Appropriate only if the business scales significantly or a tenant or insurer requires it.

NZ suppliers

Same as Option A for extinguishers and signs. For standalone detectors:

• Bunnings NZ -- stocks Clipsal, Ei Electronics, and compatible battery smoke detectors. Accessible in Rotorua (Te Ngae Road store). Lowest price for battery units.
• Mitre 10 NZ -- similar product range.
• Electrical trade suppliers (Rotorua Electrical, CEL) -- supply photoelectric detectors in commercial quantities.

Note: Smoke detectors for this application do not require specialist fire trade installation -- they can be installed by Tom using a drill and a step-ladder. No IQP is required for standalone battery detectors.

Risks

• Standalone detectors provide early warning only -- no suppression, no automatic FENZ notification. A detector activating at 2am on an unattended site provides no benefit unless Tom or a neighbour can hear the siren and call 111.
• If Tom is not nearby, the early warning benefit is limited to reducing the time between fire start and FENZ arrival -- useful but not a substitute for suppression.
• Over-specification risk: if a purchaser inadvertently buys a wireless-mesh interconnectable unit (e.g., from the Nest/Ring ecosystem or a panel-compatible brand) and interconnects the units, this may trigger a Specified System classification. Purchase standalone-only units from a hardware store rather than from a fire protection company to avoid this risk.
• Budget overshoot: approximately $1,200--$1,500 above the $2,000 guidance budget when IQP visit is included.

---

Option C: ABE Extinguishers Only -- Reduced Count, Budget-Constrained

Spec summary

A reduced-count variant of Option A, targeting the $2,000 budget by purchasing fewer extinguishers at Phase 1 and deferring some internal bays to Phase 2. This option is presented for completeness, but it is NOT RECOMMENDED -- see BWoF and compliance note below.

• 6 x 4.5kg ABE (large boat/caravan bays only)
• 3 x 9kg ABE external (same as Option A)
• 6 x small household goods bays deferred to Phase 2
• Reduced signage: 9 ID signs for Phase 1 extinguishers only

Does this trigger BWoF?

NO. Same reasoning as Option A -- extinguishers alone, regardless of count, do not trigger BWoF.

Requirements compliance

Phase 1 cost (NZD incl. GST)

This fits within or marginally above the $2,000 budget.

Annual inspection cost estimate

• 9 extinguishers x $55 average = $495/year
• 5-yearly hydraulic test: $207--$414 every 5 years

Phase 2 upgrade path

Add the remaining 6 x 4.5kg ABE for the household goods bays as soon as budget allows. Cost to complete: approximately $900--$1,000 incl. GST for units, brackets, and signs.

NZ suppliers

Same as Option A.

Risks

• COMPLIANCE RISK: The small household goods bays are unprotected in Phase 1. If a fire starts in a small bay, there is no extinguisher within the required travel distance. NZS 4503:2005 requires extinguishers in all occupied areas -- the operator cannot selectively omit bays that are actively rented.
• RECOMMENDATION: Option C is only acceptable if the small household goods bays are not rented out until the remaining extinguishers are installed. If all 12 bays will be offered to customers at Phase 1 launch, Option A (full complement) is required.
• Do not use this option to defer compliance to save cost if all bays are open.

---

Recommended Option

Recommended: Option A (ABE Extinguishers Only -- Minimum Legal Compliance) is the correct Phase 1 choice.

Rationale:

• Option A satisfies all mandatory NZS 4503:2005 requirements for this facility, including the 15m Class B travel distance rule in enclosed bays.
• It does not trigger any BWoF obligation.
• It is consistent with the Phase 1 priority (legal compliance at minimum cost) and the guidance budget intent.
• It avoids all Specified System obligations, building consent processes, and compliance schedule entries.
• The $2,000 budget is marginally tight when IQP commissioning is included. The realistic Phase 1 cost is approximately $2,400--$2,600 incl. GST for a full 15-extinguisher installation with IQP commissioning. This should be flagged to Ed before purchasing. A single-supplier quote from Ultrafire Protection (Tauranga) may bring the total closer to budget.

Option B (adding standalone smoke detectors) is recommended as the first Phase 2 addition, not Phase 1 -- it adds meaningful early-warning benefit at modest cost and does not trigger BWoF if the correct battery-operated, non-interconnected units are specified. Budget the additional $336--$660 for detectors once the Phase 1 extinguisher baseline is in place.

Option C is not recommended unless the small household goods bays are not being rented at Phase 1 launch. If all 12 bays are open to customers, the full 15-extinguisher complement is legally required.

---

Location Compliance Certificate (Separate Process)

This is a pre-opening legal requirement derived from the compound requirements document. It is not a fire equipment item but must be resolved before Phase 1 launch.

What it is: If the aggregate petrol likely to be on site at any time exceeds 50 litres (Class 3.1A flammable liquids), the site may require a Location Compliance Certificate under the Health and Safety at Work (Hazardous Substances) Regulations 2017.

Why it may be triggered: Multiple boats stored simultaneously, each with a petrol tank of 15--25 litres, can aggregate to over 50 litres quickly. For example, four boats each with 15-litre tanks = 60 litres.

Process:

1. Engage a WorkSafe-registered compliance certifier to conduct a one-time assessment of the site and the likely aggregate hazardous substance quantities.
2. The certifier will confirm whether the 50-litre threshold is triggered for Class 3.1A (petrol) and whether any other HSNO thresholds apply (LPG aggregate, etc.).
3. If a certificate is required, the certifier issues a Location Compliance Certificate after confirming the site meets storage requirements (ventilation, signage, spill kit, separation distances).
4. The certificate must be renewed periodically (typically annually or on change of use).

Estimated cost: $500--$1,500 for initial assessment and certificate, depending on certifier. This is a separate budget line from the $2,000 fire equipment envelope.

