Regulatory Matters

As an Authorised Advisor, the firm is authorised to provide broad based investment advice and receive and transmit order in respect of:

• UCITS (Undertakings for Collective Investment in Transferrable Securities)
• Tracker Bonds
• Insurance Policies (including unit linked investments, pensions, life assurance, income protection insurance, specified illness insurance and savings contracts)
• Personal Retirement Savings Accounts (PRSAs)
• Listed Shares and Bonds

The firm is also authorised to act as a deposit broker and to give advice in respect of deposits.

As a broker, we provide a fair and personal analysis of the market in relation to the life assurance, specified illness, income protection, investment, pensions and bank deposits. This means we will research the market place and recommend the best products to suit your needs.

We offer impartial financial advice on a fee basis in respect of lifestyle financial planning, investment and retirement planning

In addition to these regulated activities, Signature Financial Planning provides services in the area of financial planning, which is a financial service that is not regulated by the Central Bank of Ireland and for which specific fees will be quoted in advance of any work undertaken.

Signature Financial Planning Ltd is subject to and complies with the Consumer Protection Code, Minimum Competency Code and the Fitness and Probity Standards as laid down by the Central Bank of Ireland and which offers protection to consumers. The codes can be found on the Central Bank’s website www.centralbank.ie.

Signature Financial Planning Ltd does not hold a shareholding in an insurance undertaking and likewise, no insurance undertaking has a shareholding in our firm.

Consumer Protection

The firm is a member of the Investor Compensation Scheme established under the Investor Compensation Act, 1998. This legislation provides for the establishment of a compensation scheme and to the payment, in certain circumstances, of compensation to clients of firms covered by the Act. However, you should be aware that a right to compensation will only arise in respect of regulated products which the firm is authorised to advise on and deal in and where money or investment instruments arranged by this firm on your behalf cannot be returned either for the time being or in the foreseeable future and where the client fails within the definition of eligible investor as set out in the Act. In the event that a right to compensation is established, the amount payable is the less of 90% of your loss which is recognised as being eligible for the compensation or €20,000. Your legal rights against the firm are not affected by this scheme.

Signature Financial Planning Ltd also holds Professional Indemnity Insurance to the value of €1,500,000 as it required to do under the European Union Insurance Mediation Directive (2002/92/EC).

Conflicts of Interest and Complaints

This firm does not have any “tied” relationships with any institution that would compromise our ability to offer you an unbiased advice and choice. It is the policy of the firm to avoid any conflicts of interest when providing business services to its clients. However, where an unavoidable conflict may arise, we will advise you in writing before providing any such service. If you have not been advised of any conflict you may assume that none arises. A full copy of our conflicts of interest policy is available on request.

The firm has written procedures in place for effective consideration and handling of complaints. A copy of our full complaint procedure is available on request. The procedure ensures that complaints will be recorded and acknowledged in writing within 5 business days. Any complaints that you may have should be addressed to the Compliance Officer, Signature Financial Planning Ltd, Unit E7, Calmount Business Park, Ballymount, Dublin 12. All complaints will be fully investigated and the outcome of the investigation will be communicated to the complainant.

In the event of the complainant remaining dissatisfied with the firm’s handling of and response to a complaint you may make a complaint to the Financial Services and Pensions Ombudsman:

The office of the Financial Services and Pensions Ombudsman can be contacted at:

Lincoln Place
Dublin 2

Lo call: 1890882090
Tel: 01 6620899
Fax: 01 6620890
Email: enquiries@financialombudsman.ie

Knowing Your Client and Suitability Statement

Our services and advice are highly dependent upon our knowledge of your financial circumstances and, to this end, we will require you to complete a pre-meeting questionnaire or provide us with sufficiently adequate third-party documentation to enable us to obtain the relevant information. In the event that you fail to provide us with sufficient information in respect of either your overall personal circumstances or for a specific transaction, we are required under the Consumer Protection Code 2012 not to act you in such matters.

The suitability of all financial products depends on many factors and Signature Financial Planning Ltd undertakes to use its experience and expertise in considering all relevant factors before recommending to any party the purchase of any products.

Before purchasing any product, you will be advised of such suitability and then given a statement of why, in our opinion, such product is suitable for your needs. All advice given will be based on our understanding of current law and Revenue Commissioner practice. It may be that subsequent changes might affect the validity of recommendations that may have been made and the use of any such product might need to be reviewed as a result.

Ongoing suitability assessments will form part of the service to clients whose investments come under the remit of the MiFID Regulations 2017 and the Insurance Distribution Regulation 2018. Where your investment falls under these regulations we will provide you, on an annual basis, with a client report summarising how the product continues to meet your investment needs and objectives and your risk profile or not as the case may be

Handling Client’s Money

We do not operate bank accounts specifically for client monies. Other than fees due to the firm, Signature Financial Planning Ltd will only accept payments by cheque or banker’s draft where the payment is made out to the financial institution.

Receipts

Signature Financial Planning Ltd will issue a receipt for each non-negotiable or negotiable instrument or payment received. This is pursuant to Section 30 of the “Investment Intermediaries Act, 1995”. These are issued with your protection in mind and should be stored safely.

Anti-Money Laundering Requirements

As with other professional services firms, we are under the stringent requirements to identify our clients for the purposes of anti-money laundering legislation. We are required to request from you, and retain, some information and documentation for these purposes. If satisfactory evidence is not provided within a reasonable time, there may be circumstances in which we may not be able to proceed with your business transaction.

