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. 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. We(1) We deposit any funds paid by you into our trust account, in the course of carrying on insurance distribution, handle client money which is an account operated in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy part 7.8 of the CASS rules Corporations Act. (2) All money paid to us by you or a person acting on your behalf, or which is available received by us on requestbehalf of you, will be held by us in one or more segregated trust accounts with an Australian ADI or an approved foreign bank. Such segregation of your money does not protect your money from the risk of loss arising from Xxxxxxx’s inability to pay back part or the full amount owed to you. These moneys do not constitute a loan to us and are held on trust by us. You agree and acknowledge that individual Accounts of our clients are not separated from each other within the segregated trust accounts operated by us and that your moneys may be co-mingled with our other clients’ moneys, and that we will not be liable for the insolvency or any act or omission of any ADI holding the trust accounts. Furthermore, you understand the possible risks of this as explained in the PDS, that you have received or downloaded. (3) Unless expressly notified, we shall deem you to be a retail client. We handle reserve the right to review your account and reclassify you as a wholesale client at our absolute discretion. We will not use retail client money to margin, guarantee, secure, transfer, adjust or settle dealings in either one derivatives by us or on behalf of the following wayspeople other than you. Generally, both we only use house funds as collateral or margin with our hedging counterparties. However, this does not limit our right to use wholesale client money (apart from sophisticated investor funds) to margin, guarantee, secure, transfer, adjust or settle dealings in derivatives by us or on behalf of which are described in more detail below:people other than you. i. it is held on (4) 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 client money may only 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 withdrawn from the segregated client 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 (a) where you are entitled to the premium as cleared money and have submitted a valid, written request to withdraw the funds from You that has been accepted by us; (b) where a fee or from charge or interest has accrued on your account with us; (c) where required by law or in compliance with the Operating Rules of a third-party premium finance provider on Your behalf)licensed market; and ii(d) where you have accrued a realised trading loss on your account. Where the withdrawal is for any liability owed towards Mitrade, we reserve the right to withdraw that amount at any time, in our sole discretion. (5) Positions are marked-to-market with payments being settled daily to account for market movements. This means that the aggregate net unrealised and realised profit accruing to clients shall be transferred into the client trust account as at the point end of each business day. You also authorise and consent to the aggregate net unrealised and realised client loss to be transferred out of the client trust account by Xxxxxxx. Mitrade reserves the right to withdraw funds to which it is entitled from the client trust account at which their leisure. (6) Under the commission becomes due ASIC Client Money Reporting Rules, we are required to comply with various record-keeping, reconciliation and payable reporting obligations in relation to Us the retail and sophisticated client money held in the client money trust. Under these rules, we must: (a) Keep records of retail and sophisticated client money received and retain such records for Our own account provided this is consistent 7 years; (b) Perform a daily and monthly reconciliation of the retail and sophisticated client money on our accounts with the terms of actual retail and sophisticated client money held in the client money trust; (c) Notify ASIC within 5 business days if we identify a breach of the insurer ASIC Client Money Reporting Rules or if a discrepancy is identified by the reconciliation; (d) Xxxxx with ASIC an annual director’s declaration and an external auditor’s report on our compliance with the ASIC Client Money Reporting Rules within 4 months of the end of our financial year; and (e) Establish, implement and maintain policies and procedures designed to whom ensure our compliance with the premium is payable. Until that point commission will ASIC Client Money Reporting Rules. (7) Once withdrawn from the client money trust account, monies shall accordingly be treated as the legal and beneficial property of Mitrade, subject to an obligation by Mitrade to transfer an equivalent back to Client in accordance with their rights under this Client Agreement. (8) Whilst we remain ultimately responsible for the client money segregation, protection and handling of the client money, certain functions unrelated to the provision of financial services are handled by our subsidiary company (Mitrade Services Ltd) or our parent company (Mitrade Group Pte Ltd) in certain jurisdictions. 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 moneyThese services include payment processing.