NZ compliance certifiers (Bay of Plenty region):

• WorkSafe NZ maintains a register of compliance certifiers. Search at worksafe.govt.nz under "compliance certifiers -- hazardous substances."
• Tauranga-based certifiers will be the most accessible for Hamurana. Ultrafire Protection may be able to recommend a certifier contact through their FPANZ network.

Action required: Commission this assessment before first customer stores a boat with a petrol tank. This cannot be deferred.

---

Fire Signage Summary

The following signs are required at Phase 1, drawn from the compound requirements and NZS 4503:2005:

Note on emergency exit signage: The open-bay shed design likely does not require illuminated emergency exit signs -- the bay openings are the exits. Confirm with Rotorua Lakes Council if any enclosed office or welfare area is added; that would trigger illuminated exit sign requirements.

Consolidated signage note: The compound requirements document references operational/signage-requirements.md as the master consolidation point for all signage (CCTV, H&S, fire, prohibition). The signage vendor agent should read that document once populated. Fire signage above should be cross-referenced against that document to avoid duplication or gaps.

---

Open Questions

1. Budget confirmation: Option A realistic cost is approximately $2,400--$2,600 incl. GST (equipment + IQP commissioning), not $2,000. Does Ed want to adjust the budget envelope, or should the IQP visit be treated as a separate line item outside the $2,000 fire equipment budget?

1. Ultrafire quote: Has a supply-and-install quote been requested from Ultrafire Protection (Tauranga)? A combined supply + IQP commissioning quote may reduce total cost and should be obtained before any direct purchasing. Also seek a second quote from Wormald NZ or a Rotorua-based fire protection provider for comparison.

1. Location Compliance Certificate: Has a WorkSafe-registered compliance certifier been engaged? This is a pre-opening legal requirement if aggregate petrol on site will exceed 50 litres. It needs to be commissioned as soon as the likely occupancy pattern (number of boats with petrol tanks) can be estimated.

1. Enclosed bay ventilation: The Easter 2026 site visit should confirm whether the 12 enclosed bays have adequate ventilation (louvres, gaps at eaves, or mechanical extraction) to prevent petrol vapour accumulation. If not, this needs to be addressed before boats with fuel tanks are stored -- it is an HSWA PCBU obligation, not optional. What is the current ventilation state of the bays?

1. Boat tank volumes: Are typical stored boats expected to have tanks over 75 litres? The compound requirements specify that boats with tanks over 75L should be stored in open-air bays, not enclosed shed bays. If any customer wants to store a large-tank boat in an enclosed bay, this needs to be assessed against HSNO and ventilation requirements before accepting the booking.

1. Standalone smoke detector confirmation with Rotorua Lakes Council: Before purchasing standalone detectors for Phase 2, confirm with Rotorua Lakes Council (building consent authority) that the chosen unit does not constitute a Specified System. A brief written query (email to BCA with the product spec sheet) is sufficient to get a position on record and avoids accidentally triggering BWoF.

1. IQP service contract: The annual inspection obligation requires an IQP. Ultrafire Protection (Tauranga) is the recommended primary contact. Confirm they cover Hamurana for annual call-outs and their travel charge basis before committing to them as the ongoing service provider.

1. 9kg ABE upgrade for specific bays: Any bay renting to a customer who stores a boat with a large petrol tank (or any customer who declares bulk fuel storage) should be upgraded to a 9kg ABE. The current spec assumes the customer contact has been issued the hazardous goods declaration and that the operator upgrades the bay extinguisher on the basis of that declaration. Confirm this upgrade process is documented in the operating procedures.

---

Max Storage Ltd -- Customer Storage Licence Agreement

---

IMPORTANT: This is a first draft for Ed's review. It has not been reviewed by a solicitor. Do not use with customers until reviewed and cleared by a NZ commercial solicitor.

---

Agreement Reference: MSL-__________

Date: __________

---

Parties

Operator:

Max Storage Ltd

Te Waerenga Road, Hamurana, Rotorua

("we", "us", "the operator")

Customer:

Full legal name: ___________________________________

Physical address: ___________________________________

Email address: ___________________________________

Phone number: ___________________________________

("you", "the customer")

---

Storage Space

Bay / Space identifier: __________

Description: ___________________________________

Primary items to be stored: ___________________________________

Estimated value of goods stored: $__________

(Required for insurance and PPSR purposes -- see clause 13)

---

Agreement Summary

Note on fee increase notice: If we collect payment by direct debit, the notice period for any fee increase is 30 days (required by BECS direct debit scheme rules). If payment is by invoice, 14 days' notice applies. Ed to confirm billing method before finalising this clause.

---

Part 1 -- Nature of This Agreement

1. Licence, not a lease

1.1 This agreement grants you a licence to use the storage space identified above to store specified goods. It does not create a tenancy, lease, or any interest in land. You have no exclusive possession of any part of the property beyond the specific storage space during the term of this licence.

1.2 The storage space is located within a building owned by Douglas Enterprises Ltd and operated by Max Storage Ltd under a separate arrangement. Your agreement is with Max Storage Ltd as operator.

1.3 We retain the right to relocate your storage space on reasonable notice (minimum 14 days' written notice) if operationally necessary, provided the replacement space is of equivalent or greater size.

---

Part 2 -- Term and Fees

2. Monthly rolling term

2.1 This agreement starts on the date shown above and continues on a month-to-month basis until ended by either party in accordance with clause 3.

2.2 There is no minimum fixed term. You are not committed beyond the current month.

3. Ending this agreement

3.1 Either party may end this agreement by giving 14 days' written notice to the other party. Notice may be given by email to the address recorded in this agreement or by post to the last known address.

3.2 We may end this agreement immediately and without notice if:

(a) you store prohibited goods (see clause 7);

(b) you fail to pay fees for 21 or more consecutive days;

(c) you cause or threaten to cause damage to the property or to other customers' goods;

(d) you are convicted of an offence involving the facility or the goods stored;

(e) there is a material breach of any health and safety or environmental obligation in this agreement.

