Compliance Policies

Compliance Policies Anti Money Laundering .................................................................................................... 5 Introduction ........................................................................................................................... 5 MBS Policy Statement ........................................................................................................... 5 Money Laundering ................................................................................................................ 6 Application of Policy ............................................................................................................. 7 MBS and Anti-Money Laundering ........................................................................................ 9 Knowing Your Customer ....................................................................................................11 Responsibilities and Obligations ....................................................................................... 11 Anti-Money Laundering Procedures .................................................................................12 International Sanctions ......................................................................................................14 Suspicious Activities ............................................................................................................15 Training, awareness, advice and guidance .......................................................................15 Money Laundering Reporting ............................................................................................ 16 Records ................................................................................................................................ 16 Examples of Suspicious Activity ......................................................................................... 16 Policy Review ....................................................................................................................... 18 Complaints Policy ............................................................................................................ 19 Complaint Definition:..........................................................................................................19 Complaint Handling: ...........................................................................................................20 Complaints Procedure: .......................................................................................................21 Complaint Timescales:........................................................................................................21 Redress: ............................................................................................................................... 23 Record Keeping: ..................................................................................................................23 Responsibilities ...................................................................................................................24 Short Complaints: ...............................................................................................................24 Investigating a Complaint...................................................................................................25 Waiving Time Limits: ...........................................................................................................27 Closing a Complaint: ...........................................................................................................28 Momentum Broker Solutions Limited, Press House, Narborough Wood Park, Desford Road, Enderby, Leicester LE19 4XT. Momentum Broker Solutions Limited is authorised and regulated by the Financial Conduct Authority. Momentum Broker Solutions is a limited company registered in England & Wales No 07267159

Referring a Complaint to a Third Party: ............................................................................28 FOS Referral:........................................................................................................................ 28 Conflicts of Interests ....................................................................................................... 30 Introduction ......................................................................................................................... 30 Regulatory Background ......................................................................................................30 MBS’ Policy Statement ........................................................................................................32 Our Framework ...................................................................................................................33 Insurance Distribution and Conflicts of Interest .............................................................. 34 Application of Policy ...........................................................................................................34 High-Level Standards ..........................................................................................................35 Managing Conflicts of Interest ........................................................................................... 35 Management Information ..................................................................................................38 Reporting and Record Keeping .......................................................................................... 38 Training, Advice and Further Questions ...........................................................................39 Conflicts of Interest Notification Form ..............................................................................40 Financial Crime ................................................................................................................ 41 Introduction ......................................................................................................................... 42 Policy Statement .................................................................................................................42 Application of Policy ...........................................................................................................44 Financial Crime ....................................................................................................................45 MBS’ Inter-Related Financial Crime Policies......................................................................45 Knowing your customer .....................................................................................................46 Responsibilities and Obligations ....................................................................................... 46 Training, advice and further guidance ..............................................................................47 Money Laundering reporting, Anti Bribery and Data Protection Officer ....................... 48 Records ................................................................................................................................ 48 Whistle Blowing Policy .................................................................................................... 50 What is Whistle Blowing: ....................................................................................................52 What does this policy cover: .............................................................................................. 53 Which procedure should I use? ......................................................................................... 54 Where can I get independent advice? ...............................................................................54 Responsibilities ...................................................................................................................54 How do I go about raising a concern ................................................................................55

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Raising your concern externally ........................................................................................ 55 What sort of response can I expect from the organisation? ...........................................56 What happens if I’m implicated?........................................................................................ 56 Confidentiality .....................................................................................................................56 What takes place during an investigation? .......................................................................57 What happens after the investigation? .............................................................................57 Where can I obtain further information ...........................................................................57 Breaches and Issues Policy ............................................................................................. 58 Policy Statement .................................................................................................................58 What is a breach? ................................................................................................................58 Material breaches ...............................................................................................................59 Non-material breaches .......................................................................................................59 What is an issue? .................................................................................................................59 Reporting breaches and issues.......................................................................................... 60 Process One - Breaches and Issues relating to all matters other than data protection / security and the Conduct Rules. ........................................................................................ 60 Process Two - Breaches and Issues relating only to the Conduct Rules. ....................... 62 Process 3 – All matters relating only to data protection / security. ................................ 65 Significant and material breaches .....................................................................................68 AR Business partners..........................................................................................................69 Press and publicity ..............................................................................................................69 The police ............................................................................................................................ 69 MI and root cause analysis.................................................................................................69 Contract Certainty Policy ............................................................................................... 70 Introduction ......................................................................................................................... 70 Scope of Policy ....................................................................................................................70 Policy Statement .................................................................................................................71 Application of Policy ...........................................................................................................78 Training, Advice and Guidance .......................................................................................... 78 Record Keeping ...................................................................................................................78 Policy Review ....................................................................................................................... 78 INDEX ................................................................................................................................ 79 Policy Statement: ................................................................................................................79

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History of changes to this document ................................................................................79

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Anti Money Laundering Introduction Money Laundering Regulations were first introduced in the UK in 1993, with the aim of preventing criminals from being able to use the financial system to conceal the origins of criminal proceeds.

The FCA have confirmed that general insurance brokers are not subject to their AntiMoney Laundering (AML) rules as the majority of insurance products do not deliver sufficient functionality to be the first choice of vehicle for the money launderer. However, all firms have a regulatory requirement under SYSC to have proportionate systems and controls to enable them to identify, assess, monitor and manage the risk of being involved in money laundering or fraudulent transactions.

Nonetheless, we are subject to a legal requirement to identify and report suspicious transactions under Proceeds of Crime Act (2002) (POCA) and the Terrorism Act 2017.

The purpose of this policy and procedure is to ensure that MBS mitigates the risk that is used by criminals for money laundering purposes.

MBS has taken a risk-based approach to the development of its anti-money laundering policy and procedures, and has therefore set out different controls according the risks posed by its business operation.

This means MBS’ money laundering procedures are specific and applies to all MBS employees and is ARs. The policy considers the scale of financial services activities and the nature and complexity of the MBS business and its AR’s.

The Proceeds of Crime Act 2002 (as amended) (POCA) sets out a series of criminal offences in relation to money laundering. There is a maximum sentence that could be applied to any individual for the offence of money laundering of 14 years and/or an unlimited fine.

The establishment of this policy enables MBS to fulfil its regulatory and legislative obligations.

MBS Policy Statement MBS is committed to meeting its obligations for the prevention of money laundering required by the Proceeds of Crime Act 2002 (and associated legislation) and as highlighted in the FCA Handbook under Systems and Controls (SYSC 6):

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“A firm must establish, implement and maintain adequate policies and procedures sufficient to ensure compliance of the firm including its managers, employees and appointed representatives with its obligations under the regulatory system and for countering the risk that the firm might be used to further financial crime.”

In other words: The aim of this policy is to prevent the proceeds of crime from being placed in the financial system through MBS and to detect suspicious transactions and report them to the authorities.

MBS requires the business and its AR’s and anyone operating on behalf of MBS to abide and operate in accordance with certain policies and procedures and our systems of control.

This ensures that all employees and MBS AR’s meet all appropriate compliance obligations. MBS shall monitor its compliance with those controls and deal with any matters identified in accordance with this policy and/or MBS Breaches policy and procedures or similar as required.

Money Laundering This policy applies to compliance with all MBS company and FCA rules, principles, policies, procedures, guidance, standards and other applicable regulations to MBS employees e.g. the Proceeds of Crime Act. Money Laundering is the process by which criminals attempt to hide and disguise the true origin and ownership of the proceeds of their criminal activities as ‘clean’ money or other assets with no obvious link to their criminal origins. (The legal definition of money laundering for the purposes of UK legislation is contained in the Proceeds of Crime Act 2002).