The provision of investment services is regulated under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 and, as such, directors and staff in Investment Intermediary firms are required to report all knowledge or suspicion or reasonable grounds to know or suspect that a criminal offence giving rise to any direct or indirect benefit from criminal conduct has been committed, regardless of whether that offence had been committed, or have reasonable grounds to know or suspect that such offences have been committed we are required by law to make a report to An Garda Siochana and Revenue Commissions. In such circumstances, we are prohibited from discussing such reports with you of same, such prohibition arising from restrictions imposed by the “tipping off” provisions of the anti-money laundering legislation.

Clients Duty of Disclosure to Insurers and Duty of Utmost Good Faith and The Responsibility of Clients

The law in the Republic of Ireland deems insurance to be a special class of conduct which imposes onerous duties upon prospective Insurers and their agents, who are obliged to act with utmost good faith towards Insurers at all times. In addition, they are obliged to disclose to Insurers, before the contract is concluded, all material information that is known to them. This obligation of disclosure extends to those matters of which they ought to be aware in the ordinary course of their business.

If there is a breach of these duties, the Insurers will be entitled to cancel the policy of insurance from inception, if the breach induced the making of the contract on the relevant terms, as well as seeking the recovery of all claims already paid under the policy. These duties of utmost good faith and disclosure also apply to the claims process. In completing a proposal form, or other documentation relating to an insurance policy, the accuracy of all answers, statements and/ or information is the Insured’s sole responsibility.

Remuneration Policy

Signature Financial Planning Ltd is a financial planning business which is remunerated by fees and/or commissions. We will offer you the option to pay by means of a fee or commission in respect of advice for investments and pensions. With regard to protection products for life assurance, specified illness protection and income protection, we are remunerated based on commission payable by the product producer.

Fees are charged on a time spent and disbursements basis, but specific fees for a project or process may be quoted for particular circumstances. Other than these said projects or processes, our current basic hourly rate is €250 + VAT @ 23%. In determining the rate, any additional charges factors such as specialist skills, complexity, value, risk and urgency will be taken into account. The rate of fees may be increased over time. In the event of a client defaulting on any payment of fees, the firm will, if necessary exercise its legal rights to recover such monies due. Fees may be charged for advice given irrespective of whether a product purchase is initiated by the client.

Where no explicit fee is charged to you, we are usually remunerated directly by the provider concerned – this may result in a reduced investment allocation rate or a higher management charge. In all instances we strive to keep our charges competitive and appropriate to your personal circumstances. Where we put in place a financial product with a financial institution that generates a payment to us by commission or other payments summary details of such receipts will be included in a product disclosure document, if completed and, if

applicable, full details will be provided to you with your contract document. Where the firm receives override, renewal or trail commission from product providers, these contribute to the costs of our ongoing administration and consulting services which we provide to you. Should you require us to work on a fee basis, we will not undertake any work until fees are specified and agreed in advance.

Termination of Relationship and Outstanding Fees

You or we may terminate our authority to act on your behalf with immediate effect at any time, but the termination must be communicated in writing and cannot be backdated. The termination will be without prejudice to the completion of any transactions already initiated and you will remain responsible for the payment of any fees and expenses incurred up to the date of termination, or the date of compensation of any transactions in progress, whichever is the later.

In the event that a product arranged on your behalf is redeemed which results with Signature Financial Planning Ltd being required to refund commissions received, we reserve the right to charge you a fee for services provided up to the amount of commission refunded.

Cancellation/Cooling Off Period

A consumer has the right to withdraw from a life assurance company product (covering protection, pensions or investments) without giving any reason, within 30 days of the start date of the policy – this is known as the “Cooling-off Period”. This right of withdrawal may be exercised by notice in writing to the relevant life assurance company quoting your policy number

Data Protection

We operate to the highest standards of client confidentiality and meet statutory requirements under the Data Protection Acts 1998 to 2018, and the European Union’s General Data Protection Regulation effective from 25th May 2018.

Our staff and support service providers will use your personal information to offer advice on suitable products, service your business on an ongoing basis, monitor services for quality control purposes, or as otherwise required by law. For these purposes we may share your contact details and other relevant information with product providers and our support service providers, for the purposes of providing you with appropriate advice.

We would also like to offer you products and services which we think may be of interest to you. In order to do so, we would like your consent so that we may contact you by letter, email, SMS text, or telephone (mobile and landline). You have the right to ask us not to send marketing information to you at any time.

Full details of our Data Privacy Notice – Customer Summary is available on request or on our website www.signaturefinancial.ie

Insurer or Investment Company Security and Investment Risk Warning

Signature Financial Planning Ltd seeks insurance and investment contracts for our clients from Financial Institutions that are regulated by the Central Bank of Ireland or other EU regulators. However, we cannot and do not guarantee the current solvency or continuing solvency of any institution used and clients should note that the financial position of an Institution could change after insurance cover or investments have been incepted.

We also ensure that any investments made by clients acting on our advice are structured bearing their personal needs and circumstances in mind. Nevertheless it is important that you, as a client who may receive such investment advice, acknowledge that all investments as well as financial products such as cash deposits carry at least some element of risk, either by way of systemic or specific market risk or through the failure of a financial institution to fulfil its commitments to holders of products, such as but not limited to, deposit accounts or tracker bonds.

In addition, the past performance of a particular investment market or a particular investment product should not be interpreted as an indicator of future investment performance as investment markets, especially over the short term, can fall as well as rise.

Governing Law and Business Succession

These Terms of Business shall be governed by and constructed in all aspects according to the laws of the Republic of Ireland and are valid from 1^st April 2012 until further notice and will be deemed to cover any successors in business to Signature Financial Planning Ltd. This Terms of Business supersedes with immediate effect any others that may have been previously to you.