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 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 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 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(1) We deposit any funds paid by you into our trust account, which is an account operated separately from our own house funds account. (2) All money paid to us by you or a person acting on your behalf, or which is received by us on behalf of you, will be held by us in one or more segregated trust accounts with an approved bank. Such segregation of your money does not protect your money from the risk of loss arising from Mitrade’s inability to pay back part or the full amount owed to you. These moneys do not constitute a loan to us and are held on trust by us. You agree and acknowledge that individual Accounts of our clients are not separated from each other within the segregated trust accounts operated by us and that your moneys may be co-mingled with our other clients’ moneys, and that we will not be liable for the insolvency or any act or omission of any banks holding the trust accounts. Furthermore, you understand the possible risks of this as explained in the course of carrying on insurance distributionRisk Disclosure Notice, handle that you have received or downloaded. (3) Unless expressly notified, we shall deem you to be a retail client. We reserve the right to review your account and reclassify you as a different client classification (e.g. professional client) at our absolute discretion. We will not use client money to margin, guarantee, secure, transfer, adjust or settle dealings in accordance derivatives by us or on behalf of people other than you. Generally, we only use house funds as collateral or margin with the FCA Client Assets Sourcebook our hedging counterparties. (CASS4) rules, which are designed to protect You. A copy of the CASS rules is available on request. We handle Your 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 only 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 withdrawn from the segregated client 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 (a) where you are entitled to the premium as cleared money and have submitted a valid, written request to withdraw the funds from You that has been accepted by us; (b) where a fee or from charge or interest has accrued on your account with us; (c) where required by law or in compliance with the Operating Rules of a third-party premium finance provider on Your behalf)licensed market; and ii(d) where you have accrued a realised trading loss on your account. Where the withdrawal is for any liability owed towards Mitrade, we reserve the right to withdraw that amount at any time, in our sole discretion. (5) Positions are marked-to-market with payments being settled daily to account for market movements. This means that the aggregate net unrealised and realised profit accruing to clients shall be transferred into the client trust account as at the point end of each business day. You also authorise and consent to the aggregate net unrealised and realised client loss to be transferred out of the client trust account by Mitrade. Mitrade reserves the right to withdraw funds to which it is entitled from the client trust account at which their leisure. (6) We are required to comply with various record-keeping, reconciliation and reporting obligations in relation to all client money held in the commission becomes due client money trust bank account. Under these rules, we must: (a) Keep records of retail and payable to Us sophisticated client money received and retain such records for Our own account provided this is consistent 7 years; (b) Perform a daily and monthly reconciliation of the retail and sophisticated client money on our accounts with the terms of business actual retail and sophisticated client money held in the client money trust; (c) Notify CIMA if we identify a breach of the insurer client money segregation or if a discrepancy is identified by the reconciliation; (d) Establish, implement and maintain policies and procedures (7) Once withdrawn from the client money trust account, monies shall accordingly be treated as the legal and beneficial property of Mitrade, subject to whom an obligation by Mitrade to transfer an equivalent back to Client in accordance with their rights under this Client Agreement. (8) Whilst we remain ultimately responsible for the premium is payable. Until that point commission will remain client money segregation, protection and handling of the client money, certain functions unrelated to the provision of financial services are handled by our affiliated company (e.g. Mitrade Global Pty Ltd, Mitrade Services Ltd) or our parent company (Mitrade Group Pte Ltd) in certain jurisdictions. 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 moneyThese services include payment processing.

Client Money. We24.1. Client money rules and authoriza�ons All money paid to us by you or a person ac�ng on your behalf, or which is received by us on behalf of you, will be held by us in one or more segregated bank accounts. These moneys do not cons�tute a loan to us. You agree and acknowledge that individual Accounts of our clients are not separated from each other within the segregated trust accounts operated by us. Furthermore, you understand the possible risks of this as explained in the course policies, that you have received or downloaded 24.2. Investment of carrying on insurance distribution, handle client moneys held We may invest any of your money held in any segregated trust account as permi�ed by the Client Money Rules and you irrevocably and uncondi�onally authorize us to undertake any such investment. 24.3. Treatment of investment capital and interest Unless otherwise agreed in wri�ng with you: (a) We are solely en�tled to any interest or earnings derived from your moneys being deposited in a segregated trust account or invested by us in accordance with the FCA Client Assets Sourcebook Money Rules with such interest or earnings being payable to us from the relevant segregated trust account or investment account, as the case requires as and when we determine; (CASSb) rulesUpon realiza�on of an investment of your moneys, which are designed the ini�al capital invested must either be invested in another investment permi�ed by the Client Money Rules or deposited by us into a segregated trust account operated in accordance with the Client Money Rules; (c) In the event that the amount received upon realiza�on of an investment of your moneys is less than the ini�al capital invested, we must pay an amount equal to protect You. A copy the difference into a segregated trust account for the benefit of you, except where any such difference is the result of amounts paid out of the CASS rules investment to us and/or any Associate of ours in accordance with the terms and condi�ons of this Agreement; (d) We will not charge a fee for inves�ng your moneys in accordance with the Client Money Rules. 