3.3 If we end this agreement under clause 3.2, access to your storage space will be cut off immediately. The notice and lien process in Part 7 then applies to your stored goods.

4. Fees and payment

4.1 The monthly storage fee is stated above, GST-inclusive. We will not charge additional fees not set out in this agreement without giving you written notice.

4.2 Payment is due on the date shown above each month. We will [invoice you by email / debit your nominated account -- Ed to confirm].

4.3 If a payment is overdue by more than 7 days, we may charge a late payment fee of $[TBD -- Ed to set] (GST-inclusive). Ed to decide whether to include a late payment fee and at what amount.

4.4 We may increase the storage fee by giving you written notice of at least [14 / 30] days (see fee increase notice in the Agreement Summary). Any increase takes effect from the date stated in the notice. If you do not wish to continue at the new fee, you may end this agreement under clause 3.1 before the increase takes effect.

4.5 If you end this agreement, fees are payable up to the end of the notice period. We will not charge fees for any period after the notice period ends, provided you have removed all goods and returned access credentials.

---

Part 3 -- Consumer and Business Declaration

5. How you are using this storage

5.1 Please tick one:

• □ Personal or household use. I am storing goods for personal, household, or non-commercial purposes (for example, a personal boat, caravan, or household items).
• □ Business use. I am acquiring this storage in the course of a business. I confirm that all parties to this agreement are in trade, and we expressly agree to contract out of the Consumer Guarantees Act 1993 in accordance with section 43(2) of that Act. I acknowledge that this means the guarantees implied by that Act do not apply to this agreement.

5.2 If you select "business use" but the goods are in fact stored for personal or household purposes, you remain entitled to the protections of the Consumer Guarantees Act 1993. We rely on your declaration in good faith.

---

Part 4 -- Health and Safety

6. Site rules and your safety obligations

6.1 By signing this agreement you confirm that you have read and understood the following site rules, which form part of this agreement:

(a) Speed and traffic:

Maximum speed on-site is 10 km/h. One-way traffic flow applies [Tom to confirm direction after Easter site visit]. Do not block the access driveway or the fire access path.

(b) Reversing:

When reversing a trailer or large vehicle, use a spotter or get out and check clearances before reversing. Do not rely solely on mirrors.

(c) No smoking or naked flames:

No smoking, vaping, or use of naked flames anywhere on the property. This includes in vehicles while the engine is running in an enclosed area.

(d) Pedestrian safety:

Walk in designated areas. Do not walk in the vehicle manoeuvring zone while vehicles are moving.

(e) Fire access path:

A minimum 4.0-metre-wide access path from the gate to the shed must be kept clear at all times. Do not park, store items, or leave trailers in this path. This is a legal requirement under the NZ Building Code (C/AS5) and must be observed at all times, including while loading and unloading.

6.2 You have obligations under the Health and Safety at Work Act 2015 (HSWA) to take reasonable care for your own safety and for the safety of others who may be affected by your actions on-site. You must not interfere with or misuse any safety equipment, signage, or emergency system on the property.

6.3 You must report any accident, near-miss, hazard, or unsafe condition to us immediately. Use the contact details at the end of this agreement.

6.4 Emergency procedure: In the event of fire, call 111 immediately and evacuate. Do not re-enter. The site address for emergency services is: Te Waerenga Road, Hamurana, Rotorua. WorkSafe NZ: 0800 030 040. Rotorua Hospital: 07 348 1199.

---

Part 5 -- Prohibited and Controlled Items

7. Prohibited items -- absolutely not permitted

7.1 The following items must not be brought onto the property or stored in your storage space under any circumstances. Breach of this clause is a material breach entitling us to immediately end this agreement and exercise our lien rights under Part 7.

Absolutely prohibited:

• Petrol or diesel in portable containers (jerry cans, fuel bladders, or any container separate from a vehicle's or boat's own built-in fuel tank)
• Standalone LPG cylinders not physically connected to a caravan's own appliances (connected cylinders with valve closed are permitted -- see clause 8)
• Agricultural chemicals, pesticides, or herbicides
• Pool chemicals, oxidisers, chlorine, bleach concentrates, or peroxides
• Fireworks, pyrotechnics, or explosives of any kind
• Asbestos-containing materials
• Radioactive materials
• Unlabelled chemicals or substances in non-original containers
• Fuel in containers with damaged or missing closures
• Electric vehicle battery systems over 10 kWh capacity (including electric boats, electric vehicles with large battery packs, and high-capacity solar storage batteries) -- prohibited at Phase 1 pending further review
• Live animals
• Food, perishable goods, or goods that may attract vermin
• Stolen goods, contraband, or illegal substances

7.2 If we have reasonable grounds to believe prohibited goods are being stored, we may enter your storage space for inspection, after giving notice where practicable. Where the risk is immediate (for example, evidence of fuel leakage or fire hazard), we may enter without prior notice. [Flag for solicitor review -- see drafting notes.]

8. Controlled items -- permitted with conditions

8.1 The following items are permitted only if the stated conditions are met. You must declare these items at sign-up (see clause 9).

8.2 You must not refuel any vehicle, boat, or trailer on the property. You must not change oil or perform any maintenance that involves draining or handling fuels or lubricants on-site.

9. Hazardous goods declaration

9.1 You must complete and sign the hazardous goods declaration below before your access code is activated. The declaration forms part of this agreement.

Hazardous goods declaration:

I declare that the goods I intend to store include the following (tick all that apply):

• □ Petrol in a boat's or vehicle's built-in fuel tank. Estimated quantity: _____ litres. Vehicle/boat make and model: _______________
• □ LPG cylinder(s) physically connected to a caravan. Number of cylinders: _____. Total estimated capacity: _____ kg.
• □ Diesel in a boat's or vehicle's built-in fuel tank. Estimated quantity: _____ litres.
• □ Lithium-ion battery system under 1 kWh. Description: _______________
• □ Lithium-ion battery system 1--10 kWh. Description: _______________
• □ None of the above.