Money laundering activity includes: • Acquiring, using or possessing criminal property • Handling the proceeds of crimes such as theft, fraud and tax evasion • Being knowingly involved with criminal or terrorist property • Entering into arrangements to facilitate laundering criminal or terrorist property • Investing the proceeds of crimes through the acquisition of property/assets • Transferring criminal property The objectives of Money Laundering are to: • Disguise the source of the property/cash • Disguise the criminal’s identity • Conceal the ownership of the property • Retain an element of control of the property Anti Money Laundering

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• • •

Avoid detection and forfeiture Benefit securely Possibly fund other criminal activity

There are three stages in the money laundering process: I. Placement: the physical distribution of the proceeds (e.g. depositing ‘dirty’ cash with someone to launder II. Layering: involves carrying out multiple and often complex financial transactions, with the specific intention of hiding the original source of illegal deposits III. Integration: returning the ‘cleansed’ funds to the criminal, often in the form of physical assets, via what appears to be a legitimate transaction The main offences are: • Money laundering offences of concealing, arranging or acquiring the proceeds of crime: maximum penalty 14 years imprisonment and/or fine • The offence of failure to report knowledge or suspicion of money laundering: maximum penalty 5 years imprisonment and/or fine • The offence of destroying or disposing of documents which are relevant to an investigation: maximum penalty 5 years imprisonment and/or fine • Tipping off/prejudicing an investigation by informing the subject, or any third party, of a suspicion, that a disclosure has been made or that the authorities have received a suspicious transaction report and are acting or proposing to act or investigate: maximum penalty 5 years imprisonment and/or unlimited fine Realisation Once the money laundering process is completed the ultimate goal is to realise the money and for the criminal to spend their gains.

MBS’ Anti-Money Laundering controls are part of MBS’ commitment to treating customers fairly (TCF) and ensuring good outcomes for our customers, as ultimately all customers pay for the consequences of illegal transactions and are either directly or indirectly affected by the criminal activity from which the proceeds of crime or terrorist financing are generated.

Application of Policy MBS Money Laundering policy applies to all MBS employees’ external consultants, contractors and temporary personnel while working for MBS and its AR’s including their respective permanent and short-term employees.

All individuals should be aware and alert about Money Laundering and assessing suspicious behaviour associated with money laundering.

Ultimately everyone is responsible for reporting suspicious activity and where necessary that they collect sufficient ‘know your customer’ information. It is everyone’s responsibility to identify and recognise such and seek guidance from MBS’ Money

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Laundering reporting office and/or Operations Director or Quality and Compliance Director.

MBS takes a risk-based approach to anti-money laundering which is proportionate to the size of the risk which we identify, therefore allowing us to direct resources to cover the main identified risks applicable to our business.

In assessing our money laundering risk, we have examined 4 main areas: Customer Risk Different customer profiles could have different levels of risk attached to them. All customers are subject to our standard due diligence procedures which include a full customer fact find and Sanctions and PEP checks.

We carry out a fact find before the sale of any insurance product to determine the customers demands and needs for the product and the majority of premium transactions are not made in cash.

We have therefore assessed that our general insurance customers are generally of a low risk.

We do however acknowledge that on occasion we may receive requests from customers which pose a higher potential threat of money laundering and would be perceived as being higher risk exposure, for example: • a customer who is not known to us and wants to pay a lump sum cash for an insurance premium that sits outside of our cash handling policy; or a customer who has complex insurance needs which requires changing the insurance risk by vehicle, cover, use, etc. on a regular basis and insisting on paying cash.

Product Risk This is the risk posed by the product or service itself. The product risk is driven by its functionality as a money laundering tool.

The Joint Money Laundering Steering Group has categorised the products with which firms typically deal into three risk bands – reduced, intermediate and increased.

Typically, pure protection insurance and general insurance contracts are categorised as reduced risk. We have therefore categorised our product risk as low risk due to the following: • •

We carry out a fact find before the sale of any insurance product to determine the customers’ demands and needs for the product.

Any claims payments made are subject to a formal claims handling and investigation process.

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•

Where changes to insurance policies are requested these are validated through a fact find process to determine the customers demands and needs.

Interface Risk Relationships where a customer makes face-to-face contact with us can be perceived to carry less risk as this presents an opportunity for us to verify that the client’s identity documents are of true likeness to the client.

Business conducted at a distance in a non-direct manner can result in an increased exposure of risk through impersonation. In order to mitigate this risk where enhanced customer due diligence procedures apply we request original copy identification to be forwarded and return this by Recorded Delivery to the client.

Country (territorial) Risk The geographic location of the client or origin of the business activity has a risk associated with it, this stems from the fact that countries around the globe have different levels of risk attached to them.

As we deal only with customers within the UK we have assessed the country risk as being as low risk

MBS and Anti-Money Laundering This policy set’s out MBS’ policy and procedures to enable all individuals to take responsibility for effectively managing the money laundering risks faced by MBS and comply with the money laundering controls as detailed within this policy and supporting procedures.

In addition, we explain how to access MBS’ Senior Manager who has overall responsibility for fulfilling the role of Money Laundering Reporting oversight and how to report and deal with any suspected or actual money laundering incident in accordance with the direction and requirements of board.

As part of our induction process all staff receive training in relation to identifying and reporting suspicious activity transactions generally. We also give all staff and AR’s annual refresher training about anti-money laundering.

Below is a list (which is not exhaustive) of suspicious transaction indicators: • Clients who are reluctant to provide proof of identity if requested in accordance with our cash handling procedures.

• Dealing with customers outside our normal geographical area who are not known to us or have links via other customers particularly if such individuals wish to pay in cash.

• Where the source of funds is unclear.

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• •

• • • •

Where there is no apparent insurable interest.

Customers purchasing/hiring and returning multi vehicles in order to create confusion then requesting refunds of premiums to be paid in cash or to other individuals or organisations.

Payment by a card not in their name and/or a transaction made by a third party (linked to Financial Sanctions).

Unsatisfactory documentation received in response to due diligence requests.

Use of false addresses or post office boxes.

Known criminal or relative/ associate of known criminal.

Where you suspect that we are dealing with a suspicious transaction, you must take the following steps: • If appropriate, refer to your line manager but not in a manner that would alert the customer to the fact you have knowledge or are suspicious of money laundering (tipping off) or any other suspicious activities.

• Do not discuss your suspicions with anyone within or outside the office who is not authorised to deal with such concerns.

• You should report in confidence to Operations Director or Quality and Compliance Director and agree a course of action which may include gaining supplementary information or where appropriate taking over the transaction.

• Operations Director or Quality and Compliance Director will acknowledge in writing to you that they will undertake an investigation and that you have fulfilled your obligation by reporting the suspicion.

• Operations Director or Quality and Compliance Director will undertake a thorough investigation and make any appropriate report of the suspicious event, even if the business is not taken up.

The report will include: o Details of all parties to the transaction o How the identity of the client was verified [where applicable] o A full description of the transaction o Reasons for suspicion and supporting evidence i. ii.

iii.

Internal logging and notification to MBS’ Board will be made of the suspicion.

The matter will be reported within 7 days to the National Crime Agency (NCA).

Information regarding reporting is found on www.nationalcrimeagency.gov.uk. All correspondence will be kept for 5 years.

If a requirement of the regulator, the FCA/ MoJ/ Finance House/Insurers/Police must be notified, notification will be made by Operations Director or Quality and Compliance Director.

As part of our staff training it is made clear that any failure to comply with this policy may result in disciplinary measures being taken.

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All senior personnel within the business will, at all times, support this policy and will not seek to influence any member of staff to behave in a manner which has the potential to allow the occurrence of money laundering.

