Common use of Client Money Clause in Contracts

Client Money. We, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client money.

Client Money. We40.1 Any money received by us in respect of your account with us shall be treated as Client Money except where you separately agree with us to transfer full ownership of money to us for, amongst other things, the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, in which circumstances such money will not be regarded as Client Money. 40.2 In relation to Client Money unless you notify us in writing, or otherwise, we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the course of carrying money held in Client Money bank accounts and by entering into these Terms you acknowledge that you waive any entitlement to interest on insurance distributionsuch money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, handle client money care and diligence, in accordance with the FCA Client Assets Sourcebook CMA Regulations when selecting which third party bank to use. We will periodically (CASSat least annually) rules, which are designed to protect You. A copy review the adequacy and appropriateness of any bank where your money is or may be deposited and of the CASS rules is available on requestarrangements for holding your money, in accordance with the CMA Regulations. We handle client money in either one will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the following ways, both third-party bank or for any resulting shortfall or loss in the return of which are described in more detail below:your money. i. it is held on Your behalf in 40.4 The Client Money account will be a segregated bank pooled account that is subject and holds the Client Money relating to a non-statutory trust; or iinumber of clients. it is Claimants to money held by Us as agent in pooled accounts have a claim to a rateable proportion of the relevant insurer money held in that pool. 40.5 We may pass money received from you to a third party (“e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) in respect of a transaction. 40.6 Although we will remain responsible for money received from you even if we pass it to a third party, you may be exposed to the additional risk transfer”). The aim of the trust is to protect You that, in the event of Our financial failurean insolvency or similar in relation to that third party, or the failure amount of money received by us from the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able sufficient to make claims on client moneysatisfy your claims. We may transfer any money we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) to another legal entity (including any of our Group Companies), as such money will not form where we transfer all or part of Our (or our business to that entity and your Client Money relates to the bank’s or third party’s) propertybusiness transferred. The fact Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that We will hold money on trust gives rise to fiduciary duties which such Client Money will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent of a relevant insurer that entity for you in accordance with a written agreement with that insurer. The written agreement will specify the extent CMA Regulations. 40.7 You consent to which risk transfer will apply us releasing any Client Money balances, for or on your behalf, from Client Money bank accounts and whether it includes all items of money or is restricted for example, us to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that treat as Client Money any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstancesunclaimed Client Money balance where: i. when We actually receive the premium as cleared funds from You 40.7.1 we have determined that there has been no movement on your balance for a period of two years (notwithstanding any payments or from a third-party premium finance provider on Your behalfreceipts of charges, interest or similar items); and ii. 40.7.2 we have written to you at the point at which the commission becomes due your last known address and payable on a regular basis informing you of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premiummake a claim, provided this is consistent with the terms we shall make and retain records of business all balances released from our Client Money bank accounts in respect of the insurer your Client Money and undertake to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneymake good any valid claims against any released balances.

Client Money. We, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as an agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. Client money is kept separate from Our own money. Client money will be deposited into a client bank account with an authorised UK clearing bank. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- non-statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account account, provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point point, commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client money.

Client Money. We, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rulesCentral Bank of Ireland’s Premium Handling Rules, which are designed to protect You. A copy of the CASS these rules is available on request. We handle client money will accept payments in either one cash, by cheque, credit / debit cards or electronic bank transfer in respect of the following ways, both all classes of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). The aim of the trust is to protect You insurance in the event of Our financial failure, circumstances permitted under our regulatory authorisations. We are not authorised to accept cash or the failure of the bank or a third party at which the money may be heldnegotiable instruments in any other circumstances. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on Risk transfer When handling client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise we are required by law to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us act as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify for the extent to which Insurer, i.e., risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiumsapplies. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. Any Segregation of bank accounts Client money is kept separate from Our own money. Client money will be deposited into a designated ‘Client Premium Account’, any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Commission Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. Payment to third parties We may transfer client money to another person, such as another intermediary, in this or in another jurisdiction for the purpose of effecting a transaction through that person. Premium rebate We will refund any rebate that becomes due to Consumers within 5 business days of receiving it or having been notified by the insurer that it is due to You. Any rebate due to You will be paid in full and any charges will not be deducted without Your prior written agreement in each case. Where We transfer client money that the premium rebate is subject €10 or less we will offer You the choice of (a) receiving the premium rebate (b) receiving a reduction from a renewal premium or other premium currently due to us or (c) making a donation of the rebate amount to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneyregistered charity.

Client Money. We, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as an agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. with an authorised UK clearing bank. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- non-statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-third party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client money.

