This Client Agreement is issued by Rafter Associates Financial Management Ltd (RAFM Ltd) – 8th September 2021
8th September 2021
Spring Fields, 9 Spring Hill Farm, Harborough Road, Pitsford, Northamptonshire NN6 9AA.
Our Companies House Register Number is 1978259.

This is our standard client agreement upon which we intend to rely. For your own benefit you should read these terms carefully before giving your consent. If you do not understand anything, please ask us for further information.

REGULATORY STATUS
Rafter Associates Financial Management is authorised and regulated by the Financial Conduct Authority (FCA) under Firm Reference Number 116031.
You can check our authorised status, our permitted activities and the people who work for us on the Financial Services Register at www.fca.org.uk or by telephoning
the FCA on 0800 111 6768.
The FCA’s address is 12 Endeavour Square, London E20 1JN.

OUR SERVICES & SCOPE OF ADVICE
Our financial planning services cover all retail investment products; we offer independent advice. We assess a sufficient range of products that are sufficiently diverse with regard to their type, issuers or product providers to ensure that our clients’ investment objectives can be suitably met. Our recommendations for life policies are based on a fair analysis of the whole of the market. Where we have arranged investments for you, we shall review these and provide a report on the overall suitability of the investments for your circumstances, at least annually or more frequently as otherwise agreed in writing between us.

We are available to talk to clients at any time during normal working hours and, other than by prior arrangement, there is no charge for this.

WE DO NOT HANDLE CLIENTS’ MONEY. WE NEVER ACCEPT A CHEQUE MADE PAYABLE TO US NEITHER DO WE HANDLE CASH, UNLESS IT IS PAYMENT IN SETTLEMENT OF CHARGES OR DISBURSEMENTS FOR WHICH WE HAVE SENT YOU AN INVOICE.

INSTRUCTIONS
You may give instructions to us, in English, by (telephone, post, fax, e-mail or in person.) We may ask you to confirm verbal instructions in writing. We will act upon your instructions for investment transactions, but in doing so we may not be able to adhere to our Best Execution policy as set out in this agreement.

CLIENT CATEGORISATION
We have classified you as a “retail client”, which means that you have the highest level of protection under the regulatory system.

If you want to be categorised differently, you should discuss this with your adviser or a member of your service team. In such circumstances we will inform you if your circumstances indicate that you should be classified differently, for example as a professional client or an eligible counterparty. We reserve the right to arrange such a re-categorisation on a case-by-case basis and, where we agree to do so, it may mean that you will have a reduced level of regulatory protection; which might mean you lose a right of access to the Financial Ombudsman Service (FOS). The FOS is the independent body that deals with complaints against financial services providers.

INVESTMENT OBJECTIVES
Our recommendations will be based upon your stated investment objectives, acceptable level of risk and any restrictions you may wish to place on the type of investments you are willing to consider. We shall confirm in writing the suitability of our recommendations, and advise you of your rights to cancel or withdraw from a product where appropriate or, if it is the case, we will inform you that no such rights will apply. We shall draw to your attention specific investment risks that apply to our recommendations and shall require your consent before proceeding. Details of your stated objectives will be set out in a Suitability Report which we will issue to you to confirm our recommendations.

Our service relies upon accurate information about yourself, so please advise us if there are any changes to your personal or financial circumstances.

PAYMENT FOR SERVICES
To ensure that you are always fully aware of our advice costs and how and when you will be asked to pay them, we will always confirm these both verbally and in writing.

We offer an initial discussion without charge, at which we will describe our services fully and explain the payment options. It will take at least one meeting to establish your current position, identify your needs, preferences and objectives and assess your attitude to risk. This information forms the basis of your personalised financial plan, which we will discuss and agree with you prior to implementation.

Payment will usually fall due at the end of the advice process, namely, at the time that you accept our recommendations, complete applications and commit money to contracts.

Our standard charging structure is as follows:
Remuneration for research, planning and implementation: 3% of invested assets (new or transferred) Remuneration for monitoring and review: 1% of invested assets per annum

This remuneration structure provides a complete portfolio management service, including a regular monitoring and review service.

We reserve the right to charge you a minimum fee of £250 if you engage our services and ask us to provide advice and/or a recommendation, with which you subsequently decide you do not want to proceed, or you terminate the relationship after we have provided advice. This is in order to cover the costs of any initial work, research and administration and applies to any product or fund.