Knowing Your Customer One of the best ways to prevent money laundering is to prevent money being placed in the financial system in the first place. One way of preventing criminals from accessing the financial system is to verify their identity and thus help prevent them disguising the source of criminal proceeds.

The risk of money laundering through general insurance products and services may not be as great as investment business due to the short duration of policies and the inability to access payments made for insurance cover which is not refundable.

A risk-based approach to KYC is therefore appropriate to take account of the circumstances surrounding the customer, the type of policy, the amount and method of payment.

For example, a consumer customer holding a UK bank account will have provided identity verification before opening the account and so a cheque, direct debit or credit card payment would be reasonable to accept for a consumer customer (unless specific dealings with that particular consumer customer give rise to suspicion, such as payment using another individuals card who is unavailable to authorise the transaction).

However, where payments are made in cash, further customer identity checks must be carried out.

For a commercial customer a company check will be carried out to verify the identity of the relevant firm.

In short, a commercial customer must be verified by either searching the relevant company registry or confirming the company’s listing on a regulated market

Responsibilities and Obligations MBS’ obligations (Proceeds of Crime Act 2002) In short, all individuals must: • not knowingly assist in concealing money laundering (14 years and/or an unlimited fine for knowingly assisting) • report suspected and actual money laundering (5 years and/or an unlimited fine for failing to report) • not tip off a money launderer or otherwise prejudice a money laundering investigation (5 years and/or an unlimited fine for ‘tipping off’) and

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•

not destroy or dispose of relevant documents (5 years and/or an unlimited fine for destruction of relevant documents).

The Proceeds of Crime Act 2002 (as amended) (POCA) sets out a series of criminal offences in relation to money laundering with a maximum sentence for the offence of money laundering of 14 years and/or an unlimited fine.

General Principles: • not refund premium overpayments or cancellations to another party without an explanation why the payment is being made to another party other than the policyholder.

If the explanation is satisfactory, authority must be sought before payment is made from a senior manager or director for amounts of less than £ 5,000; and from MBS’ Operations Director or Quality and Compliance Director for amounts of £5,000 or more • not ignore knowledge or suspicion of any money laundering • not “tip off” a money launderer, or prejudice an investigation into money laundering if a disclosure has been made (a party should never be informed of any suspicions or reports made) • not conceal, disguise, convert, transfer or remove criminal property where they suspect that there has been money laundering • not accept a customer or introduction if they know or suspect (by whatever means) the acquisition, retention, use or control of criminal property (i.e. the source of the funds may come from drug trafficking, terrorism, organised crime, fiscal crime (e.g. VAT fraud, carousels and the like) or other criminal activity) • not have dealings with or make payments to introducers or representatives who have not been fully vetted and do not remain fit and proper to do business with • Individuals MUST not take any further action, after making a report to the Operations Director or Quality And Compliance Director, unless otherwise required by the

Anti-Money Laundering Procedures As an insurance broker we are not subject to FCA Anti-money laundering regulations and are not required to appoint a Money Laundering Reporting Officer, however we are required to allocate responsibility for our Anti-money laundering systems and controls and reporting of suspicious activity. Hazel Westwood – Operations Director is the Senior Manager who has this responsibility and is supported by Steve Walton – Quality and Compliance Director.

This section details the specific procedures that apply to all individuals dealing with customers who wish to place insurance business through MBS and its AR’s or anyone acting on behalf of MBS.

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Remember it is everyone’s responsibility to be aware and alert about Money Laundering and assessing suspicious behaviour associated with money laundering and to seek guidance from MBS’ Money Laundering reporting office and/or Operations Director or Quality and Compliance Director Accepting a Consumer Customer The FCA’s definition of a consumer customer is “any natural person who is acting for purposes which are outside his trade or profession”, and The Consumer Insurance (Disclosure and Representations) Act 2012 (CIDRA) definition that came into force 6 April 2012 is "an individual who enters into the contract wholly or mainly for purposes unrelated to the individual's trade, business or profession".

No checks required for: Accepting cheques, direct debits or credit or debit card payments where the card holder or individual providing the instruction is the one and same as the individual incepting the Insurance policy.

Check required for: Implicit consent (you must speak to and if necessary obtain written consent) to accept direct debits or credit card payments where the card holder or individual providing the instruction is not the same as the individual incepting the Insurance policy.

You must verify the identity when accepting cash. Two documents, one from the personal identification list and one from the address verification list must be provided: Personal identification - one item: • Current full signed UK/EU passport • Current UK full or provisional photo-card Driving Licence • Current UK full (old style) Driving Licence (provisional not acceptable) with paper counterpart as applicable • Firearms certificate or shotgun licence • Inland Revenue Tax notification or demand or assessment (less than 12 months old) • Letter from Benefits Agency confirming entitlement to benefits or state pension Address verification - one item: • Council Tax bill or statement (valid for current year) • Utility bill or statement issued/ dated in the last three months/current year for water bills (mobile phone statements are not accepted) (internet prints are not accepted) • Bank/Building Society/National Savings statement or passbook containing current address (issued/dated in the last three months) (internet prints are not accepted) If the client has lived at their current address for less than three months they must also provide one additional item from the address list above that shows their previous address.

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If the customer does not possess any of the identification documents detailed above you must contact MBS’ Operations Director or Quality and Compliance Director.

Accepting a Commercial Customer The FCA’s definition is “a commercial customer is a customer who is not a consumer”.

Under the Insurance Conduct of Business Rules (ICOBS), an individual acting both as a consumer and in a commercial capacity must be treated as 'commercial customer.

Commercial customers must provide: • Full name of the company • Registered number • Registered office in the country of incorporation • Business address Contact number Additionally, for private companies: • Names of all Directors or Board Members • Names of beneficial owners holding over 25% Credit Check and Company Search: You must conduct a credit check using MBS’ approved credit checking source and check the companies listing by either searching the relevant company registry (Companies House) or confirming the company’s listing on a regulated market.

International Sanctions In particular MBS’ obligations and arrangements expects adherence with international sanction requirements.

So far as it is relevant to Anti-Money Laundering (AML) international sanctions compliance, there is an expectation for MBS to incorporate comprehensive international sanctions procedures within a risk-based approach which is proportionate to the risks presented.

These procedures include: • Appropriate due diligence • Screening against appropriate sanctions target lists to ensure risk related to any persons or entities identified positive are not underwritten, including but not limited to: o Her Majesties Treaty (HMT) Consolidated Lists o Other Financial Sanctions Lists relevant to MBS o Office of Foreign Assets Control (OFAC) the financial intelligence and enforcement agency of U.S. treaty, where relevant.

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•

•

Follow internal procedure strictly, when processing payment of claims, refunds, to persons or the benefit to whom payment is being made and immediately report any suspicious activity in accordance with section 9 and Ensure sanctions compliance procedures are properly recorded, regularly audited and updated, including ensuring all MBS staff are appropriately trained on the use of sanctions procedures.

Suspicious Activities All individuals are responsible for reporting suspicious activity and where necessary collecting sufficient ‘know your customer’ information in reporting suspicions to the Operations Director or Quality and Compliance Director.

At any stage of either accepting and monitoring customers transactions if you suspect or recognise behaviour that may amount to money laundering, you must: • contact MBS’ Operations Director or Quality and Compliance Director immediately with details • create a full report (with as much information as possible) of the suspected or actual activity and send the completed report to the Operations Director or Quality and Compliance Director • ensure the customer is not informed of the report or given any indication of any suspicion • take no further action without instruction from the Operations Director or Quality and Compliance Director If at any time you require advice and guidance, please speak with MBS’ Operations Director or Quality and Compliance Director who will escalate the matters as necessary If you are not aware of how to contact the Operations Director or Quality and Compliance Director please speak to your Line Manager

Training, awareness, advice and guidance MBS provides training to all relevant individuals on Money Laundering including refresher training at least annually to ensure continuing awareness and details of any updates to the requirements.