Client Money. WeA CLIENT ACCOUNT • We will only accept or hold money in our client account if payment is made to us for a specific purpose relating to the matter with which we are dealing, such as a deposit for a property purchase or money on account of costs. Any money we have to pay back will only be paid to the person from whom we received it or to the bank account from which it was sent and payments will not be made in cash. No money may be paid into our client account without the course express consent of carrying on insurance distributionthe lawyer acting for you. • If we retain no more than £10.00 of your money in our client account at the end of your matter and we wish to return it to you, handle but having made reasonable attempts to ascertain where you live, they remain unknown and the further costs of finding where you live would be excessive in relation to the amount we hold we shall pay the money we retain, instead, to a charity of our choosing. If the sum we hold is between £10.01 and £25.00 and we have sent a client account cheque for that amount to you at your last known address and the cheque remains unpresented after 6 months, the cheque will be cancelled and the balance paid over to a charity of our choosing. • We hold client money in accordance Handelsbanken Plc who are regulated by the Financial Conduct Authority (FCA). We are not liable for any losses you might suffer as a result of the bank institution being unable to repay deposits in full. When a banking institution is unable or likely to be unable to meet a claim against it, you may be protected by the Financial Services Compensation Scheme (FSCS), which in qualifying circumstances can pay compensation. The limit of compensation is £85,000 per banking institution and therefore if you hold other personal money in Handelsbanken, the limit remains £85,000 including funds held in our client account and funds held in those banks personally by you. You should check with your banking institution, the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect Youor a Financial Advisor for more information. A copy of In the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the unlikely event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstancedeposit taking institution, Our general creditors we will assume (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit unless we hear from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent of a relevant insurer you in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, writing to the receipt of premiums. Where risk transfer applies, You will be protected contrary) that we have your implied consent to disclose your details to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneyFSCS.

Client Money. We7.1. If we hold money on a client’s behalf, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is will be held on Your behalf in a segregated bank account trust fund that is subject separate from our own cash assets. These separate trust fund arrangements are commonly known as “client money”. If we were ever unable to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer pay our debts, then those to whom we owe money (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third partyour creditors) should not be able to make claims on our client money, money in the separate trust funds as such money will it does not form part of Our (or the bank’s or third party’s) propertyour own cash assets. 7.2. The fact trust arrangement we use for client money is known as a non−statutory trust. Here, we may use premiums and claims monies we receive to cross−fund clients’ premiums and claims; for example we may pay a premium on to an insurer before we have received it from the client if we believe it is in the best interests of that client. 7.3. We have agreements with some insurers (known as “risk transfer agreements”). Under these risk transfer agreements the insurers agree that they are responsible to you for any premium that you have already paid to us and that they remain responsible for any premium refunds or claims payments until the premium refund or claim payment is received by you. In this case we may hold client money due to or from the insurers in the same trust fund. 7.4. Where we do not have risk transfer agreements in place with insurers the client money we hold will still be protected within the non−statutory trust but will be known as “non risk transfer” client money. Non risk transfer clients have priority over insurers to the money in the trust fund as insurers granting risk transfer have agreed to subordinate their interests in the trust to those of ▇▇▇▇▇ Commercial’s non risk transfer clients. 7.5. We do not use client money to pay ourselves commission before we receive your premium. 7.6. When we hold client money on trust for you this gives rise to fiduciary duties which upon us that will not be owed to You discharged until the client money reaches is deemed to have reached the insurerinsurer or product provider (as detailed above, at which time Our this is when we receive premium in the case of risk transfer agreements). 7.7. Without affecting our fiduciary duties with regard to Your money will cease. By holding you, in some cases we may: • hold client money in accounts which are outside of the United Kingdom and which may be subject to a non-statutory trust, We are entitled to different legal and regulatory conditions and may make advances treat money differently in the event of credit from a bank failing. If you are a consumer (a person who buys products or services for personal use and not for business purposes) you can ask us not to put your client money in an account in a particular country. • pass client money to another intermediary, including ones outside of the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims United Kingdom where different legal and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies regulatory conditions apply and where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will may be treated as received by You only when they differently in the event of an intermediary failing. If you are actually paid a consumer, you can ask us not to Youpass your money to an intermediary outside of the United Kingdom or in a particular country. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also • arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated certain investments with a value at least equivalent equal to the money that would otherwise have been paid into a separate client bank account. If We we do this, We we will be responsible for meeting any shortfall in Our the client money resource which funds if the shortfall is attributable due to falls a reduction in the market value of a segregated investmentthose investments. 7.8. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trustIf, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds process of handling client money, we earn interest or benefit from You (investment income or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission foreign exchange rate movements, we will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, keep any such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneyamounts.