The charges that you incur will depend on three factors:

the extent of the work carried out at inception

the level of service that you wish to receive now and in the future

the solution you choose for investment business (if appropriate)

You may ask us for an estimate of how much we might charge in total, but obviously it will be a best estimate and we will not be bound by this. You may also ask us not to exceed a certain amount without checking with you first.

Where we agree an ongoing advisory service with you we shall provide you with an annual report on costs and charges, including the effect of costs and charges on the overall return of your investments. Where relevant, the product providers themselves will send you separate summaries detailing their own costs and charges and the impact these have on your policies.

EXAMPLE CHARGES
INVESTMENT, SAVINGS & PENSION BUSINESS CHARGING STRUCTURE
We do not receive any payment from product providers – the entire cost for advice is borne directly by the client.

There are two methods of payment: facilitation and separate fee.

Facilitation – this is where the provider deducts the client agreed initial fee from the amount to be invested and pays it to us; therefore, a lower amount is invested. Separate fee – this is where the client pays the agreed fee to us separately; therefore, the full amount is invested.

Either method can be used to pay the agreed ongoing fee, i.e. the provider can deduct the client agreed fee amount from the fund value and pay it to us, or the client can choose to leave the fund intact, but pay an amount directly to us via separate fee that is equal to the appropriate

percentage.

FACILITATION EXAMPLE OF REMUNERATION FOR ADVICE AND A RECOMMENDATION TO INVEST A £100,000 LUMP SUM (NEW MONEY OR TRANSFER OF EXISTING FUNDS):

Initial advice fee = 3%.

ongoing advice fee = 1%. (Example percentages only; actual percentages will depend on the exact nature and complexity of the service provided, see ‘Payment for Services’ section above. 3% of £100,000 (£3,000), is deducted by the provider from the investment and is paid to the adviser, therefore £97,000 is invested.

1/12th of 1% of £97,000 (£80.84) is deducted by the provider from the fund in the first month and is paid to the adviser. This process is repeated every month for the duration of the contract.

This means that the total fee paid by you in the first year would be £3,970.

Please note that the monetary equivalent of the 1% ongoing advice fee will vary according to the size of the fund invested, the frequency of the remuneration paid to RAFM Ltd and fluctuation in the value of the investments during the year. The ‘total fee paid by you in the first year’ figure assumes that the fund valueremains static over 12 months, which is for purposes of illustration.

SEPARATE FEE EXAMPLE OF REMUNERATION FOR ADVICE AND A RECOMMENDATION TO INVEST A £100,000 LUMP SUM (NEW MONEY OR TRANSFER OF EXISTING FUNDS):

Initial advice fee = 3%.

ongoing advice fee = 1%. This is an example percentage only; actual percentages will depend on the exact nature and complexity of the service provided – please see the ‘Payment for Services’ section above.

3% of £100,000 (£3,000) separate fee payable to the adviser therefore £100,000 is invested. 1/12th of 1% of £100,000 (£83.33) separate fee payable to the adviser in the first month. This process is repeated every month for the duration of the contract.

This means that the total fee paid by you in the first year would be £3,999.96.

Please note that the monetary equivalent of the 1% ongoing advice fee will vary according to the size of the fund invested, the frequency of the remuneration paid to RAFM Ltd and fluctuation in the value of the investments during the year.

FACILITATION EXAMPLE OF REMUNERATION FOR ADVICE AND A RECOMMENDATION TO INVEST £1,000 PER MONTH:

Initial advice fee = 3%.

ongoing advice fee = 1%. (Example percentages only; actual percentages will depend on the exact nature and complexity of the service provided, see ‘Payment for Services’ section above). Upon investment of each monthly contribution, the provider deducts the agreed fee and pays it to the adviser; therefore a lower amount is invested each month for the duration of the contract.

The fee includes two elements as follow:

3% of £1,000 (£30), therefore £970 is invested each month

Over 12 months, 1% x 1/12 of the fund value per month is payable. 1/12th of 1% of £970 (£0.81) separate fee payable to the adviser in the

first month. This process is repeated every month for the duration of the contract.

This means that the total fee paid by you in the first month would be £30.81 and the total paid in the first year would be £422.86 (£360 Initial Fees + £62.85 ongoing charge).

Please note that the monetary equivalent of the 1% ongoing advice fee will vary according to the size of the monthly contribution, the frequency of the remuneration paid to RAFM Ltd and fluctuation in the value of the investments during the year. The ‘total fee paid by you in the first year’ figure assumes that the fund value remains static over 12 months, which is for purposes of illustration.