All individuals are registered to access MBS’ e-learning arrangement managed by RWA Compliance Services Ltd. In the event that individuals are unable to gain access individuals have authority to contact RWA Compliance Services limited directly on 01604 709509 or helpdesk@rwagroup.co.uk.

In addition, as a matter of good practice in corroboration with RWA Business Consultancy Ltd, MBS will regularly horizon scan market news (including quarterly material issued by the FCA) for impact and relevance to ensure current relating market issues are

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highlighted and communicated as may be necessary to ensure continued on-going and up-to-date focus on money laundering and wider financial crime related matters.

All individuals can access wider information on market news at https://insight.rwabusiness.com

Money Laundering Reporting MBS has a Senior Manager who has overall responsibility for conducting the role of internal money laundering oversight and whose purpose is to control the day to day management of Money Laundering prevention.

The Operations Director or Quality and Compliance Director is free to act on their own authority and has adequate resources to devote to Anti-Money Laundering and Counter Terrorism; in addition, they will receive any reports submitted and make any external reports to the National Crime Agency ‘NCA’ as necessary.

The Operations Director or Quality and Compliance Director is the focal point and coordinator for all money laundering activity within MBS and is responsible for: • receiving and reviewing internal disclosures and making external reports • overseeing compliance with the AML Policy and Procedures and p • providing oversight of MBS’ requirements in respect of training • working closely with MBS’ Operations Director or Quality and Compliance Director

Records Centralised records are in place and include all Money Laundering notifications; these are maintained by the compliance team in conjunction with MBS’ Operations Director or Quality and Compliance Director.

MBS will in addition keep the records appertaining to customer identity and details of their transactions in accordance with the Data Protection Act and related regulations for a minimum of 7 years after the cessation of the customer relationship.

Records demonstrating the adequacy of MBS’ systems and controls on money laundering detection and prevention will also be kept for a minimum of 7 years.

In addition, further details can be found in MBS’ Records Management policy which sets out policy more generally including all other minimum retention periods.

Examples of Suspicious Activity Suspicions may not fit into any pre-defined situation or circumstance. MBS’ policy requires staff to report any suspicious circumstances to the Operations Director Or Quality and Compliance Director who will decide whether to make internal or external reports as appropriate.

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Where a criminal is trying to launder money, they may not be concerned about losing money as a result, provided the laundering process is achieved and ‘clean’ money appears at the other end.

Here are some examples of extraordinary or unusual behaviours for all individuals to be aware of, please note this list is not exhaustive: New customer • The customer is more interested to know about the cancellation terms of the insurance contract, rather than its terms and conditions, main exclusions and benefits • The cover requested seems higher than is usual for this type of business (potential link to possible fraud) • A customer presents MBS with delays and problems when asked for documentation regarding their incorporation and copies of their accounts • A customer’s company has superior turnover and profit figures, out of line with the sector and there is no clear rationale why this is the case • A customer insists in paying in cash and enquires about the cash limits before any reports have to be made • A customer has offshore accounts or their holding company is offshore or arranged in a complex structure for no obvious purpose. There may be legitimate tax minimisation reasons though complex structures may create suspicions of ‘layering’ and or • A customer is attempting to make the insurance transaction via a third party for no apparent purpose.

Extraordinary Payments • The customer attempts to pay with cash, particularly on a policy that has a large premium, be cautious, specifically if this transaction would normally be made by cheque, credit and debit card or electronically • The customer is new and seems to focus on this insurance placement as a “one off” transaction rather than an on-going business relationship • The customer expects MBS to perform a transaction in secrecy, yet the insurance is not part of a due diligence transaction and or • A customer overpays their premium amount and then requests MBS to refund this to another party (see procedures).

Cancellation transactions you consider to be suspicious must be monitored and treated with caution: • The customer wishes to cancel the policy early for no obvious reason • The customer wishes to cancel the policy and requests payment to another party • The customer requests cancellation of a number of policies without reasonable explanation; and/or Anti Money Laundering

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There is a pattern of the customer regularly cancelling policies.

Some examples of suspicious activities that could indicate money laundering include, but are not limited to, the following: • The customer wishes to engage MBS in transactions that lack business sense or are inconsistent with the customers stated business strategy • The information provided by the customer that identifies the source of funds or wealth is false, misleading, or substantially incorrect • The customer exhibits a lack of concern regarding risks, commissions and other transaction costs, or basic internal financial controls • The customer appears to be acting as an agent for an undisclosed principal, but declines or is reluctant, without legitimate commercial reasons, to provide information or is otherwise evasive regarding that person or entity • The customer has difficulty describing the nature of his or her business or lacks general knowledge of his or her industry • Repeated overpayments of insurance premiums; and/or • Unusual early redemptions of insurance policies without regard for penalties or fees.

Policy Review This policy will be reviewed annually with any unscheduled reviews to take place where necessary as prompted by any event of significant change.

The review process for this policy will be led by the Individual Responsible for Compliance, reporting to the Board of Directors for final sign off and ratification of any required changes.

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Complaints Policy Approach: MBS places considerable importance on delivery good outcomes for our customers and we aim to demonstrate this through a fair and prompt resolution of any complaint.

Naturally, our aim is to provide a first-class service to all our customers. However, on some occasions we accept that, for whatever reason, we may fall short of customers’ expectations.

Not all complaints are related to an individual’s performance. However, as a business we must learn from our shortcomings and therefore need staff and our AR’s to report all elements of customer dissatisfaction in the knowledge and confidence that this will be handled in a way which is fair to both customer and member of staff or AR. All complainants should be handled with courtesy at all times, irrespective of whether you believe a complaint to be unjustified.

It is our view that if a complaint is handled fairly and professionally and is brought to a successful conclusion in a timely manner, the complaint can be turned into a compliment.

MBS understands that complaints are a key source of management information which allows the us to conduct structured analysis of complaint activity, The identification of complaint trends and root causes for complaints allows MBS to take appropriate mitigating action in adapting processes to ensure that future related complaint activity is minimised.

The quality of information entered onto the complaints register is vital to ensure that the business can continually improve and has the basis from which to provide accurate and timely reporting both internally and as required by the regulator.

Complaint Definition: The Financial Conduct Authority (FCA) defines a complaint as: “Any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service or a redress determination, which: (a) alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and (b) relates to an activity of that respondent, or of any other respondent with whom that respondent has some connection in marketing or providing financial services or products, which comes under the jurisdiction of the Financial Ombudsman Service.

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Momentum use the FCA’s definition of a complaint as the basis for identifying when a complaint has occurred.

The FCA defines an eligible complainant as: • A consumer (any natural person who is acting wholly or mainly for purposes which are outside his trade, business, craft or profession) • A ‘micro-enterprise’ employing fewer than 10 persons (i.e. 9 or less) with a turnover or annual balance sheet that does not exceed €2 million • A ‘small business’ (other than a micro-enterprise) with an annual turnover of below £6.5m, and less than 50 employees or with an annual balance sheet total of below £5 million • A charity with an annual income of less than £6.5 million • A trustee of a trust with a net asset value of less than £5 million If a member of staff or AR is in any doubt about the category into which a complainant falls, they should seek guidance from our Quality and Compliance Director.

To ensure we comply with all FCA complaint handling requirements we must follow the formal Complaints Procedure set out in this document.

Whether or not a complaint is defined as ‘eligible’ by the FCA is important because the Financial Ombudsman Service is only available to eligible complainants. However, we have chosen to follow this procedure for all complaints we receive, including those from non-eligible complainants, as we believe this is in the best interest of our customers.