Client Money. We, in 7.1. Client money is money that we receive and hold on behalf of our clients over the course of carrying our relationship such as premium payments, premium refunds and claim payments. We hold this either on insurance distribution, handle client money your behalf or on behalf of your insurer(s) as determined by the agreement we have in accordance place with each insurer. 7.2. In most cases we will have an agreement with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us insurers where we act as agent of for the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the and any money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which received by us will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having if it has been received by the insurer when they are and the insurer will bear the risk of any losses in the event that our firm becomes insolvent. In the same way, we may also have an agreement with the insurer that any claims money or premium refunds received by Us. Where us from the agreement extends to premium refunds and/or claims, any premium refunds or claims insurer will not be treated as received by You only when you until they are actually paid over to Youyou. Any interest earned on We may hold both insurer and client money in the same bank account, but when this happens insurers will have previously agreed that is subject to any claim by you on monies that are client money will come before their claim. 7.3. In cases where we do not have such an agreement with an insurer we will hold your money in either a statutory or a non-statutory trust client money bank account. These accounts are governed by rules that seek to protect clients against any inability of an insurance broker to transfer premiums to an insurer, or to transfer refunds and/or claims money to a client. 7.4. The terms of a non-statutory trust account allow us to use the money held in trust on behalf of one client to pay another client’s premium before it is received from that client and to pay premium refunds or claims before we receive payment from the insurer. This is in line with standard industry practice and we are not permitted to use client money for any other purpose. If you do not wish us to hold your money in a non-statutory trust account, please let us know. 7.5. Any commission due to us may be taken from the client money account and this may be taken before we pass the premium onto the insurer. If we earn interest on any money held in this account this will be retained by Usus and not passed on to you. 7.6. We may also arrange need to hold client moneytransfer money to an affiliate, where this is required, you authorise us to do so. If we use a third party to place your insurance we may need to transfer your money to that party but we still remain responsible for your money until it is subject deemed to be received by the insurer. In some cases this may mean that your money is transferred to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to third party outside of the money that would otherwise have been paid into a client bank accountUK where the legal and regulatory systems are different. If We such a third party fails, your money may be treated differently than it would had the third party been in the UK. 7.7. If you do thisnot want your money to be passed outside of the UK or if you have any other objections to this section, We please contact us immediately. If we do not hear from you we will be responsible for meeting any shortfall in Our assume you consent to us handling client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneyway.

Client Money. We, in the course of carrying on insurance distributionmediation, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is are available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). ) The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Usinsurer. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. with an authorised UK clearing bank. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client money.

Client Money. We7.1. If we hold money on a client’s behalf, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is will be held on Your behalf in a segregated bank account trust fund that is subject separate from our own cash assets. These separate trust fund arrangements are commonly known as “client money”. If we were ever unable to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer pay our debts, then those to whom we owe money (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third partyour creditors) should not be able to make claims on our client money, money in the separate trust funds as such money will it does not form part of Our (or the bank’s or third party’s) propertyour own cash assets. 7.2. The fact trust arrangement we use for client money is known as a non-statutory trust. Here, we may use premiums and claims monies we receive to cross-fund clients’ premiums and claims; for example we may pay a premium on to an insurer before we have received it from the client if we believe it is in the best interests of that client. 7.3. We have agreements with some insurers (known as “risk transfer agreements”). Under these risk transfer agreements the insurers agree that they are responsible to you for any premium that you have already paid to us and that they remain responsible for any premium refunds or claims payments until the premium refund or claim payment is received by you. In this case we may hold client money due to or from the insurers in the same trust fund. 7.4. Where we do not have risk transfer agreements in place with insurers the client money we hold will still be protected within the non-statutory trust but will be known as “non risk transfer” client money. Non risk transfer clients have priority over insurers to the money in the trust fund as insurers granting risk transfer have agreed to subordinate their interests in the trust to those of Marsh Commercial’s non risk transfer clients. 7.5. We do not use client money to pay ourselves commission before we receive your premium. 7.6. When we hold client money on trust for you this gives rise to fiduciary duties which upon us that will not be owed to You discharged until the client money reaches is deemed to have reached the insurerinsurer or product provider (as detailed above, at which time Our this is when we receive premium in the case of risk transfer agreements). 7.7. Without affecting our fiduciary duties with regard to Your money will cease. By holding you, in some cases we may:  hold client money in accounts which are outside of the United Kingdom and which may be subject to a non-statutory trust, We are entitled to different legal and regulatory conditions and may make advances treat money differently in the event of credit from a bank failing. If you are a consumer (a person who buys products or services for personal use and not for business purposes) you can ask us not to put your client money in an account in a particular country.  pass client money to another intermediary, including ones outside of the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims United Kingdom where different legal and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies regulatory conditions apply and where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will may be treated as received by You only when they differently in the event of an intermediary failing. If you are actually paid a consumer, you can ask us not to Youpass your money to an intermediary outside of the United Kingdom or in a particular country. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also  arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated certain investments with a value at least equivalent equal to the money that would otherwise have been paid into a separate client bank account. If We we do this, We we will be responsible for meeting any shortfall in Our the client money resource which funds if the shortfall is attributable due to falls a reduction in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneythose investments.