I confirm that I have read the prohibited items list in clause 7 and that none of my goods fall within the absolutely prohibited items. I confirm that any controlled items listed above meet the conditions in clause 8.

Signed: ___________________ Date: ___________

---

Part 6 -- Privacy Notice and Consent

10. How we collect and use your personal information

10.1 What we collect. To enter this agreement, you provide us with personal information including your full name, physical address, email address, phone number, and vehicle registration(s). We also collect payment details for billing purposes. When you access the facility, our pin pad access system records your entry and exit times linked to your access code. CCTV cameras on the property record video footage.

10.2 Why we collect it. We collect and hold this information for the following purposes:

• Administering this storage agreement (billing, access code management, correspondence)
• Security of the facility and stored goods
• Recording and managing access to the facility
• Supporting any insurance claim or legal proceedings relating to goods stored at the facility
• Resource consent compliance: access logs and camera footage may be used as evidence to support an application for resource consent for the operation of this facility. You expressly consent to this use by signing this agreement.
• Debt recovery if fees are unpaid
• Compliance with our legal obligations

10.3 Who holds it. Your personal information is held by Max Storage Ltd, Te Waerenga Road, Hamurana, Rotorua. Privacy enquiries: [email/phone -- Ed to add].

10.4 Who may receive it. We may share your personal information with:

• Our insurer, in connection with any claim or risk assessment relating to the facility
• NZ Police, where legally required or where we have reasonable grounds to believe disclosure is necessary to prevent or investigate a serious offence (Privacy Act 2020, IPP 11)
• Rotorua Lakes Council, for resource consent compliance purposes (including providing access logs and camera footage summaries). Where possible we will provide anonymised or aggregated data to the Council rather than individually identifying information.
• A licensed auctioneer or debt recovery service, if it becomes necessary to enforce our lien under Part 7
• Any other party required by law

10.5 CCTV footage. CCTV cameras are in operation on this property for security purposes. Footage is retained for up to 90 days and then automatically overwritten, unless it is required for a live insurance claim, Police investigation, or Privacy Act access request, in which case it will be preserved until the matter is resolved. Signage at the site entry also gives you notice of CCTV recording.

10.6 Access log data. Entry and exit records from the pin pad are personal information. They are retained for [7 years -- consistent with overall data retention policy], and may be used for the resource consent evidence purpose described in clause 10.2.

10.7 Your rights. You have the right to access and correct the personal information we hold about you. Requests must be responded to within 20 working days. To make a request, contact us at [email/phone]. You also have the right to complain to the Privacy Commissioner at privacy.org.nz if you believe your privacy has been breached.

10.8 Provision is necessary. You cannot enter this storage agreement without providing the required personal information. Provision of the information declared above is necessary for us to administer the agreement, manage access, and comply with our legal obligations.

10.9 Electronic contracting consent. You consent to entering into this agreement electronically. An electronic signature (including ticking a box, typing your name, or replying by email to confirm acceptance) is a valid and binding signature for the purposes of this agreement and satisfies any requirement for a signature under the Contract and Commercial Law Act 2017.

---

Part 7 -- Default, Lien, and Abandoned Goods

11. Our lien over your stored goods

11.1 We have a lien over all goods you store at the facility for all amounts owing by you under this agreement, including storage fees, late payment fees, and the reasonable costs of enforcing this lien. The lien attaches from the moment your goods are brought onto the property.

11.2 While any amount is owing and unpaid, we may retain your goods and deny you access to them.

11.3 If the default and notice process in clause 12 is completed without payment, we have the power to sell or dispose of your goods as set out in clause 12. This is a contractual power of sale, not a statutory one.

12. Default and abandonment notice procedure

12.1 This clause sets out what happens if you do not pay fees when due. We will follow this process in sequence. We will not dispose of your goods without completing this process.

Day 0 -- Missed payment

We will send a courtesy reminder by email and/or SMS.

Day 7 -- First formal default notice

If payment has not been received within 7 days of the due date, we will send a written default notice to your registered email address and by post to your registered physical address. The notice will state the amount overdue, the payment deadline (14 days from the notice date), and that access may be cut off if payment is not received.

Day 21 -- Access cut-off

If the debt remains unpaid 14 days after the Day 7 notice, we will deactivate your access code. We will send a second written notice advising that access has been suspended, stating the total amount now owing, and giving you a further 14 days (to Day 35) to make payment and reinstate access.

Day 35 -- Formal abandonment notice

If the debt remains unpaid, we will send a formal abandonment and disposal notice by email and, if possible, by registered post. The notice will state that we consider the goods abandoned for the purposes of this agreement, the total amount owing, and that if payment is not received within 14 days we will sell or dispose of the goods. The notice will describe the goods and invite you to contact us to arrange payment.

If your stored goods include a boat, caravan, vehicle, or trailer, we will conduct a search of the Personal Property Securities Register (PPSR) at this stage. If a registered finance company has a security interest in your goods, we will notify them of the default and give them the opportunity to pay the operator's debt and take possession of the goods.

Day 49 -- Sale or disposal

If no payment has been received by Day 49 (14 days after the abandonment notice), we may sell or dispose of the goods. For boats, caravans, and vehicles, we will use a licensed public auctioneer wherever practicable.

12.2 Abandonment defined. For the purposes of this agreement, goods are deemed abandoned if: (a) fees remain unpaid for 35 days or more after the due date; and (b) you have not responded to our notices or made contact with us during that period. This is a deeming provision in this contract -- it does not require us to prove you intended to permanently give up ownership.

12.3 Application of sale proceeds. Proceeds from any sale will be applied in this order:

1. Costs of sale (auctioneer's fees, advertising, removal, and storage costs incurred in the process)
2. All amounts owing to us under this agreement
3. Any surplus will be held for you and paid to you on request

We will not keep any surplus beyond what is owed to us. If we cannot locate you after holding the surplus for 5 years, we may be required to deal with it under the Unclaimed Money Act 1971.