Complaint Handling: A complaint cannot be handled by the person against whom the complaint is made. The complaint handler must be a senior member of staff. (See also, section entitled Complaints against Staff Members or the company’s representatives, below) All complaints received by us whether oral or written must be reported immediately to our Compliance Team. Any oral or written statement by a customer which might be considered a complaint must also be referred to the Compliance Team.

Reporting complaints and potential complaints means that the Compliance Team can determine whether the complaint is from an eligible complainant or not.

We are required to investigate a complaint ‘competently, diligently and impartially’ and we are also required to ‘obtain additional information as necessary’.

The Compliance Team will decide to whom the complaint should be allocated for review and response.

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Complaints Procedure: In relation to our internal complaints procedure, we must ensure that: A. a reference to the complaint handling procedures is included before the conclusion of the contract. This must explain how our customers can complain to us by telephone and /or in writing. If the insurance is sold by telephone, the complaints procedure must be forwarded to the client immediately (promptly) after the sale has concluded and always within 5 working days.

We achieve this by including our Terms of Business Document within our customer correspondence which contains full details of our complaints procedures. Details of the Financial Ombudsman Service are also drawn to the customer’s attention within the Terms of Business Document.

B. a copy of our complaints procedure is supplied to the customer upon request, and we must also ensure that a copy is automatically provided to the customer upon receipt of a complaint.

C. MBS also understands that it must ensure that all literature and correspondence relating to complaints is in clear and plain language.

D. we provide our complaint procedure information in a format which is capable of being reproduced in writing.

E. MBS will not make any charge for the provision of the Complaints Procedure or the handling of a Complaint of any description.

F. a notice is provided on our website (and the websites of our Appointed Representatives) of the existence of a dispute resolution procedure and the existence of the Financial Ombudsman Service (FOS).

Complaint Timescales: We shall promptly and within 5 working days, send a complaint acknowledgement which includes prominent mention of the customer’s right to refer to the FOS, or in the absence of such right (due to customer being ineligible to access FOS), will reassure the customer that the complaint has been received and is being dealt with.

The complaint acknowledgment will also provide the customer with the name and title of the complaint handler, and we will also enclose the FOS complaint information leaflet (where appropriate).

Within 8 weeks we will keep the customer reasonably informed as to the progress of the Complaint. Momentum understands that the FCA expects that all complaints will be dealt with in this period.

By the end of 8 weeks after receipt of a complaint, where a complaint has not been settled, we will issue a final response or issue a response which: A. explains why we are still not in a position to make a final response, giving reasons for the delay and indicating when we will be able to provide a final response, and Complaints Policy

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B. inform the customer that they may refer the complaint to the Financial Ombudsman Service if they are dissatisfied with the delay and encloses the explanatory leaflet if not previously provided.

Responses we send within 8 weeks: Our written response must include: A. An offer of appropriate redress if the client has been financially affected. This does not have to be in a ‘final response’ letter.

B. Information on how to pursue their complaint if the customer remains dissatisfied. The response will also indicate that we will regard the complaint as closed if we do not receive a reply within 8 weeks; We will inform the customer that they may refer their complaint to the Financial Ombudsman Service (if they are eligible) if they remain dissatisfied and that they have 6 months from the date of our letter to do so. We will also articulate within this letter that we will not give the FOS permission to handle a complaint outside of this time limit.

If the complaint is rejected, we will provide full details of the decision, including reasons why.

If the customer: A. does not reply to the final response, we are not required to send the following correspondence.

B. does not reply within 8 weeks, we will treat the complaint as closed.

C. does reply within or after the 8 weeks, we are required to continue to comply with the procedure above (with time limits adjusted accordingly).

If the customer takes more than 1 week to reply to a letter of the kind described above, the additional time in excess of 1 week will not count for the purposes of complaint response time limits.

If we can resolve a complaint by close of business on the third normal working day after the complaint was received, this is classed as a short complaint.

All short complaints must be recorded in our complaints register.

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If, within the third normal working day after the complaint was received, the complaint can be resolved, we must write to the person who has complained using the summary short complaint resolution letter and we must also enclose a copy of the FOS leaflet.

All short complaints must be reported on the our FCA RMAR return through FCA RegData.

Redress: Any Redress that we offer to a complainant has to be fair and in proportion to their financial loss. It should, in addition, be consistent with the fair treatment of our customers as detailed in our TCF policy.

Record Keeping: All complaints must be properly recorded on receipt by the Complaints Team and at each appropriate stage of handling within a Complaints Register. All records will be kept for a minimum of three years.

On receipt of a complaint, the Complaints Team will decide which category and product type the complaint relates to, and record this on the Complaints Register. The categories and types are defined by the FCA. If a complaint can be resolved before close of business on the third normal working day after the complaint was received, this is classed as a short complaint and must be recorded, and included in our reporting to the FCA. If a complaint can be resolved before close of business the third day after receipt, but there is a possibility that this may involve staff training or further complaints, this will also be recorded on the register.

Under our TCF policy, root cause analysis of all complaints, is considered to be an essential management information tool. A short record of complaints will, therefore, be retained although this may not form part of the our official complaints register If a complaint cannot be resolved before close of business the third day after receipt, this is classed as a long complaint and must be recorded as such in the complaints register.

We will retain a record of the complaints log (along with any correspondence and notes, including details of redress) for at least 3 years.

Reporting and Monitoring The FCA will request an analysis report on at least a 6-monthly basis. This will have to be submitted to the FCA with full details of the complaint, outcome and redress if applicable.

In addition, following a complaint, we will actively document where retraining needs have been identified, and the date such training was carried out All complaints must be categorised into one of the following areas for FCA reporting purposes.

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(A) (B) (C) (D) (E)

Advising, Selling & Arranging Terms & Disputed Sums / Charges General Admin / Customer Service Arrears Related Other

Staff should make suitable enquiries or seek appropriate assistance in identifying the correct category to ensure that accurate data is maintained.

Details of the complaint must be recorded on our complaint report sheet, including: • Client name • Policy Number/Reference • Risk Group (i.e. Consumer/Commercial) • Date of complaint • Type of complaint (Long/short) • Method of complaint (e.g. verbal, written, email etc.)

• Complaint category (See above) • FCA Class of Business (Motor/Property or Other)

Responsibilities Staff - All relevant employees (including our AR’s) must be familiar with the complaints procedure and, upon receipt of a complaint, all relevant employees must follow the Step

by Step Guide as indicated.

Team Managers - must ensure that complaints received by their team members are recorded on the complaints log and that the time limits above are adhered to.

Operations Director, supported by the Quality and Compliance Director - must ensure completion of the FCA Reporting and Quality Monitoring Audits, incorporating root-cause analysis, taking responsibility for outstanding complaints and any corrective action identified.

Quality and Compliance Director – is responsible for the oversight of the our compliance with DISP, which could include: •

Reviewing MBS’ management information in relation to complaints and assess whether it is fit for purpose.

•

Reviewing management information and assessing whether appropriate actions are taken in response to the results of root cause analysis undertaken.

Short Complaints: Dependent on the nature of the complaint, in some instances it may be possible to reach a satisfactory resolution with a complainant, to the complainant’s satisfaction, in a shorter period of time.

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Should a complainant have indicated their acceptance of our resolution by close of business on the third business day, a ‘summary resolution communication’ will be issued to the complainant in accordance with FCA rules.

The written communication will: • refer to the fact that the complainant has made a complaint, which we deem to have been resolved; • remind the complainant of their right to refer their complaint to the Financial Ombudsman Service • detail whether we have waived the relevant FOS time limits • provide the website address in reference to the further information available for the FOS Acknowledging the Complaint: This section applies unless we have resolved the complaint to the complainant’s satisfaction by the end of three business days after receipt, as outlined above.