Client Money. We, in In the course of carrying on insurance distributiondistribution activities, We do not handle client money money. This will be handled on Our behalf by UKGlobal Broking Group Limited (‘We’, ‘Our’, ‘Us’ for the remainder of this clause only) in accordance with the FCA FCA’s Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS these rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it It is held on Your behalf in a segregated bank account that is subject to a non-statutory non‐statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory non‐statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Usinsurer. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. Client money is kept separate from Our own money. Client money will be deposited into a client bank account with an authorised UK clearing bank. Any interest earned on client money that is subject to a non-statutory non‐statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client money.

Client Money. We, in 7.1. Client money is money that we receive and hold on behalf of our clients over the course of carrying our relationship such as premium payments, premium refunds and claim payments. We hold this either on insurance distribution, handle client money your behalf or on behalf of your insurer(s) as determined by the agreement we have in accordance place with each insurer. 7.2. In most cases we will have an agreement with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us insurers where we act as agent of for the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the and any money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which received by us will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having if it has been received by the insurer when they are and the insurer will bear the risk of any losses in the event that our firm becomes insolvent. In the same way, we may also have an agreement with the insurer that any claims money or premium refunds received by Us. Where us from the agreement extends to premium refunds and/or claims, any premium refunds or claims insurer will not be treated as received by You only when you until they are actually paid over to Youyou. Any interest earned on We may hold both insurer and client money in the same bank account but when this happens insurers will have previously agreed that is subject any claim by you on monies that are client money will come before their claim. 7.3. In cases where we do not have such an agreement with an insurer, we will hold your money in either a statutory or a non- statutory trust client money bank account. These accounts are governed by rules that seek to protect clients against any inability of an insurance broker to transfer premiums to an insurer, or to transfer refunds and/or claims money to a client. 7.4. The terms of a non-statutory trust account allow us to use the money held in trust on behalf of one client to pay another client’s premium before it is received from that client and to pay premium refunds or claims before we receive payment from the insurer. This is in line with standard industry practice and we are not permitted to use client money for any other purpose. If you do not wish us to hold your money in a non- statutory trust account, please let us know. 7.5. Any commission due to us may be taken from the client money account and this may be taken before we pass the premium onto the insurer. If we earn interest on any money held in this account this will be retained by Usus and not passed on to you. 7.6. We may also arrange need to hold client moneytransfer money to an affiliate, where this is required, you authorise us to do so. If we use a third party to place your insurance we may need to transfer your money to that party but we still remain responsible for your money until it is subject deemed to be received by the insurer. In some cases this may mean that your money is transferred to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to third party outside of the money that would otherwise have been paid into a client bank accountUK where the legal and regulatory systems are different. If We such a third party fails, your money may be treated differently than it would, had the third party been in the UK. 7.7. If you do thisnot want your money to be passed outside of the UK or if you have any other objections to this section, We please contact us immediately. If we do not hear from you we will be responsible for meeting any shortfall in Our assume you consent to us handling client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneyway.

Client Money. We, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. with an authorised UK clearing bank. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- non-statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-third party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client money.