24.4. Property held on trust If property, other than money, is available given to us by you or a person ac�ng on requestyour behalf, or for your benefit, it must be held by us on trust in accordance with the Client Money Rules. 24.5. We handle client money You authorize us to deal with your account You irrevocably and uncondi�onally authorize us and/or any Associate of ours to: (a) Withdraw, deduct or apply any amounts payable by you to us and/or any Associate of ours under this Agreement from your moneys held in either one any segregated trust account or invested by us, including, without limita�on making a payment for, or in connec�on with, the margining, adjus�ng or se�ling of dealings in Margin Contracts or CFDs entered into by you or the following wayspayment of interest or charges to us, both it being acknowledged and agreed by you that such amounts belong to us under this Agreement and may be used by us in our business from �me to �me, including for the payment of which are described amounts to our counterpar�es; (b) Pay, withdraw, deduct or apply any amounts from your moneys held in more detail belowany segregated trust account or invested by us as permi�ed by the Client Money Rules, it being acknowledged and agreed by you that any such amounts that belong to us may be used by us in our business from �me to �me, including for the payment of amounts to our counterpar�es; (c) Deal with any property, other than money, given to us in accordance with the terms and condi�ons of this Agreement, including, without limita�on: i. it is held Dealing with such property in connec�on Your behalf with the margining, adjus�ng or se�ling of dealings in a segregated bank account that is subject to a non-statutory trust; Margin Contracts or CFDs entered by you: or ii. it is held by Us as agent of the relevant insurer (“risk transfer”). The aim of the trust is Selling or charging in any way any or all your property which may from �me to protect You �me be in the event possession or control of Our financial failureus or any of our Associates following the happening of a Specified Event; (d) Deal with any property, 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 other than money, given to us 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 permi�ed 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 moneyClient Money Rules.

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. 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. 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. 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 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 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 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. We(1) We deposit any funds paid by you into one or more segregated accounts, in the course of carrying on insurance distribution, handle client money which are operated in accordance with the FCA Client Assets Sourcebook (CASS) rules, which are designed to protect You. A copy part 7.8 of the CASS rules Corporations Act. (2) All money paid to us by you or a person acting on your behalf, or which is available received by us on requestbehalf of you, will be held by us in one or more segregated trust accounts with an Australian ADI or an approved foreign bank. We handle Such segregation of your money does not protect your money from the risk of loss arising from Xxxxxxx’s inability to pay back part or the full amount owed to you. These moneys do not constitute a loan to us and are held on trust by us. You agree and acknowledge that individual Accounts of our clients are not separated from each other within the segregated trust accounts operated by us and that your moneys may be co-mingled with our other clients’ moneys, and that we will not be liable for the insolvency or any act or omission of any ADI holding the trust accounts. (3) You acknowledge and agree that we have the right to use wholesale client money (apart from sophisticated investor funds) to margin, guarantee, secure, transfer, adjust or settle dealings in either one derivatives by us or on behalf of the following ways, both of which are described in more detail below:people other than you. i. it is held on (4) 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 client money may only 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 withdrawn from the segregated client 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 (a) where you are entitled to the premium as cleared money and have submitted a valid, written request to withdraw the funds from You that has been accepted by us; (b) where a fee or from charge or interest has accrued on your account with us; (c) where required by law or in compliance with the Operating Rules of a third-party premium finance provider on Your behalf)licensed market; and ii(d) where you have accrued a realised trading loss on your account. Where the withdrawal is for any liability owed towards Mitrade, we reserve the right to withdraw that amount at any time, in our sole discretion. (5) We are entitled to invest the point at which the commission becomes due and payable to Us for Our own money in our trust account provided this is consistent in accordance 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 Corporations Act 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 intermediaryCorporations Regulations including in: (a) Investments in any manner in which we are, for the purpose time being, authorized to invest in; (b) Investments on deposit with any eligible money market dealer (c) Investments on deposit at interest with any Australian ADI (d) The acquisition of effecting cash management trust interests (e) Investment in a transaction through that person. Where We transfer client money that is subject to security issued or guaranteed by the Commonwealth or a non- statutory trust, to another person, We will remain liable to You for such money for as long as it remains client money.state or territory; and/or (f) Investment on deposit with a clearing and settlement facility (6) Unless otherwise agreed in writing with you:

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.