Our Client Agreement

We are a financial planning business, focused on helping you understand and plan for your financial future. This
agreement sets out the terms under which we’ll provide our services to you, so it’s important that you read it
fully. If there’s something you don’t understand please ask us to explain it.

1. 1. Our obligations

      Our recommendations

      • We are independent for Investments and pension business. This means that we will assess a
        sufficient range of relevant products available on the market which is diverse in terms of
        product type and provider to ensure that your investment objectives can be suitably met. We are
        not limited in the type of product or provider in terms of having any close links with any firms
        or any contractual relationship with a third party that may impair the independent basis of our
        advice to you.
      • When looking to address your protection needs, we will provide advice based on a fair and
        personal analysis of the market.
      • Before providing advice we’ll assess your needs, consider your financial objectives and assess
        your attitude to any risks that may be involved. If you don’t want to discuss a particular area
        of financial planning and that area should not form part of the advice given, we can exclude it,
        if you instruct us to do so. This might of course have a bearing on the advice that might have
        been given.
      • Before making any recommendations we’ll carry out a suitability assessment so that we are able
        to act in your best interests.
      • We’ll confirm any recommendations we make in writing (our suitability report) along with details
        of any special risks that may be associated with the products or investment strategies we’ve
        recommended.
      • Where we agree to provide you with a full ongoing advisory service, which includes an ongoing
        review of the suitability of the investments we have recommended, we’ll carry out this review at
        least annually. To do this we will need to make contact with you to assess whether the
        information we hold about you remains accurate and up to date. We’ll notify you of the results
        of our assessment and, if relevant, any updated recommendations.
      • Please be aware that investments can fall, as well as rise, and that you may not get back the
        full amount invested. The price of investments we may recommend may depend on fluctuations in
        the financial markets, or other economic factors, which are outside our control. Past
        performance is not necessarily a guide to future performance.
      • Specific warnings relevant to the investments, investment strategies or other products we
        arrange are provided in the relevant product literature provided.
      • We may, where appropriate, recommend holding some, or all, of your investments with a
        discretionary fund manager (DFM), a professional investment manager appointed to monitor your
        portfolio and make investment decisions on your behalf. In such cases we’ll explain the
        respective responsibilities of ourselves and the DFM in relation to your investments.
      • In some circumstances, we may need to act as your ‘agent’ in relation to the part of your
        portfolio held with a DFM. This means that you won’t have a direct contractual relationship with
        the DFM and the DFM will instead treat us (the firm) as its client. Before setting up this type
        of arrangement we will explain the implications to you. Fundamentally though, the implications
        will be that you will have no recourse to the Financial Ombudsman Service in the event of a
        complaint regarding their service nor would you be able to refer to the Financial Services
        Compensation Scheme in the unlikely event that the firm becomes insolvent. Further details would
        be confirmed in the Key Features Document supplied by the DFM.

      Financial crime

      • We are obliged to put in place controls to prevent our business from being used for money
        laundering and other forms of financial crime.
      • We’ll verify your identity before undertaking any business with you. To do this we may use
        electronic identity verification systems and we may conduct these checks from time to time
        throughout our relationship, not just at the beginning. The check may leave a ‘footprint’ on
        your credit file but it will not affect your credit rating.

      Best execution

      • Where we send investment applications on your behalf to third parties (e.g. to put an investment
        into force), we’ll take all sufficient steps to ensure that we obtain the best possible result
        for you. This is referred to as ‘best execution’.
      • We have a best execution policy. If you want to see a copy of it please ask us.

      Conflicts of interest

      • Although we’ll always try to act in your best interests there may be situations where we or one
        of our other clients has some form of interest in the business being transacted for you. If this
        happens, or we become aware that our interests or those of one of our other clients conflict
        with your own interests, we’ll write to you and ask for your consent to proceed before we carry
        out any business for you. We’ll also let you know the steps we’ll take to make sure you are
        treated fairly.
      • We have a conflicts of interest policy. If you want to see a copy of it please ask us.