In relation to all written complaints, the person designated to handle the complaint will acknowledge the complaint in writing within five business days.

In relation to all oral complaints, the person designated to handle the complaint will acknowledge the complaint in writing within five business days, setting out their understanding of the complaint and inviting the customer to confirm in writing the accuracy of that understanding.

The acknowledgement letter will outline the result of the investigation if complete.

If the investigation has not been completed, the acknowledgement letter will confirm that MBS: • •

•

Will investigate the complaint and respond within four weeks; Highlight that if the investigation is not completed within four weeks following the initial receipt of the complaint, the customer will be informed of the reasons for the delay; and Point out that on completion of the investigation the customer will be informed of the outcome and options available to them.

A copy of our external Complaints Procedure will be enclosed with the acknowledgement letter.

Investigating a Complaint The person designated to handle the complaint will investigate the complaint and will consult the adviser/member of staff whose actions or omissions gave rise to the complaint. The designated person will also take into consideration relevant decisions: • By the Ombudsman • By regulators such as the FCA Complaints Policy

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•

By us concerning previous customer complaints.

The investigation will include a review of the customer file, documenting the root cause analysis and may where necessary, involve contact with third parties such as product providers to obtain information.

If the person designated to handle complaints is themselves the subject of the complaint, the investigation will be conducted by another senior person.

Immediately on completion of the investigation, the person designated to handle the complaint will write to the customer notifying them of the outcome of the investigation, the nature and terms of any settlement.

In addition, if the complainant is eligible to refer their complaint to the Financial Ombudsman Service then our letter must inform them of their right to do so if they are not satisfied with the outcome.

This ‘final response’ letter must also point out that this should be within the next six months or they may lose the right to take the complaint to the Ombudsman unless we have agreed to waive this time limit.

The letter must incorporate the name, address, telephone number and website address of the Ombudsman and a leaflet which explains the Ombudsman arrangements, or which (for complaints received electronically including by e-mail) directs the customer to the Financial Ombudsman Service Consumer Leaflet.

Any compensation offered must be fair and the basis of calculation should be explained to the customer.

If the investigation is not concluded within four weeks, the person designated to handle the complaint must write to the customer informing them that the investigation is continuing and the reasons for the delay and when he/she expects to be able to contact the customer again.

If the investigation is not concluded within eight weeks, the person designated to handle the complaint must write to the customer informing them of the reasons for further delay and that if the customer is not satisfied with progress they may refer the complaint to the Financial Ombudsman Service if they are eligible to do so.

The letter must also point out that this should be within the next six months or they may lose that right. The letter must incorporate the name, address, telephone number and website address of the Ombudsman and a leaflet about the Ombudsman’s arrangements, or instead can (for complaints received electronically including by e-mail) direct the customer to the Financial Ombudsman Service Consumer Leaflet.

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Each of the above events must be recorded in our Complaints Register. The complaint handler should maintain a file for each complaint which should include copies of all correspondence relating to the complaint.

The file will be held within the relevant customer file.

Waiving Time Limits: As indicated above our final response must point out that the complainant, if they are not satisfied with our response, must refer their complaint to the FOS within six months of the date of our final response or they may lose the right to take the complaint to the Ombudsman.

The effect of FCA complaints rule changes introduced to fall in line with the Alternative Dispute Resolution Directive is that the FCA have given firms the choice to waive this and other time limits.

Under normal circumstances our position is that we will not waive the six month FOS referral time limit or the longer six year time limit. The six year time limit relates to a complaint needing to be made within six years of the event that is being complained about happening (or within three years of the customer reasonably knowing that something had happened, if that makes the time period longer than six years).

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Closing a Complaint: Where we receive confirmation from the customer that they are satisfied with the findings of the investigation and any resolution, the complaint will be considered closed and recorded as such on the register. Similarly, where we have issued a ‘final response’ letter we will update our records to record the complaint as closed.

Once a complaint is closed, a designated person will investigate and tackle any underlying ‘root cause’ issues, particularly where these appear to be the result of recurring or systemic problems.

Where appropriate, for example where the same issues may affect other customers, steps will be taken immediately to prevent further complaints; such remedial action may include offering appropriate redress to affected customers.

Referring a Complaint to a Third Party: If a customer makes a complaint regarding a matter that is the responsibility of a third party e.g. insurer or underwriter, and we currently market, or have previously marketed that third party’s products, we will be responsible for referring the complaint to the third party.

In all such cases the complaint will be referred to the third party in a durable medium within one business day of receipt and we will issue the customer with a letter confirming the referral and giving the third party’s contact details. This will be completed within five business days.

If we are jointly or partly responsible for the subject matter of the complaint, a referral will be made as outlined above, and those matters which are our responsibility will be handled according to the general complaints procedure set out in earlier sections.

FOS Referral: The FCA Rule at DISP 2.8.1 R (4) means, that if a firm consents, the FOS may investigate a complaint before the firm itself has done so, provided the FOS tells the complainant that the firm may handle it more quickly and the complainant nevertheless wishes the FOS to handle the complaint.

If one of our customers complains directly to the FOS, they will forward a copy of the complaint to us and ask us if we are happy for the FOS to consider the case. We are required to tell the FOS whether we agree or refuse permission (our consent) for the FOS to investigate the complaint before we have done so.

Where the FOS undertakes the complaint, we are nevertheless still responsible for writing to the complainant if the complaint is not resolved within 8 weeks. It is the FCA’s view that

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the FOS will provide a fast turnaround on complaints such that the issue of the 8-week deadline should generally not apply.

We do not envisage, that we will provide our consent for the majority of our complaints, If there are any circumstances in which you feel it is appropriate for us to allow our consent, you should refer these cases to either the Operations Director or Quality and Compliance Manager.

MBS must co-operate fully with the Ombudsman in resolving any complaints. This includes promptly forwarding all files as requested by the Financial Ombudsman Service.

All correspondence with the Ombudsman will be routed via the Complaints Handler.

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Conflicts of Interests Introduction The purpose of this policy is to set high-level requirements for MBS to meet its overarching legal and regulatory obligations in the identification, management, organising and mitigation of conflicts of interest.

MBS provides a range of insurance distribution services to a large number of customers through its network of AR’s and for certain services act as an agent of the insurers. MBS recognises that circumstances may arise in which the interest of a customer may conflict with those of another customer or with MBS’ own interests.

This policy framework facilitates and governs the identification and management of conflicts of interest for the company including ensuring that individuals adhere to MBS operating standards and where applicable are able to assist in demonstrating good risk management and control.

MBS operates a policy of independence and aims to treat all customers fairly at all times and always act in the best interests of its customers. MBS will never deliberately put itself in a position where its interests or duty to another party prevents MBS from discharging its duty to a customer.

Identifying and managing a conflict of interest is treated seriously and with high importance and due regard to all of MBS’ stakeholders, that includes the Financial Conduct Authority and its role in the financial markets.

The establishment of this policy enables MBS to fulfil its regulatory and legislative obligations.

Regulatory Background The regulatory expectations and specific requirements relating to conflicts of interest are set out in: • Principles 6 & 7 of the Principles for Businesses (treating customers fairly and communicating information in a way which is clear, fair and not misleading) • SYSC 10 (conflicts of interest) • SYSC 19F (Remuneration and performance management of sales staff) and • ICOBS 2.5.-1R (customer’s best interests) In summary as a regulated firm, we are required to: • Identify conflicts.

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• • • • •

Have effective controls in place to prevent or manage any conflicts to ensure no customer harm.

Monitor our controls to ensure these work as expected.

Have a conflicts of interest policy which sets out our systems and controls in relation to conflicts.