SEPARATE FEE EXAMPLE OF REMUNERATION FOR ADVICE AND A RECOMMENDATION TO INVEST £1,000 PER MONTH:

Initial advice fee = 3%.

ongoing advice fee = 1%. (Example percentages only; actual percentages will depend on the exact nature and complexity of the service provided, see ‘Payment for Services’ section above.) 3% of £1,000 (£30) separate fee payable to the adviser therefore £1,000 is invested.

Over 12 months, 1% x 1/12 of the fund value per month is payable. 1/12th of 1% of £1,000 (£0.83) separate fee payable to the adviser in the first month

This process is repeated every month for the duration of the contract.

This means that the total fee paid by you in the first month would be £30.83 and the total paid in the first year £424.81 (£360 Initial fees + £64.81 ongoing charge).

Please note that the monetary equivalent of the 1% ongoing advice fee will vary according to the size of the fund invested, the frequency of the remuneration paid to RAFM Ltd and fluctuation in the value of the investments during the year.

ONE-OFF COSTS
Pension Report (for Non-Existing Clients): £495.

This document details what pension benefits are available within an existing Pension Scheme, together with the projected values and critical yields needed on transfer to achieve the desired growth (Please note we cannot advise on defined Benefit Transfers).

The one-off costs should not be ‘bundled’ or added together for a planning review or a series of actions, as an investment alone may well mitigate any further fees for the work involved.

INSURANCE BUSINESS CHARGING STRUCTURE
For insurance business (e.g. life insurance, income protection), we are usually remunerated by way of commission paid to us by the provider, although it is possible for us to come to a separate fee agreement or work at an hourly rate. Prior to commencement of the recommended product, you will receive a client-specific illustration, which will detail the provider remuneration, together with any other fees and costs that relate to your product.

VAT
We are registered for VAT (our VAT registration number is 443 7526 43).

The remuneration we receive from you, insurers and investment houses for the services we provide under the terms of this Client Agreement are normally exempt from VAT. In certain circumstances, such as where we analyse your affairs or existing products and there is no intention to provide advice and/or a recommendation, the work we do will be subject to VAT. Whatever the case, your adviser will confirm to you in writing if the fees are subject to VAT or not.

THESE ARE EXAMPLES AND ARE USED FOR ILLUSTRATIVE PURPOSES ONLY; THE ACTUAL AMOUNTS WILL VARY, DEPENDING ON THE INITIAL WORK CARRIED OUT, THE CHOSEN SERVICE LEVEL AND THE STRUCTURE OF THE INVESTMENT MANAGEMENT. WE RESERVE THE RIGHT TO ALTER OUR FEES AT ANY POINT IN THE FUTURE. IF THIS HAPPENS, WE WILL INFORM YOU IN WRITING AT THE EARLIEST OPPORTUNITY. YOU WILL BE FREE TO WITHDRAW FROM THIS CLIENT AGREEMENT WITHOUT PENALTY IF YOU DO NOT AGREE THAT THE REVISED BASIS IS FAIR OR YOU DEEM IT PROHIBITIVELY EXPENSIVE.

COMPLAINTS & COMPENSATION
WHAT TO DO IF YOU HAVE A COMPLAINT
WHAT TO DO IF YOU HAVE A COMPLAINT

We hope that the service we provide meets with your expectations at all times. However if you are dissatisfied with our service please contact Neil Rafter, who is the firm’s Compliance office. If you are unhappy with the outcome of your complaint you may complain directly to the Financial Ombudsman Service (FOS). Further details and a copy of our complaints process are available on request and the FOS website address is: www.financial–ombudsman.org.uk.

ARE WE COVERED BY THE FINANCIAL SERVICES COMPENSATION SCHEME (FSCS)? We are covered by the FSCS. You may be entitled to compensation from the FSCS if we cannot meet our obligations. Compensation depends on the type of business and the circumstances of the claim. The compensation limits are as follow:

Investment – Prior to April 2019 most types of investment were covered up to 100% of the first £50,000 per person, which was the maximum compensation payment. With effect from the 1st April 2019, this maximum has increased to £85,000.

Deposit – Since the 30th January 2017, the deposit protection limit has been £85,000. Insurance – Insurance advising and arranging is covered for 100% of the claim, with no upper limit.