12.4 Notices deemed effective. Any notice sent to your last registered email address and last known postal address is deemed effective when sent, regardless of whether it is actually received. You are responsible for keeping your contact details current with us. Notify us promptly of any change to your email or physical address.

12.5 Costs of enforcement. If we incur reasonable legal or enforcement costs in connection with a default under this agreement, those costs may be recovered from the sale proceeds as part of the costs of sale.

---

Part 8 -- PPSR and Goods Ownership

13. PPSR acknowledgement and warranty

13.1 You warrant that you are the owner of the goods you store, or that you have the authority of the owner to store them.

13.2 You warrant that you have disclosed to us, at sign-up, all security interests registered against your goods on the Personal Property Securities Register (PPSR), including any finance company charges, hire purchase arrangements, or other encumbrances.

13.3 You acknowledge that if a security interest registered against your goods is not disclosed and we suffer loss as a result (for example, a finance company successfully claims the goods after we have sold them), you indemnify us for that loss.

13.4 We are not required to search the PPSR on your behalf at sign-up. A PPSR search will be conducted before any disposal under clause 12.

---

Part 9 -- Environmental and Spill Liability

14. Spill reporting and remediation

14.1 You must report any fuel spill, chemical spill, oil leak, or other contamination incident to us immediately on discovery. Do not attempt to clean up a spill without first calling us. Use the contact details at the end of this agreement.

14.2 Spill first response: Do not use water on a petrol spill. Use the spill kit located [near the main shed entrance -- Tom to confirm location and mark on-site]. Call Tom on [number]. If the spill has reached a drain, waterway, or soil beyond the concrete pad, call the Bay of Plenty Regional Council environmental hotline: 0800 884 880.

14.3 You are liable for all reasonable costs of remediation of any contamination caused by your goods, vehicles, or activities on the property. This includes costs incurred by us, costs required by any regulatory authority, and any fines or penalties imposed on us arising from contamination you caused.

14.4 Failure to report a spill or contamination incident immediately is a material breach of this agreement, entitling us to terminate immediately under clause 3.2.

14.5 You must not change oil, flush fuel systems, or perform any maintenance on the property that results in fuel, oil, or chemical waste being released onto the concrete pad, soil, or drainage system.

---

Part 10 -- Liability

15. Our liability to you

15.1 We will take reasonable care to maintain the facility in a safe and secure condition. This is the standard of care required of us under the Consumer Guarantees Act 1993 (guarantee of reasonable care and skill -- s 28).

15.2 We are not liable for loss of or damage to your stored goods that does not result from our negligence or failure to maintain the facility to a reasonable standard. This includes (without limitation):

• Theft by third parties where we have maintained reasonable security measures
• Damage caused by weather, flooding, or other events outside our reasonable control
• Damage caused by vermin or pests
• Damage caused by the condition of your own goods or your own packaging choices
• Loss or damage caused by your own actions or those of someone you allow access to the facility

15.3 Consumer customers. If you are storing goods for personal or household purposes (as declared in Part 3), we cannot exclude or limit our liability to you for any failure to meet the Consumer Guarantees Act 1993 guarantee of reasonable care and skill. You retain all rights under that Act. Clause 15.2 does not exclude our liability for our own negligence.

15.4 Business customers. If you have declared in Part 3 that you are acquiring storage for business purposes and have agreed to contract out of the Consumer Guarantees Act 1993 under section 43(2), our liability for loss of or damage to stored goods is limited to the declared value of the goods recorded in this agreement, or $[TBD], whichever is lower. [Ed to set the cap amount. Solicitor to review this clause for consumer-safety and proportionality.]

15.5 We are not liable for any indirect, consequential, or economic losses arising from your use of the facility (for example, loss of business use of a stored boat or caravan).

16. Your insurance obligation

16.1 You are responsible for arranging and maintaining your own insurance for the goods you store at the facility, at their full replacement value. We strongly recommend that you take out or extend an existing policy to cover goods while in storage.

16.2 We do not insure your goods. Our insurance covers our own public liability and our building and equipment -- it does not cover your stored goods.

16.3 Storing goods without insurance is at your own risk. We will not compensate you for loss or damage to uninsured goods where the loss did not arise from our negligence.

---

Part 11 -- Our Right to Enter

17. Operator access rights

17.1 We may enter your storage space in the following circumstances:

(a) Emergency: At any time and without prior notice, if there is a fire, flood, structural danger, suspected fuel or gas leak, or any other circumstance posing an immediate risk to persons or property.

(b) Routine inspection or maintenance: After giving you at least 48 hours' written notice (by email), for the purpose of inspecting the facility, carrying out maintenance, or ensuring compliance with this agreement.

(c) Suspected breach of prohibited items clause: After giving notice where it is practicable to do so, if we have reasonable grounds to believe prohibited goods are being stored. Where the suspected risk is immediate or urgent, we may enter without prior notice. [Flag for solicitor review -- see drafting notes.]

(d) Default process: As part of the notice and lien process in clause 12, once access has been cut off and the abandonment process has commenced.

17.2 We will record any entry to your storage space and notify you of the entry as soon as practicable afterwards.

---

Part 12 -- Dispute Resolution

18. Resolving disputes

18.1 If you have a complaint about our services or this agreement, please contact us first at [email/phone]. We will acknowledge your complaint within [5] working days and try to resolve it within [20] working days.

18.2 If we cannot resolve the dispute directly, either party may refer it to the Disputes Tribunal (disputes.govt.nz) for claims up to $30,000. The Disputes Tribunal is a low-cost, accessible process that does not require a lawyer.