Client Money. We9.1 It is a condition of these Terms and Conditions of Business that we are entitled to ask you to let us have money on account of costs to be incurred for both our fees and other disbursements. 9.2 Money held by us for you, whether on account or otherwise, will be held in a separate client bank account and administered according to the course SRA Accounts Rules. You may be entitled to interest, details of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client In order to comply with our money in either one of the following wayslaundering obligations, both of which are described in more detail below: i. it is held on Your behalf in where a segregated bank account that is subject to a non-statutory trust; or ii. it is transaction does not complete we will repay monies held by Us as agent of us, for you, to you alone and not to any third party on your behalf unless we are satisfied with the relevant insurer (“risk transfer”). The aim of the trust is reasons for paying to protect You in the event of Our financial failure, or the failure of the bank or a third party at which and have satisfactory ID required under Anti-Money Laundering rules. 9.3 As required by the SRA Accounts Rules, money may held by us will be held. In such a circumstance, Our general creditors (taken in payment or those part payment of our bills within 14 days of the bank or third party) should not be able to make claims on client moneydate of the bill, as such money will not form part of Our (or the bank’s or third party’s) property. The fact unless that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent for any other purpose. 9.4 We do not accept any payments in cash. If you deposit cash direct with our bank we reserve the right to charge for any additional anti- money laundering checks we deem necessary regarding the source of the funds and allocating funds to your ledger. 9.5 Where we make a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items payment of money to you or to another person on your behalf, it will usually be by cheque sent in the ordinary post or an electronic funds transfer e.g. via the clearing house automated payment system (CHAPS). Whichever payment method is restricted used we do not accept any responsibility or liability for exampleany losses arising in respect of any interception delays, appropriation, misuse or delay in receipt or loss resulting from changes in foreign exchange rates. As a security measure and for your protection we ask that you tell us the payee’s bank account number in addition to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that payee’s name for inclusion in any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank accountcheque. If We do thisyou want us to send you funds through the CHAPS/BACS system or by telegraphic transfer, We will be responsible we suggest you fax the bank details rather than sending to us by email for meeting any shortfall in Our client money resource which is attributable to falls in the market value security reasons using our Return of a segregated investment. Any investment returns on any segregated designated investments will be retained Funds form duly signed by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneyyou.

Client Money. We7.1. If we hold money on a client’s behalf, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is will be held on Your behalf in a segregated bank account trust fund that is subject separate from our own cash assets. These separate trust fund arrangements are commonly known as “client money”. If we were ever unable to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer pay our debts, then those to whom we owe money (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third partyour creditors) should not be able to make claims on our client money, money in the separate trust funds as such money will it does not form part of Our (or the bank’s or third party’s) propertyour own cash assets. 7.2. The fact trust arrangement we use for client money is known as a non-statutory trust. Here, we may use premiums and claims monies we receive to cross-fund clients’ premiums and claims; for example we may pay a premium on to an insurer before we have received it from the client if we believe it is in the best interests of that client. 7.3. We have agreements with some insurers (known as “risk transfer agreements”). Under these risk transfer agreements the insurers agree that they are responsible to you for any premium that you have already paid to us and that they remain responsible for any premium refunds or claims payments until the premium refund or claim payment is received by you. In this case we may hold client money due to or from the insurers in the same trust fund. 7.4. Where we do not have risk transfer agreements in place with insurers the client money we hold will still be protected within the non-statutory trust but will be known as “non risk transfer” client money. Non risk transfer clients have priority over insurers to the money in the trust fund as insurers granting risk transfer have agreed to subordinate their interests in the trust to those of Jelf Insurance Brokers Limited’s non risk transfer clients. 7.5. We do not use client money to pay ourselves commission before we receive your premium. 7.6. When we hold client money on trust for you this gives rise to fiduciary duties which upon us that will not be owed to You discharged until the client money reaches is deemed to have reached the insurerinsurer or product provider (as detailed above, at which time Our this is when we receive premium in the case of risk transfer agreements). 7.7. Without affecting our fiduciary duties with regard to Your money will cease. By holding you, in some cases we may:  hold client money in accounts which are outside of the United Kingdom and which may be subject to a non-statutory trust, We are entitled to different legal and regulatory conditions and may make advances treat money differently in the event of credit from a bank failing. If you are a consumer (a person who buys products or services for personal use and not for business purposes) you can ask us not to put your client money in an account in a particular country.  pass client money to another intermediary, including ones outside of the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims United Kingdom where different legal and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies regulatory conditions apply and where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will may be treated as received by You only when they differently in the event of an intermediary failing. If you are actually paid a consumer, you can ask us not to Youpass your money to an intermediary outside of the United Kingdom or in a particular country. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also  arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated certain investments with a value at least equivalent equal to the money that would otherwise have been paid into a separate client bank account. If We we do this, We we will be responsible for meeting any shortfall in Our the client money resource which funds if the shortfall is attributable due to falls a reduction in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneythose investments.