Keep and regularly update a record of any conflicts.

Report to the Board on a frequent basis and, at least annually, provide written reports on all conflicts to the board.

To support these requirements, we: • Train staff about our approach to conflicts of interest, its application to the individual’s role and their responsibilities under this policy both as part of our induction and on at least an annual basis as well as when changes are made to this policy.

There are specific requirements in SYSC10 as to the content of conflicts policy; it must: • Identify the circumstances which give rise to a conflict of interest entailing a material risk of damage to the interests of a client.

• Specify procedures to be followed and measures to be adopted to manage conflicts.

• Be designed to ensure that relevant persons engaged in different business activities involving a conflict of interest carry on those activities at a level of independence appropriate to the size and activities of MBS and of the group to which we may belong as well as to the materiality of the risk of damage to the interests of clients.

• Be designed to ensure that the insurance distribution activities are carried out in accordance with the best interests of the client and are not biased due to conflicting interests of MBS or another client.

• Include where appropriate to ensure the right degree of independence: o effective procedures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients. o separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of MBS. o the removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities.

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o

o

•

•

measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out services or activities; and measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate services or activities where such involvement may impair the proper management of conflicts of interest.

If the adoption or the practice of one or more of those measures and procedures does not ensure the requisite level of independence, we must adopt such alternative or additional measures and procedures as are necessary and appropriate.

The procedures and measures we rely upon must be appropriate to our size and activities and, if applicable, to the group to which we may belong and to the risk of damage to the interests of the client.

In the event that a conflict cannot be managed, as a measure of last resort, it must be disclosed to the customer.

MBS’ Policy Statement MBS is committed to ensuring that its business and operational activities do not contravene law and regulatory requirements and has assessed and determined the types of potential conflict situations that may be normally encountered. These potential conflicts have been categorised along with appropriate methods of mitigation.

Section 8 explains how conflicts are managed in more detail.

Principally, the fact that MBS is as an agent under common English law owes a duty to its customers and is not permitted to carry out particular activities without the consent of its customers.

MBS will ensure that is does not: • Jeopardise its loyalty and trust to customers where it conflicts with MBS’ own interests.

• Use the position of agent to acquire a secret profit or benefit.

• Act in any way for both its customer and agent without full and clear straightforward and appropriate disclosure and agreement It is our policy to avoid, wherever possible, conflicts of interest which could result in client disadvantage or detriment but, where these may be unavoidable, to manage any such conflicts properly and fairly.

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In the event that we cannot manage a conflict we will, as a measure of last resort, disclose it to the customer in accordance with the requirements in SYSC 3.3.13 and as set out in section 5 of this policy.

If any member of staff identifies a conflict this should be reported to Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director.

If any member of staff has any queries about this policy, these should be raised with Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director.

In addition MBS operates in accordance with the FCA’s Principle for Business (In particular PRIN 8 Conflicts of interest) and Senior Management Systems and Controls rules (SYSC 10) which require MBS to pay due regard to the interests of each customer and to manage any conflicts of interest fairly.

This requirement applies to situations between MBS and its customers and, between customers; and more specifically applies to component parts of the Conduct of Business (COB) and Insurance Conduct of Business (ICOB) sourcebooks.

Everyone involved with financial services activities, including introducing, advising, arranging and or the administration of regulated insurance policies is expected to act in accordance with this and other relating MBS Policies and Procedures at all times.

MBS will analyse Management Information available to ensure that we are able to demonstrate and evidence that its framework for managing conflicts of interest is delivering the desired effect and that it facilitates appropriate governance, whilst ensuring that a customer centric culture is sufficiently embedded across all operations and practices.

Where there are gaps or weaknesses identified, MBS will endeavour to feedback information to the various working groups so that proper consideration can be given to any remedial work necessary to bridge such gaps or to eliminate weaknesses. This will ensure that MBS continues to develop its approach and policy on conflicts of interest on an on-going basis.

Our Framework The Managing Director of MBS, its management, employees and AR’s will aim to adhere to and maintain the standards required by law and for regulatory compliance by operating to a set framework methodology.

In doing so, and as mentioned a policy of independence aims to treat customers fairly at all times and never deliberately intends to put MBS in a position where its interests or duty to another party prevents MBS from discharging its duty to a customer.

The framework operated is designed to facilitate MBS in maintaining reasonable and appropriate controls to identify and manage any potential conflict and forms part of MBS’ culture and its business practices which means MBS’ aim is to not put its trust with customers at risk by: • implementing reasonable management control and oversight; • providing appropriate education and training; • promoting ethical and responsible decision-making; Conflicts of Interests

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ensuring its framework assesses the way in which it is remunerated; in particular arrangements it has in place in relation to add-on insurance or services, including its premium finance relationships • making timely and appropriate (customer focused) disclosures; • respecting the rights of stakeholders; • adopting a culture of continuously recognising and managing conflict of interest risk in line with the size and complexity of the business; • remunerating fairly and responsibly; and • at all times treating its customers fairly MBS, its management, its employees and its AR’s shall be conversant with these provisions and enable implementation of appropriate policy where applicable. MBS will ensure it provides adequate financial and human resources, and appropriate training and oversight for its individuals to meet the necessary regulatory obligations.

•

Insurance Distribution and Conflicts of Interest Undertaking activities associated with a contract of insurance is a regulated activity and MBS ensures, through a framework of systems, controls and good governance that anyone involved in such activity is appropriately skilled and deemed competent to advise, arrange and administer regulated insurance products, this process includes education on conflicts of interest.

So that MBS’ approach to conflict of interest continually equals fair treatment of customers and is sufficiently embedded, MBS mandates the understanding of this policy and regular reading and understanding of business and regulatory learning modules available from MBS’ Compliance function and e-learning arrangements.

As mentioned, MBS has assessed and determined the types of potential conflict of interest situations that may be normally encountered. These principally include (but are not limited to): • Conflicts between Customers.

• Conflict as agent for the insurer (such as strategically managing the placement of a customer’s risk with a particular insurer or not influencing the ability of an individual so as to achieve a better deal for MBS).

• Business Transactions (such as personal or other financial interest exists).

• Incentives (such as staff bonus or remuneration schemes).

• Inducements or Bribes (such as unsolicited gifts and business courtesies, including meals and entertainment, favours, inappropriate gifts and promises).

• Outside Activities (such as external directorships or outside business interests).

• Complaints and Disputes (such as complaints about actions of individual staff) MBS’ expectation for these potential conflicts of interest forms its high-level standards for identifying, organising and managing conflict of interest.

Application of Policy This policy applies to compliance with all MBS company and FCA rules, principles, policies, procedures, guidance, standards and other applicable regulations to all MBS employees, Conflicts of Interests

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including AR’s, external consultants, contractors and temporary personnel while working for MBS. It is everyone’s personal responsibility to observe these standards and operate to the set framework whether or not these standards and requirements are also imposed by law as individuals who fail to comply with the standards and requirements of this policy will be deemed as acting outside the scope of their contractual responsibilities.

Compliance will not only be responsible for the day to day management of measuring adherence with this policy but shall also review and adapt this policy through a method of continuous improvement.

High-Level Standards MBS aims to encourage the highest professional and ethical standards and requires all individuals to meet these standards to maintain the good reputation of the company.

All individuals are expected to behave responsibly and with integrity taking into account their wider responsibilities to society as a whole, and always act in a courteous, honest and fair manner including meeting the requirements of regulatory authorities, and appropriate codes of practice and conduct in the normal course of conducting business but must also observe specific standards in regard to handling potential conflicts.

MBS has assessed and determined the types of potential conflict situations that may be normally encountered. These potential conflicts have been categorised with appropriate methods of mitigation and management. Further details can be found in Section 8 which explains the processes that MBS will follow to manage conflicts in greater detail.