18.3 For disputes above $30,000, the parties agree to attempt mediation before commencing proceedings in any court.

18.4 Nothing in this clause prevents you from exercising your rights under the Consumer Guarantees Act 1993 or making a complaint to the Commerce Commission (comcom.govt.nz) if you believe your consumer rights have been breached.

---

Part 13 -- General

19. Keeping contact details current

19.1 You must promptly notify us in writing of any change to your email address, physical address, or phone number. Notice given to your last registered contact details is deemed effective if your details are out of date because you failed to notify us.

20. Entire agreement

20.1 This agreement, including the hazardous goods declaration in clause 9, is the entire agreement between us about storage at this facility. Any earlier discussions, quotes, or email exchanges are superseded by this signed agreement.

21. Changes to this agreement

21.1 Changes to this agreement (other than fee increases, which are governed by clause 4.4) require the written agreement of both parties.

22. Governing law

22.1 This agreement is governed by the law of New Zealand.

---

Signatures

By signing below, each party confirms that they have read and understood this agreement, including the hazardous goods declaration, the prohibited items list, the health and safety site rules, the privacy notice, and the lien and abandonment procedure.

Customer signature:

Signed: _________________________________

Full name (print): ________________________

Date: ___________________________________

Capacity (if signing on behalf of a company):

Company name: __________________________

Authorised signatory: [ ] Yes

---

Operator signature:

Signed by Max Storage Ltd:

Signed: _________________________________

Name (print): ____________________________

Date: ___________________________________

---

Operator Contact Details

Max Storage Ltd

Tom [surname -- Ed to confirm]: [mobile number -- Ed to add]

Ed Douglas: [mobile number -- Ed to add]

Email: [email address -- Ed to add]

Site address (for emergency services only): Te Waerenga Road, Hamurana, Rotorua

---

End of Agreement

---

Insurance Options

Requirements Loaded

Financial obligations compound requirements status: EMPTY -- integration/financial-obligations.md is not yet populated. Lender-specific insurance minima (building sum insured, mortgage clause requirements) are derived from standard NZ bank practice, not the actual Douglas Enterprises loan terms. All lender figures are marked UNCONFIRMED and must be verified when the loan covenant documents are received (context/open-items.md -- waiting on Jenny).

Draft contract notes status: POPULATED (2026-04-01, v1). The "What source-insurance Should Know" section was found and has been read in full.

Tier 1 insurance requirements status: POPULATED (financial/insurance-requirements.md, 2026-03-31).

Legal-compliance compound requirements status: POPULATED (integration/legal-compliance.md, 2026-04-01).

Key constraints from contract and compound requirements:

• Max Storage Ltd is a bailee at common law for any negligence claim. The operator's public liability policy MUST cover damage to customer goods caused by operator negligence. Standard public liability policies that exclude "goods in care, custody, and control" are NOT suitable without a bailee endorsement or specialist storage policy.
• Customer goods are otherwise not covered by the operator's insurance (contract clause 16). The insurer must be notified of this arrangement and the policy must not be written on a basis that would require the operator to insure customer contents.
• EV battery systems over 10 kWh are prohibited in the contract pending insurance advice. Confirm insurer position before Phase 1 launch -- this prohibition may need to be widened or narrowed based on insurer conditions.
• CCTV retention: 90-day target adopted in the contract privacy notice (clause 10.5). Insurer minimum is 28-31 days. The 90-day figure must be confirmed as acceptable to the insurer and documented in the policy file.
• Resource consent has NOT yet been obtained. The facility is currently operating (or preparing to operate) without consent. Insurers may treat unconsented commercial use as a material non-disclosure risk -- this must be disclosed to every insurer approached. See the unconsented use section below.
• Building/material damage insurance sits with Douglas Enterprises Ltd (asset owner and borrower). Public liability and bailee liability sit with Max Storage Ltd (operator). Two separate entities require separate policies. Any coverage gap between the two must be identified and closed.
• The lender must be noted as an interested party (mortgagee/loss payee) on the Douglas Enterprises material damage policy. Exact lender requirements are UNCONFIRMED pending loan covenant documents.

---

Insurance Required

Legally Required (Mandatory Before Opening)

There is no NZ statute that specifically mandates public liability insurance for a self-storage operator. However, the following cover is effectively mandatory in practice:

Public liability (Max Storage Ltd)

Required by: best practice; likely a lender condition (UNCONFIRMED); consistent with HSWA 2015 obligations as a PCBU operating a site accessed by members of the public. No NZ storage operator should open without this cover. The cost of a single personal injury or property damage claim without insurance would likely be fatal to a business at this scale.

Material damage -- building (Douglas Enterprises Ltd)

Required by: NZ bank lending practice (UNCONFIRMED from loan docs, but standard for a $470k commercial mortgage). The lender will almost certainly require full replacement value cover as a loan condition, with the lender noted as mortgagee on the policy.

Strongly Recommended (Commercially Prudent)

Bailee liability / goods in care, custody and control (Max Storage Ltd)

Not mandated by statute, but given the nature of the goods (boats, caravans, trailers, vehicles -- typically worth $20,000-$200,000+), the operator's negligence exposure is material. A single successful negligence claim from a customer with a $100,000 boat would be commercially significant without this cover.

Statutory liability (Max Storage Ltd)

Covers fines and reparations under HSWA 2015, RMA, and Building Act. Relevant given the unattended operation model, the fire risk from boats with petrol tanks, and the BOPRC environmental reporting obligations. Recommended from Phase 1.

Business interruption (Max Storage Ltd or Douglas Enterprises Ltd -- confirm at policy placement)

The $470k interest-only loan is serviced from storage revenue. If the building is damaged and unusable for 3-6 months, the revenue gap directly threatens loan servicing. A business interruption policy covering loss of rental income is prudent from Phase 1.

Optional or Deferred

Employers liability: Not required unless Tom or other family members are on a payroll. ACC covers most workplace injury claims. Reassess if any paid employment begins.

Customer goods insurance (as a product offered to customers): Not required of the operator. See Customer Insurance Add-on Analysis section below.