Client Money. We9.1 It is a condition of these Terms and Conditions of Business that we are entitled to ask you to let us have money on account of costs to be incurred for both our fees and other disbursements. 9.2 Money held by us for you, whether on account or otherwise, will be held in a separate client bank account and administered according to the course SRA Accounts Rules. You may be entitled to interest, details of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client In order to comply with our money in either one of the following wayslaundering obligations, both of which are described in more detail below: i. it is held on Your behalf in where a segregated bank account that is subject to a non-statutory trust; or ii. it is transaction does not complete we will repay monies held by Us as agent of us, for you, to you alone and not to any third party on your behalf unless we are satisfied with the relevant insurer (“risk transfer”). The aim of the trust is reasons for paying to protect You in the event of Our financial failure, or the failure of the bank or a third party at which and have satisfactory ID required under Anti-Money Laundering rules. 9.3 As required by the SRA Accounts Rules, money may held by us will be held. In such a circumstance, Our general creditors (taken in payment or those part payment of our bills within 14 days of the bank or third party) should not be able to make claims on client moneydate of the bill, as such money will not form part of Our (or the bank’s or third party’s) property. The fact unless that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent for any other purpose. 9.4 We do not accept any payments in cash. If you deposit cash direct with our bank we reserve the right to charge for any additional anti-money laundering checks we deem necessary regarding the source of the funds and allocating funds to your ledger. 9.5 Where we make a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items payment of money to you or to another person on your behalf, it will usually be by cheque sent in the ordinary post or an electronic funds transfer e.g. via the clearing house automated payment system (CHAPS). Whichever payment method is restricted used we do not accept any responsibility or liability for exampleany losses arising in respect of any interception delays, appropriation, misuse or delay in receipt or loss resulting from changes in foreign exchange rates. As a security measure and for your protection we ask that you tell us the payee’s bank account number in addition to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that payee’s name for inclusion in any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank accountcheque. If We do thisyou want us to send you funds through the CHAPS/BACS system or by telegraphic transfer, We will be responsible we suggest you fax the bank details rather than sending to us by email for meeting any shortfall in Our client money resource which is attributable to falls in the market value security reasons using our Return of a segregated investment. Any investment returns on any segregated designated investments will be retained Funds form duly signed by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneyyou.

Client Money. We, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is are available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as the agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. with an authorised UK clearing bank. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- non-statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on in a non- non-statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-third party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client money.

Client Money. We, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-non- statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). Non-statutory trust The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-non- statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer Risk transfer applies where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. Segregation of bank accounts Client money is kept separate from Our own money. Client money will be deposited into a client bank account with an authorised UK clearing bank. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. Segregation of designated investments We may also arrange to hold client money, that is subject to a non- non-statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Commission Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. Payment to third parties We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- non-statutory trust, to another person, We will remain liable to You for such money for as long as it remains client money.

Client Money. We, in 7.1. Client money is money that we receive and hold on behalf of our clients over the course of carrying our relationship such as premium payments, premium refunds and claim payments. We hold this either on insurance distribution, handle client money your behalf or on behalf of your insurer(s) as determined by the agreement we have in accordance place with each insurer. 7.2. In most cases we will have an agreement with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us insurers where we act as agent of for the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the and any money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which received by us will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having if it has been received by the insurer when they are and the insurer will bear the risk of any losses in the event that our firm becomes insolvent. In the same way, we may also have an agreement with the insurer that any claims money or premium refunds received by Us. Where us from the agreement extends to premium refunds and/or claims, any premium refunds or claims insurer will not be treated as received by You only when you until they are actually paid over to Youyou. Any interest earned on We may hold both insurer and client money in the same bank account, but when this happens insurers will have previously agreed that is subject to any claim by you on monies that are client money will come before their claim. 7.3. In cases where we do not have such an agreement with an insurer we will hold your money in either a statutory or a non-statutory trust client money bank account. These accounts are governed by rules that seek to protect clients against any inability of an insurance broker to transfer premiums to an insurer, or to transfer refunds and/or claims money to a client. 7.4. The terms of a non-statutory trust account allow us to use the money held in trust on behalf of one client to pay another client’s premium before it is received from that client and to pay premium refunds or claims before we receive payment from the insurer. This is in line with standard industry practice and we are not permitted to use client money for any other purpose. If you do not wish us to hold your money in a non- statutory trust account, please let us know. 7.5. Any commission due to us may be taken from the client money account and this may be taken before we pass the premium onto the insurer. If we earn interest on any money held in this account this will be retained by Usus and not passed on to you. 7.6. We may also arrange need to hold client moneytransfer money to an affiliate, where this is required, you authorise us to do so. If we use a third party to place your insurance we may need to transfer your money to that party but we still remain responsible for your money until it is subject deemed to be received by the insurer. In some cases this may mean that your money is transferred to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to third party outside of the money that would otherwise have been paid into a client bank accountUK where the legal and regulatory systems are different. If We such a third party fails, your money may be treated differently than it would had the third party been in the UK. 7.7. If you do thisnot want your money to be passed outside of the UK or if you have any other objections to this section, We please contact us immediately. If we do not hear from you we will be responsible for meeting any shortfall in Our assume you consent to us handling client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneyway.