      Communicating with you

      • Our normal ways of communicating with you are by telephone, post, e-mail or in person. Our
        communications will be in English.
      • We may ask you to confirm your instructions to us in writing as this helps to avoid any future
        misunderstandings.

   2. Your obligations

      This section sets out your obligations in agreeing to receive our services.

      Providing information about your circumstances

      1. 1. • Our advice will be based on the information that you give so it’s important that
              you provide us with accurate and up to date information when we request details
              about your circumstances and objectives. This will allow us to provide you with
              suitable advice. If the information you provide is inaccurate, or if you limit
              the information provided, this could affect the suitability of the advice we
              give.

      Payment for services

      1. 1. • By accepting this agreement, you are agreeing to pay the charges for our
              services as set out in section 5 (Our charges and services agreed). Your
              selected payment method is also confirmed in section 5. We’ll tell you if any
              payments are subject to VAT.
         2. • Our initial charges are payable once we have implemented your financial plan.
            • All initial fees can either be paid directly by you or deducted from your
              investment. We must receive full payment of the amount due at the point of
              implementation unless you have elected for our fee to be deducted from your
              investment.
            • Any products we have arranged for you will only be kept under review as part of
              an ongoing service, for which you have agreed to pay. The ongoing service level
              recommended will depend upon your personal circumstances and financial
              situation. The ongoing service level agreed will be provided as a follow up to
              the initial service.
            • Our charges for ongoing services will commence alongside the initial charge,
              payable monthly in arrears.
            • Ongoing services can be cancelled at any time by informing us in writing (see
              section 3 – Cancellation and amendments) but please note that we do reserve the
              right to charge you for services we have provided before cancellation.
         3. • Where our charges are based on a % of your investments, the amount of our
              ongoing charges may increase as the size of your fund grows.
            • In some circumstances we may receive ongoing payments (commission) from product
              providers relating to existing investments you hold. Such payments may be taken
              into account when determining the charges for ongoing services. We’ll discuss
              and agree this with you where relevant.

      Our charges are guaranteed not to increase within the first 12 months of your contract with us.
      Should we need to increase our charges after this period, you will be given notice of this fact and
      the opportunity to decide whether to continue with the revised level of charges. It should be noted
      it is not compulsory for you to agree to our services and we do offer a transactional only
      service.

      Legal and accounting advice

      • We are not qualified to provide legal or accounting advice or to prepare any legal or accounting
        documents. This means that the onus is on you to refer any point of law or accountancy that may
        arise during discussions with us, to a solicitor or accountant.

   3. Cancellation and amendments

      Ending this agreement

      1. 1. • We may terminate this agreement by giving you at least 20 business days’ written notice
            • You may terminate this agreement at any time, without penalty. Notice of termination
              must be given in writing and will take effect from the of receipt
            • Any transactions already initiated will be completed according to this agreement unless
              otherwise agreed in writing.
            • You will be liable to pay for any services we have provided before cancellation and any
              outstanding fees, if applicable.

      Amendments

      1. 1. • From time to time it may be necessary to amend the terms set out in this agreement where
              it’s not necessary to issue a new agreement. If this is the case, we’ll write to you
              with details of the changes within at least 28 business days.

      Product cancellation rights

      1. • In most cases you can exercise a right to cancel by withdrawing from the contract.
           Generally, you will have a 30-day cancellation period for a life, pure protection or
           pension contracts and a 14 day cancellation period for all other contracts. Instructions
           for exercising the right to cancel, if applicable, will be contained in the relevant
           product disclosure information which will be issued to you. If you cancel a single
           premium contract, you may be required to pay for any loss you might reasonably incur in
           cancelling it which is caused by market movements. This means that, in certain
           circumstances, you might not get back the full amount you invested if you cancel the
           policy.

   4. Useful information about our services

      Who authorises us to advise you?