You will find up to date details of the FSCS compensation limits, eligibility and details of how to make a claim on its website www.fscs.org.uk

CHANGES AND TERMINATION OF AUTHORITY
We will give you written notice of changes to these terms and conditions. You or we may terminate these instructions at any time, without penalty. Notice of this termination must be given in writing and will take effect from the date of receipt. Termination is without prejudice to any transactions already initiated, which will be completed according to these terms and conditions unless otherwise agreed in writing. You will be liable to pay for any transactions made prior to termination and any fees, which may be outstanding.

RIGHT TO WITHDRAW
A right to withdraw or cancel the contract within a specified period is normally provided for many retail investment products, such as, life insurance policies, unitised collective investment schemes, open-ended investment companies, stakeholder pensions and personal pensions. Details of such rights are ordinarily contained in the product Key Features Document but we will also confirm them to you in writing; if no such rights apply, we will confirm this in writing also before or at the time of any transaction.

BEST EXECUTION
In consideration of our obligation to provide the best possible result for our clients, our policy is that we use a range of different venues that are appropriate to our client’s needs. For clients where we provide an ongoing review service involving a range of funds, we consider that the additional services provided by a platform justify the additional Best Execution costs that may be incurred. For clients requiring an ad-hoc or single investment, we select a bespoke fund that meets their particular requirements. Where we select bespoke funds these compare favourably in cost terms with a range of similar funds, and we review our preferred funds regularly. In transmitting investment applications on your behalf to third parties, we will take all reasonable steps to ensure we obtain the best possible result for you.

We review our Best Execution policy and whenever a material change occurs that affects our ability to adhere to our Best Execution policy. Further information on our Best Execution policy is available on request.

CONFLICTS OF INTEREST
We will take appropriate steps to identify situations where conflicts of interest may arise, between ourselves and a client and between one client and another and will undertake to prevent the conflict from materialising. In certain circumstances, we may not proceed with a transaction or may require your express prior consent. Further information about our conflicts of interest policy is available on request.

DATA PROTECTION – CONFIDENTIALITY
Rafter Associates Financial Management Ltd (RAFM Ltd) is a data controller, registered in accordance with the Data Protection Act 2018. We undertake at all times to comply with the provisions of this Act and to keep confidential all personal data and sensitive personal data maintained for the purposes of this agreement. Steps will be taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary. Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to the data. We confirm that this information will not be used or transferred by us to any other firm, company, entity or person (other than the product provider) without your consent, or as may be required by law. We may also provide information to the FCA and other regulatory authorities upon request. We cannot be held responsible for the information held on your file becoming inaccurate due to your change of circumstances if you fail to inform us of those changes.

MONEY LAUNDERING
We are required to verify your identity in accordance with the Proceeds of Crime Act 2002 and The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2019. We reserve the right to approach third parties and to delay any of your applications until adequate verification of identity

has been obtained.

YOUR DATA PROTECTION RIGHTS
This is to inform you of the rights which you have under the General Data Protection Review which come into effect on 25th May 2018.

Your rights have not changed substantially from those which you enjoyed previously but there is greater emphasis in various areas not least, that you should be aware of exactly what your rights are. You have a right:

To be informed. Of any matters pertaining to your business relationship with ourselves. To have access. To any information we hold, however it is held, which relates to you as a data subject
To rectification. Of any information we hold in relation to yourself, if it is incorrect. This includes information which we may have passed on to other entities in which case it is our responsibility to ensure that it is rectified.
To erasure. Of any personal data relating to you as a data subject which we may hold. In other words, you may withdraw your consent for us to hold data about you.
To restrict processing. This is only likely to occur if you contest the accuracy of information we hold or our processing of it is unlawful but you oppose erasure.
To data portability. This is a new right you have. It allows you to obtain and reuse your personal data for your own purposes across different services. You should be able to transfer data easily from one IT environment to another in a safe and secure way without hindrance to usability.
To object. To the processing of your data, if you have legitimate reasons. To your data being used in a direct marketing exercise or to your data being used for researching or statistical purposes.
Not to be subjected to automatic decision making including profiling. We do not have any automatic decision making tools. With RAFM you always deal with real people!
CLIENT CONSENT
This is our standard Terms of Business and Client Agreement upon which we intend to rely.

For your own benefit and protection, you should read these terms carefully. If you do not understand any point, please ask for further information.

This Terms of Business and Client Agreement is effective immediately.

Spring Fields, 9 Spring Hill Farm, Harborough Road, Pitsford, Northamptonshire, NN6 9AA Tel: 01604 889073

Authorised and Regulated by the Financial Conduct Authority