Client Money. We, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-non- statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-non- statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. Client money is kept separate from Our own money. Client money will be deposited into a client bank account with an authorised UK clearing bank. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client money.

Client Money. We, in In the course of carrying on insurance distributiondistribution activities, We handle client money in accordance with the FCA FCA’s Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS these rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it : • It is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. • Risk transfer applies where money is held by Us as agent of a relevant insurer in accordance with a written wriben agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted restricted; for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Usinsurer. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. Client money is kept separate from Our own money. Client money will be deposited into a client bank account with an authorised UK clearing bank. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client money.

Client Money. We, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. .A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. .The fact that We will hold money on trust gives rise to fiduciary duties which will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. .Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. .The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. .Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will be treated as received by You only when they are actually paid to You. with an authorised UK clearing bank. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to the money that would otherwise have been paid into a client bank account. .If We do this, We will be responsible for meeting any shortfall in Our client money resource which is attributable to falls in the market value of a segregated investment. .Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. .Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client money.

Client Money. We, in 7.1 Client money is money that we receive and hold on behalf of our clients over the course of carrying our relationship such as premium payments, premium refunds and claim payments. We hold this either on insurance distribution, handle client money your behalf or on behalf of your insurer(s) as determined by the agreement we have in accordance place with each insurer. 7.2 In most cases we will have an agreement with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is held on Your behalf in a segregated bank account that is subject to a non-statutory trust; or ii. it is held by Us insurers where we act as agent of for the relevant insurer (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the and any money may be held. In such a circumstance, Our general creditors (or those of the bank or third party) should not be able to make claims on client money, as such money will not form part of Our (or the bank’s or third party’s) property. The fact that We will hold money on trust gives rise to fiduciary duties which received by us will be owed to You until the client money reaches the insurer, at which time Our fiduciary duties with regard to Your money will cease. By holding client money subject to a non-statutory trust, We are entitled to and may make advances of credit from the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having if it has been received by the insurer when they are and the insurer will bear the risk of any losses in the event that our firm becomes insolvent. In the same way, we may also have an agreement with the insurer that any claims money or premium refunds received by Us. Where us from the agreement extends to premium refunds and/or claims, any premium refunds or claims insurer will not be treated as received by You only when you until they are actually paid over to Youyou. Any interest earned on We may hold both insurer and client money in the same bank account but when this happens insurers will have previously agreed that is subject to any claim by you on monies that are client money will come before their claim. 7.3 In cases where we do not have such an agreement with an insurer, we will hold your money in either a statutory or a non-statutory trust client money bank account. These accounts are governed by rules that seek to protect clients against any inability of an insurance broker to transfer premiums to an insurer, or to transfer refunds and/or claims money to a client. 7.4 The terms of a non-statutory trust account allow us to use the money held in trust on behalf of one client to pay another client’s premium before it is received from that client and to pay premium refunds or claims before we receive payment from the insurer. This is in line with standard industry practice and we are not permitted to use client money for any other purpose. If you do not wish us to hold your money in a non-statutory trust account, please let us know. 7.5 Any commission due to us may be taken from the client money account and this may be taken before we pass the premium onto the insurer. If we earn interest on any money held in this account this will be retained by Us. us and not passed on to you. 7.6 We may also arrange need to hold client moneytransfer money to an affiliate, where this is required, you authorise us to do so. If we use a third party to place your insurance we may need to transfer your money to that party but we still remain responsible for your money until it is subject deemed to be received by the insurer. In some cases this may mean that your money is transferred to a non- statutory trust, in separately permitted designated investments with a value at least equivalent to third party outside of the money that would otherwise have been paid into a client bank accountUK where the legal and regulatory systems are different. If We such a third party fails, your money may be treated differently than it would, had the third party been in the UK. 7.7 If you do thisnot want your money to be passed outside of the UK or if you have any other objections to this section, We please contact us immediately. If we do not hear from you we will be responsible for meeting any shortfall in Our assume you consent to us handling client money resource which is attributable to falls in the market value of a segregated investment. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trust, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds from You (or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneyway.