---

Unconsented Use -- Disclosure Obligation

Resource consent for commercial storage on Te Waerenga Road has not yet been obtained. This is a material fact that must be disclosed to every insurer at the time of application. Failure to disclose a material fact voids an NZ insurance policy under the Insurance Law Reform Act 1977 (s5 -- utmost good faith obligation).

What this means in practice:

• Tell every insurer: "The facility is currently operating without resource consent for commercial storage. An application is in preparation."
• Ask each insurer whether unconsented use affects their willingness to cover, policy terms, or premium.
• Some insurers may decline to cover until consent is obtained. Others may cover on the basis that the insured is pursuing consent and include a condition that consent is obtained within a defined period.
• FMG, as a rural and provincial specialist, may be more familiar with situations where rural activities are operating while a consent process is underway and may be more flexible than a purely urban commercial insurer.

The consent strategy also constrains how the facility can be described to the insurer -- it should be described accurately as a rural storage facility, not as a commercial warehouse or industrial storage site, because the latter characterisations could trigger different policy classes or exclusions.

---

Options

Option A: FMG (Rural and Provincial Specialist -- Quote Pending)

Coverage summary

FMG offers a commercial product suite covering public liability, statutory liability, material damage (commercial buildings), business interruption, and life/health. A rural self-storage facility at Hamurana falls within FMG's typical rural business underwriting scope. Their rural and provincial focus may make them more comfortable with the unattended operation model and the Rotorua/Hamurana location than a purely urban commercial insurer.

FMG does not publish specific product terms or coverage limits publicly. All policy details are provided through a direct advisor relationship.

Requirements compliance (preliminary -- cannot confirm until quote is received):

Estimated annual premium: Indicative only -- NOT YET AVAILABLE. FMG quote has been requested since 2026-03-28 (open item). See FMG section below.

What the insurer requires for this policy to be valid (Phase 1 minimum -- confirm with FMG):

1. Fire extinguishers installed, certified, and placed per NZS 4503:2005 before cover begins.
2. CCTV operational at all entry and exit points with recording enabled (1080p minimum, 28-day minimum retention).
3. Access control gate operational (pin pad logging preferred).
4. All bay doors in working order and securable.
5. No known structural defects in the building.
6. Building sum insured set at full replacement value.
7. Disclosure of unconsented commercial use -- FMG must be informed before policy inception.

Customer goods add-on: FMG may offer a compatible customer goods/occupant contents product -- must be confirmed at quote stage. See questions list in FMG section.

Risks and exclusions relevant to this facility:

• Flood near Lake Rotorua: must confirm.
• Unoccupied premises clause: unattended facility is not the same as occupied -- must negotiate or confirm this is not triggered.
• EQC does not apply to commercial buildings -- earthquake cover must be in the private policy.
• Petrol in boat tanks: must confirm whether the aggregate petrol on-site (potentially beyond 50L when all bays are occupied) affects the policy conditions or requires a Location Compliance Certificate endorsement.
• Monitored alarm may be required as a condition of continued cover within a defined period post-inception -- confirm at quote stage.

---

Option B: Howden NZ (Specialist Self-Storage Programme)

Coverage summary

Howden NZ (formerly known in the NZ market as Crombie Lockwood, now part of the Howden group) operates a specialist self-storage insurance programme for the Australasian market. This programme is specifically designed for storage operators and addresses the bailee liability gap that exists in generic commercial policies.

A specialist self-storage policy through Howden NZ typically includes:

• Public and products liability (typically $5m-$20m limit options).
• Bailee or customers' goods liability -- covers the operator's legal liability for damage to customer goods caused by operator negligence. This is the critical cover that generic public liability policies often exclude.
• Commercial property / material damage for the building.
• Business interruption.
• Statutory liability (HSWA, RMA, environmental).
• Management liability (optional).
• A compatible customer contents protection product that the operator can offer customers as an opt-in (similar to the Kennards/Hollard model -- see Customer Insurance Add-on Analysis below).

Requirements compliance (indicative -- based on Howden NZ self-storage programme guidance):

Estimated annual premium: Indicative only -- A QUOTE HAS NOT YET BEEN SOUGHT. Based on comparable NZ self-storage facility sizes and publicly available benchmarks, a specialist self-storage programme for a ~360m2 facility with $5m public liability and building cover at replacement value might indicate approximately NZD $3,500-$6,000 per annum total premium. This is a rough market estimate only; the actual premium will depend on building value, goods stored, security standard, claim history, and insurer assessment. Do not rely on this estimate for financial modelling -- obtain a quote.

What the insurer requires for this policy to be valid:

Same Phase 1 minimum as Option A (fire extinguishers, CCTV, access control, sound building fabric). Specialist programmes may have specific requirements around:

• Security certification to a defined standard (ask Howden NZ whether they require or reward a formal security grading certificate).
• A signed customer agreement that includes a liability limitation clause and customer insurance requirement.
• A documented prohibited items policy.

Customer goods add-on: Highly likely available through the Howden NZ programme. The programme is typically paired with an occupant contents product (similar to Hollard's product used by Kennards) that the storage operator can offer to customers as an opt-in at sign-up. Revenue opportunity estimated at $5-$20 per customer per month depending on goods value tier. See Customer Insurance Add-on Analysis below.

Risks and exclusions:

Same general NZ commercial policy exclusions apply (flood, gradual deterioration, mechanical breakdown, unoccupied premises, intentional damage, EQC not applicable). Specialist programmes are typically more tailored but exclusions must be confirmed at quote stage.

How to approach: Contact Howden NZ's commercial insurance team and specify that you are seeking cover for a rural self-storage facility in Rotorua. Request a quote under their self-storage or specialist commercial storage programme. Ask specifically about the customer contents protection product as an add-on.