      1. 1. • We are authorised and regulated by the Financial Conduct Authority (FCA), 12 Endeavour
              Square, London, E20 1JN. www.fca.org.uk. Our firm
              reference number is 514951.
            • Our permitted business is advising on and arranging pensions, savings and investment
              products, non-investment insurance contracts and mortgages.
            • You can check our details on the Financial Services Register by visiting the FCA’s
              website www.fca.org.uk/firms/systems-reporting/register or
              by contacting the FCA on 0800 111 6768.
            • Unless we tell you otherwise, we’ll treat you as a retail client for investment and
              pension advice, and as a “consumer” for protection advice. This means that you are given
              the highest level of protection available under the UK’s regulatory system.

      What if things go wrong?

      1. 1. • If you are unhappy with our advice or any aspect of our services, we encourage you to
              contact us as soon as possible. We’ll do our best to resolve your concerns.
            • If you wish to register a complaint, please write to Cheetham Jackson Limited, 14-16 St
              Thomas’s Road, Chorley, PR7 1HR, telephone 01257 239990 or email
              professionalstandards@cheethamjackson.com.
            • We have a complaints procedure and we can provide further details on request. If you do
              have a complaint, and you are not happy with our response, the Financial Ombudsman
              Service (FOS) may be able to help. The FOS settles disputes between financial services
              business and their clients. Full details are available at www.financial-ombudsman.org.uk.

      Additional peace of mind

      1. 1. • The Financial Services Compensation Scheme (FSCS) is the UK’s statutory compensation
              fund for customers of authorised financial services firms who are unable to pay claims
              against them, usually because they have gone out of business.
            • You may be able to claim compensation from the FSCS if we can’t meet our obligations.
              The amount of compensation available will depend on the type of business and the
              circumstances of the claim. We can provide more specific information on request, but as
              a guide:
            • Investments – eligible claims for most types of investment business are covered for up
              to a maximum of £85,000.
            • Insurance – in the majority of cases, eligible claims about the advising and arranging
              of protection products are covered for 90% of the claim, without any upper limit.
            • Further information is available from the FSCS at www.fscs.org.uk

      Benefits we may receive

      1. • Under the rules of our regulator, the FCA, as a firm providing independent advice we are unable
           to accept or retain payments or benefits from other firms (e.g. product providers) as this would
           conflict with our independent status.
         • From time to time we may attend training events funded and /or delivered by product providers,
           fund managers and investment platforms. These events are designed to enhance our knowledge and
           enhance the quality of service we provide to our clients. As such this doesn’t affect our
           obligation to act in your best interests. Please ask us if you want further details.

   5. Our charges and services agreed

      We are committed to providing the highest standard of financial advice and service. Your interests are very
      important to us and for any advice or service we provide we will:

      • be open, honest and transparent in the way we deal with you;
      • not place our interests above yours;
      • communicate clearly, promptly and without jargon - making the complex simple;

      How we are paid

      The way we are paid for our services may depend on the type of advice given. Typically this will be:

      • Investment and pension business: fees agreed and paid by you (directly or via your
        policy, where applicable) based on a percentage of the amount you invest, except in the case of
        Defined Benefit (Final Salary) pension schemes. In this instance, a separate client agreement will
        be provided which solely covers the work involved for the transfer advice.
      • Insurance business: fees agreed and paid by you or commission payable by the
        insurance provider.

      The cost of our valued service proposition

      We provide you with an initial consultation free of charge. This helps us to understand your financial
      objectives and will confirm how we can support you in working towards these. We will also discuss the cost,
      and levels, of our services both initially and throughout our relationship with you.

      Financial Review and Recommendation

      This can be a continuation from the initial discussion, where agreed, or a further appointment. This process
      covers:

      • Understanding your situation by gathering information about your existing financial arrangements and
        full personal circumstances;
      • Understanding of your investment knowledge and risk tolerance, requirement and capacity;
      • Recommendation of an asset allocation model that matches your investment risk profile and the
        subsequent assessment and suitability of any existing investments;
      • Analysis and design of your investment strategy;
      • Presentation of your recommendation.