Client Money. We7.1. If we hold money on a client’s behalf, in the course of carrying on insurance distribution, handle client money in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle client money in either one of the following ways, both of which are described in more detail below: i. it is will be held on Your behalf in a segregated bank account trust fund that is subject separate from our own cash assets. These separate trust fund arrangements are commonly known as “client money”. If we were ever unable to a non-statutory trust; or ii. it is held by Us as agent of the relevant insurer pay our debts, then those to whom we owe money (“risk transfer”). The aim of the trust is to protect You in the event of Our financial failure, or the failure of the bank or a third party at which the money may be held. In such a circumstance, Our general creditors (or those of the bank or third partyour creditors) should not be able to make claims on our client money, money in the separate trust funds as such money will it does not form part of Our (or the bank’s or third party’s) propertyour own cash assets. 7.2. The fact trust arrangement we use for client money is known as a non-statutory trust. Here, we may use premiums and claims monies we receive to cross-fund clients’ premiums and claims; for example we may pay a premium on to an insurer before we have received it from the client if we believe it is in the best interests of that client. 7.3. We have agreements with some insurers (known as “risk transfer agreements”). Under these risk transfer agreements the insurers agree that they are responsible to you for any premium that you have already paid to us and that they remain responsible for any premium refunds or claims payments until the premium refund or claim payment is received by you. In this case we may hold client money due to or from the insurers in the same trust fund. 7.4. Where we do not have risk transfer agreements in place with insurers the client money we hold will still be protected within the non- statutory trust but will be known as “non risk transfer” client money. Non risk transfer clients have priority over insurers to the money in the trust fund as insurers granting risk transfer have agreed to subordinate their interests in the trust to those of ▇▇▇▇▇ Commercial’s non risk transfer clients. 7.5. We do not use client money to pay ourselves commission before we receive your premium. 7.6. When we hold client money on trust for you this gives rise to fiduciary duties which upon us that will not be owed to You discharged until the client money reaches is deemed to have reached the insurerinsurer or product provider (as detailed above, at which time Our this is when we receive premium in the case of risk transfer agreements). 7.7. Without affecting our fiduciary duties with regard to Your money will cease. By holding you, in some cases we may: • hold client money in accounts which are outside of the United Kingdom and which may be subject to a non-statutory trust, We are entitled to different legal and regulatory conditions and may make advances treat money differently in the event of credit from a bank failing. If you are a consumer (a person who buys products or services for personal use and not for business purposes) you can ask us not to put your client money in an account in a particular country. • pass client money to another intermediary, including ones outside of the trust to enable a client’s premium obligation to be met before the premium is remitted to Us. Similarly, it allows claims United Kingdom where different legal and premium refunds to be paid from the trust to a client before receiving remittance of those monies from the insurer. Risk transfer applies regulatory conditions apply and where money is held by Us as agent of a relevant insurer in accordance with a written agreement with that insurer. The written agreement will specify the extent to which risk transfer will apply and whether it includes all items of money or is restricted for example, to the receipt of premiums. Where risk transfer applies, You will be protected to the extent that any premiums We receive from You are treated as having been received by the insurer when they are received by Us. Where the agreement extends to premium refunds and/or claims, any premium refunds or claims will may be treated as received by You only when they differently in the event of an intermediary failing. If you are actually paid a consumer, you can ask us not to Youpass your money to an intermediary outside of the United Kingdom or in a particular country. Any interest earned on client money that is subject to a non-statutory trust will be retained by Us. We may also • arrange to hold client money, that is subject to a non- statutory trust, in separately permitted designated certain investments with a value at least equivalent equal to the money that would otherwise have been paid into a separate client bank account. If We we do this, We we will be responsible for meeting any shortfall in Our the client money resource which funds if the shortfall is attributable due to falls a reduction in the market value of a segregated investmentthose investments. 7.8. Any investment returns on any segregated designated investments will be retained by Us. Where client money is held on a non- statutory trustIf, We can only withdraw commission from the client bank account in the following circumstances: i. when We actually receive the premium as cleared funds process of handling client money, we earn interest or benefit from You (investment income or from a third-party premium finance provider on Your behalf); and ii. at the point at which the commission becomes due and payable to Us for Our own account provided this is consistent with the terms of business of the insurer to whom the premium is payable. Until that point commission foreign exchange rate movements, we will remain client money. Where risk transfer applies, commission will become due and payable to Us for Our own account immediately on receipt of the premium, provided this is consistent with the terms of business of the insurer to whom the premium is payable. We may transfer client money to another person, keep any such as another intermediary, for the purpose of effecting a transaction through that person. Where We transfer client money that is subject to a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client moneyamounts.