---

Option C: NZI / IAG via a Commercial Broker (General Commercial Policy)

Coverage summary

NZI (underwritten by IAG New Zealand) is the largest commercial insurer in NZ and underwrites a broad range of commercial property and liability risks. A small rural storage facility could be placed with NZI through a commercial broker. This is a less specialised route than Option B but may produce competitive pricing.

A general commercial policy through NZI would typically include:

• Material damage (commercial buildings).
• Public and products liability.
• Business interruption.
• Statutory liability (usually as a separate policy or endorsement).

Key limitation: A standard NZI commercial property and liability policy will almost certainly exclude "goods in care, custody, and control." This means bailee liability (the operator's negligence exposure for customer goods) would NOT be covered unless a specific endorsement is added. Obtaining this endorsement from a non-specialist insurer may be difficult or expensive.

Requirements compliance:

Estimated annual premium: Indicative only -- NOT YET AVAILABLE. No quote sought. A general commercial policy for a building of this size would likely be in the NZD $2,500-$4,500 range for property and liability combined, but the absence of bailee cover would leave a significant gap.

Risks and exclusions:

Same standard exclusions as noted above, plus the critical bailee/goods-in-care gap. Unless a specialist endorsement can be added, this option does not satisfy the coverage requirement identified in the contract notes ("What source-insurance Should Know" -- bailee liability must be covered).

How to approach: Engage a commercial insurance broker (e.g., Aon NZ, Marsh NZ, or a local Rotorua commercial broker) and specify the bailee liability requirement at the outset. If the broker cannot obtain a bailee endorsement from NZI, escalate to a specialist storage programme (Option B).

---

Option D: Vero NZ / Suncorp (Rural and Commercial)

Coverage summary

Vero (underwritten by Suncorp NZ) offers rural and commercial insurance and has some rural property specialisation similar to FMG, though FMG is generally considered the stronger rural specialist in the NZ market. Vero would be worth approaching if FMG declines or the FMG premium is not competitive.

Vero's rural commercial offering would cover material damage, public liability, and business interruption. The same bailee liability gap applies as with Option C unless a specialist endorsement is available.

How to approach: Contact Vero directly or via a commercial broker. Flag the rural self-storage use, the unattended operation model, and the bailee liability requirement. Vero may be able to refer internally to a specialist team if their standard rural team cannot accommodate the risk.

Estimated annual premium: Indicative only -- NOT YET AVAILABLE.

---

FMG (Pending Quote)

A quote has been requested from FMG since 2026-03-28. No response has been received as at 2026-04-01 (see context/open-items.md -- status: OPEN, being chased by Ed).

When the FMG quote arrives, the following questions must be answered before the quote can be assessed against the compound requirements:

This section will be updated when the FMG quote is received.

---

Customer Insurance Add-on Analysis

Can Max Storage Offer Customer Goods Insurance as a Service?

Yes -- this is standard NZ self-storage practice (Kennards, National Storage, and others operate this model). The legal structure determines the regulatory requirements.

Options for Offering Customer Insurance

Option 1 -- Refer without advising (lowest complexity, Phase 1)

Include a clause in the storage agreement (already in draft contract clause 16) recommending customers arrange their own insurance. Provide a reference to a suitable insurer or product (e.g., a direct link to Howden NZ's occupant contents protection product or similar). Do not recommend a specific product, amount, or insurer to any individual customer. This avoids the Financial Advice Provider (FAP) licensing requirement entirely.

No FSPR registration required. No FMA interaction required. Suitable for Phase 1 while the main insurance policy is being established.

Option 2 -- Insurance agency arrangement (recommended if add-on revenue is desired)

Enter into an agency arrangement with a specialist insurer (such as Hollard NZ, operating through Howden NZ or a similar channel). The insurer holds the product and the FAP licence; Max Storage processes opt-ins as a named agent of the insurer. This requires registration on the Financial Service Providers Register (FSPR) as an insurance intermediary -- significantly less burdensome than obtaining a full FAP licence.

This is how Kennards NZ structures their add-on insurance. The specialist self-storage insurer (Howden NZ) would be the first point of contact to enquire whether such an arrangement is available to a small NZ operator.

FSPR registration fee: small business rate. Annual FMA levy applies. Combined compliance cost estimated at under $500 per year.

Option 3 -- Full FAP licence (not recommended)

Only warranted if Max Storage intends to actively advise customers on their insurance needs. Not recommended for Phase 1 or Phase 2 given the additional compliance burden (ongoing CPD, disclosure obligations, FMA oversight).

Revenue Opportunity Estimate

At an indicative $10-$20 per month per customer for a basic contents protection product covering fire, theft, storm, and water damage to $50,000-$100,000 of stored goods, and assuming 8-12 customers take-up the product at Phase 1:

• Low estimate: 8 customers x $10/month x 12 months = $960/year gross add-on revenue
• High estimate: 12 customers x $20/month x 12 months = $2,880/year gross add-on revenue

Commission rates for insurance agents on products of this type in the NZ market typically run 15-30% of premium. The net revenue to Max Storage would be $144-$864 per year at Phase 1 scale. This is a modest but positive contribution to income at a low compliance cost under Option 2.

The revenue opportunity scales with the customer base. At a full complement of 12 bays (Phase 1) to 20+ bays (Phase 2), the add-on becomes more material.

What Must Be in the Customer Contract

The draft contract (clause 16) already includes:

• Statement that the operator's insurance does not cover customer goods.
• Requirement/recommendation that customers insure their own goods.
• Customer's acknowledgement of their insurance responsibility.

If an agency arrangement is established (Option 2), the contract must also state:

• The name of the insurer whose product is available.
• A brief product summary.
• Confirmation that acceptance of the add-on is opt-in (not mandatory and not automatic).
• That declining the add-on means the customer assumes all risk of loss or damage to their goods.

The current draft contract wording in clause 16 satisfies Phase 1 (Option 1 referral model). If Max Storage moves to Option 2, a contract clause amendment will be needed.

---

Open Questions