      Arranging and setting up your Investment(s) and/or Pension(s) – Lump Sum or Transfers

      Should you instruct us to proceed with any of our recommendations we will act for you in the following ways:

      • Facilitate and deal with all fund and contract administration on your behalf;
      • Communicate regularly keeping you informed of progress;
      • Provide you with all documentation in line with the discussed expectations;
      • Provide you with confirmation of the actions taken on your behalf in writing.

      Your Payment Options

      Our charge for this service is based on the amount you invest and/or transfer. These charges are applied as
      follows:

      Initial fees

      Initial fees
      3% through our investment platform on investments up to £150,000, thereafter reducing to 1% on any sums above this amount. Same charges apply for additional lump sum contributions and/or regular ongoing contributions. 3% for the purchase of an annuity through the open market option (OMO). Please see minimum fee charges below: £500 minimum fee for setting up a new investment/pension through our investment platform. £1000 minimum fee for transferring funds from an existing investment/pension through our investment platform. £1000 for the purchase of an annuity through the open market option (OMO).
      Example 1: If you were to invest £100,000 on our investment platform we would charge £3,000. Example 2: If you were to invest £400,000 on our investment platform we would charge £7,000. Example 3: If the amount available to purchase an annuity through the open market option was £45,000 then we would charge £1,350.

      All initial fees can either be paid directly by you or deducted from your investment and/or pension. We must
      receive full payment of the invoice amount within 30 days of issue unless you have elected for our fee to be
      deducted from your investment and/or pension.

      On-going Service and Reviews

      Your financial and personal objectives may change over time due to changes in your lifestyle or
      circumstances. We believe it is essential to ensure the investment we recommend continues to meet your
      lifestyle and investment objectives.

      To ensure we are able to support the ongoing needs of all our clients, we have formulated an ongoing
      advisory service, the details of which are as follows:

      Ongoing service level	Details of service
      Full ongoing advisory service	Scheduled annual review meeting to undertake: A detailed assessment of your current circumstances and any changes to your plans that are needed A review of performance Regular updates and information regarding your investment(s) and pension(s) On-going support with correspondence, regulatory changes, and administration issues

      Your Payment Options for Ongoing Charges

      Our charge for ongoing service is based on the value of your investment(s) and/or pension(s). These charges
      are applied as follows:

      Ongoing service level	Details of agreed fee (Any payments subject to VAT will be shown below)
      Full ongoing advisory service	Through our recommended investment platform: Investments up to £500,000 – 1.0% p.a.; Investments between £500,000.01 and £1,000,000 – 0.85% p.a.; Investments above £1,000,000.01 – 0.7% p.a. The ongoing advice charge will be based on the collective value of assets of those residing at the same address. The charge will be applied to the whole value and taken monthly in arrears. For example: If we were to use our recommended investment platform and your assets were £300,000, the annual adviser fee would be £3,000pa. If we were to use our recommended investment platform and your assets were £750,000, the annual adviser fee would be £6,375pa. If we were to use our recommended investment platform and your assets were £1,250,000, the annual adviser fee would be £8,750pa.
      Responsibility Fee	All ongoing platform fees where the investment recommendation is to use one of Cheetham Jackson’s Model portfolio services are subject to a Responsibility fee of either 0.07% or 0.10%. For example: If we were to use our recommended investment platform and your assets were £100,000, the annual responsibilityfeewould be £70 or £100pa. If we were to use our recommended investment platform and your assets were £300,000, the annual responsibilityfeewould be £210 or £300pa. If we were to use our recommended investment platform and your assets were £750,000, the annual responsibilityfeewould be£525 or £750pa. If we were to use our recommended investment platform and your assets were £1,250,000, the annual responsibility fee would be £875 or £1,250pa

      Where we refer to a Responsibility and ongoing fee above this is to breakdown and demonstrate the difference
      in operational and regulatory costs and the adviser services we provide. The actual Responsibility fee you
      pay will be disclosed on the Suitability Report provided.

      The Responsibility fee relates to the costs we incur in relation to our operational, FCA and insurance fees,
      which is broadly calculated by how much in funds we have under advice.

      Our ongoing charge will be taken on a monthly basis in arrears via the product provider and will fluctuate
      as the value of your portfolio fluctuates. If we are unable to take the ongoing charge from the product
      provider you will be required to pay this directly.

      Our charges are guaranteed not to increase within the first 12 months of your contract with us. Should we
      need to increase our charges after this period, you will be given notice of this fact and the opportunity to
      decide whether to continue with the revised level of charges. It should be noted that it is not compulsory
      for you to agree to one of our services and we do offer a transactional only service.

      The full ongoing service can be cancelled at any time by confirming your intention in writing. In this
      event, you may transfer to our lifeboat solution. If you no longer wish to use our service at all, you will
      need to secure the services of an alternative adviser. If you do not wish to work with an adviser, you will
      need to transfer your investments to an alternative product provider.

      Our actual initial and ongoing charges and fees (in pounds and pence) will be agreed with you before
      we do any work, and we’ll explain your payment options too. We’ll also let you know where any fees are
      subject to VAT.

      VAT

      Under current legislation our services are not subject to VAT but should this change in future, and where
      VAT becomes due, we will notify you before conducting any further work.

      Aggregated Costs & Charges

      Before we provide you with our advice we will add together all the costs and charges payable so you are able
      to understand the overall costs of our services and recommendations. This is referred to as aggregated costs
      and charges information.

   6. Declaration

      • I/We acknowledge that the client agreement will come into effect when the initial adviser services
        commence and will remain in force until terminated by either party
      • This agreement is governed and shall be interpreted in accordance with English law and both parties
        shall submit to the exclusive jurisdiction of the English Courts.
      • A copy of this agreement will be available on our website for future reference. On occasion we may
        update our Client Agreement so please check this page occasionally to ensure you are happy with any
        changes.

      Appendix A – Protecting your personal information

      • To provide our services properly we’ll need to collect information about your personal and financial
        circumstances. We take your privacy seriously and will only use your personal information to deliver
        our services.
      • Processing of your personal data is necessary for the performance of our contract for services with
        you and in meeting our obligations to preventing money laundering or terrorist financing. Generally
        this is the lawful basis on which we intend to rely for the processing of your data. (Please see the
        reference to special categories of data below). Our policy is to gather and process only that
        personal data which is necessary for us to conduct our services appropriately with you and to
        prevent money laundering or terrorist financing.
      • We adopt a transparent approach to the processing of your personal data. Sometimes, we may need to
        pass your personal information to other organisations. If you apply to take out a financial product
        or service we’ll need to pass certain personal details to the product or service provider.
      • We may engage the services of third party providers of professional services in order to enhance the
        service we provide to you. These parties may also need to process your personal data in the
        performance of their contract with us. Your personal information may be transferred electronically
        (e.g. by email or over the internet) and we, or any relevant third party, may contact you in future
        by what we believe to be the most appropriate means of communication at the time (e.g. telephone/
        email /letter etc.).
      • The organisations to whom we may pass your details also have their own obligations to deal with your
        personal information appropriately. Sometimes a product or service may be administered from a
        country outside Europe. If this is the case, the firm must put a contract in place to ensure that
        your information is adequately protected.
      • Our Privacy Notice. This is a is a separate document which provides more information about the
        nature of our personal data processing activities and includes details of our retention and deletion
        policies as well as your rights of access to the personal information that we hold on you, this can
        be accessed via our website.
      • As part of this agreement we’ll ask you to consent to the transfer of personal information in
        accordance with the protections outlined above.
      • Special categories of personal data: there are certain categories of personal data that are
        sensitive by nature. The categories include: data revealing racial or ethnic origin, political
        opinions, religious or philosophical beliefs, trade union membership and data concerning health.
        Depending on the nature of the products and services that you engage us for we may need to obtain
        your sensitive personal data particularly in relation to health. Our policy is that should we
        require any special category of personal data we will only gather this with your explicit consent.
      • If you are concerned about any aspect of our privacy arrangements please speak to us.