Managing Conflicts of Interest Conflicts between Customers As mentioned MBS advise and arrange insurance for a large number of customers. In particular, situations might arise whereby we act for both customers who are tendering for one and the same contract and our ability to negotiate favourable terms for both may give rise to competition or conflict between customers interests.

In these situations, it is our policy to put in place specific procedures to preserve the ability to handle each customer’s case independently. This includes a full disclosure of the circumstances to each customer and obtaining their agreement for us to continue management of the situation. We operate a system of segregation (such as separate individuals and teams for appropriate business processes including maintaining files and records in separate secure locations). Where teams are in the same building, we will impose physical separation and security measures (such as keeping files in lockable cabinets and management monitoring adherence) There will be instances where we act for both customers who are tendering for one and the same contract and our ability to negotiate favourable terms will be overcome not only through disclosure and consent to the customer but also a combination of different individuals handling the issue (to create an information barrier) and manage appropriate management oversight.

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In exceptional circumstances MBS may conclude that, even with specific procedures it cannot be confident that it will properly serve the interests of both customers or parties without compromising the confidentiality of either customer and if no acceptable solution can be identified MBS will cease to act for one or more of the customers and refer them to another intermediary.

Conflict as agent for the insurer MBS ensure in all cases where it is acting as agent of the insurer that this is made abundantly clear to customers through prominent disclosures during the sales process to ensure customer trust is not put at risk. This is typically achieved through a combination of MBS’ customer terms of business agreement and the covering communication or oral disclosure.

In such circumstances, MBS has in place arrangements to ensure its financial deals with those insurers are managed more effectively and in particular the individuals who are managing the placement of a customer’s risk with such an insurer are not influenced in a way so as to achieve a better deal for MBS to the detriment of the customer.

Business Transactions MBS expects all individuals to be extremely careful if they have a personal interest or other financial interest exists which could compromise or appear to compromise their duties and commitment to MBS. Other than making investments in amounts not material to them and circumstances where individuals participate in a plan or own an interest in an investment vehicle in which they exercise no influence over investment decisions, MBS expects the individual to make a full disclosure of the matter and seek written approval from a senior executive or manager of MBS. In the event that an individual is a Director or Officer with which MBS may do business; all parties must be informed and it will not be possible for that individual to negotiate contracts or authorise transactions between parties.

Staff Incentives MBS operates a yearly reward scheme which can lead to a potential bonus payment for its staff based upon a strict assessment of the individuals overall performance as part of the annual appraisal process, MBS shall give careful and appropriate consideration, separately, and in particular evaluate the potential behaviours that might arise for potential conflicts as well as ensure it monitors and measures trend performance, (including individual behaviours) in regard to activities which might influence any reward payments.

Inducements or Bribes Within MBS, individuals must not seek gifts or entertainment for themselves or others from anyone with whom MBS does business and must not accept gifts or entertainment that could influence or appear to influence a decision.

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Unsolicited gifts and business courtesies, including meals and entertainment, favours, inappropriate gifts and promises are allowed by the Company; customary and commonly accepted; of minimal value, and accepted without an express or implied understanding that an individual is in any way obligated by their acceptance of the gift or courtesies.

MBS expects individuals to make a full disclosure and seek approval from a senior executive or manager of MBS for these or similar types of gifts and entertainment.

However, individuals may not accept gifts of cash or cash equivalents. MBS’ company policy bans the offer or acceptance of favours, inappropriate gifts, or the promise of gifts to influence business decisions in any way. Offering, promising, or giving gifts to try to influence a public official is prohibited.

Outside Activities Broadly speaking MBS do not anticipate that its individuals will hold any external directorships or engage in any outside business employment, make personal investment or give advice or assistance that detracts from their duties to MBS including taking personal advantage of their association with MBS or engage in conduct that is detrimental to the MBS’ interests or reputation.

This approach is not designed to prohibit such activities and, in the event, that an individual is engaged in such external activities; all parties must be informed, and MBS expects the individual to make a full disclosure of the matter and seek written approval from a senior executive or manager of MBS. Complaints and Disputes In the event that complaints and disputes about the actions of individual staff are identified MBS will assign the matter of investigating including any redress to its Complaints function.

The complaint investigator along with any other persons connected to the matter shall be required to maintain an appropriate level of independence, including maintaining records and material securely, and shall be responsible for instigating any appropriate systems and controls that might be necessary (temporarily or otherwise) to prevent reoccurrence and ensure the conflict of interest is managed effectively until the matter is resolved.

Training and Educational Material In the event insurers or suppliers to MBS offer or make payments to cover the cost of facilitating or to provide educational material, MBS will assess any offer or payment to ensure any payment or training provided does not include any element of profit for MBS. Where training and material is facilitated or provided on a non-monetary basis; MBS will ensure it considers each benefit separately to ensure they are designed to enhance the quality of service MBS will ultimately provide to its customers without breaching a customer’s interest.

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In all cases before any individual is engaged in such activities; all parties must be informed and MBS expects a full disclosure of the matter and written approval from a senior executive or manager of MBS. In the event that a conflict cannot be managed it must be disclosed before undertaking any business and we must provide the client with sufficient detail to allow them to make an informed decision on whether or not to proceed.

This disclosure process is to be managed by Hazel Westwood – Operations Director and Steve Walton – Quality and Compliance Director.

All disclosures are to be reported to Hazel Westwood – Operations Director and Steve Walton – Quality and Compliance Director who will, in turn, report to the Board with an explanation of why the conflict could not be managed.

Disclosure is a ‘measure of last resort’ and may only be used where it is not possible to manage the conflict. Disclosure must be clear and in a durable medium and must: • Specifically describe the nature or source of the conflict which has arisen • Include the steps we have taken to mitigate any risks to the client and explain that these have been insufficient to protect the clients’ interests • Explain the risks to the client which arise from the conflict • Include sufficient detail to enable the client to make an informed decision

Management Information MBS will analyse Management Information available to ensure that MBS are able to demonstrate and evidence that its framework for managing conflicts is delivering the desired effect and that it facilitates appropriate governance and that a customer centric culture is sufficiently embedded across all operations and practices.

Where there are gaps or weaknesses identified, MBS will endeavour to feedback information to the various working groups so that proper consideration can be given to any remedial work necessary to bridge such gaps or to eliminate weaknesses. This will ensure that MBS continues to develop its approach and policy on conflicts of interest on an on-going basis.

MBS’ board of Directors will aim to establish and ensure all conflicts of interest are reported and where appropriate headline details are documented within board information packs or similar (including signposting to where more detailed information about any and each individual conflict of interest reported can be accessed).

This shall enable MBS to measure its effectiveness in managing conflict of interest in accordance with its set standards and to determine how the business is meeting its wider governance objectives.

Reporting and Record Keeping All individuals are responsible for identifying and reporting (and where necessary collecting sufficient information) conflicts of interest. In the first instance, individuals must: • contact the Compliance Department of the company immediately with details for preliminary guidance.

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create a written report (capturing as much information as possible) of the potential or actual conflict activity using the conflict of interest notification form (a form can be found in section 12); and send the completed notification to the MBS Quality and Compliance Director.

• ensure all parties (including customers) are not informed of the report or given any indication of any potential conflict of interest.

• take no further action without instruction from the MBS Quality and Compliance Officer or other fellow company Director.

If at any time any individual within MBS requires advice and guidance, they must speak with the Quality and Compliance Officer or another Director of MBS who will escalate the matters as necessary. If individuals are unaware of how to contact the Quality and Compliance Officer, they must please speak to their Line Manager.

Centralised records will be maintained by MBS in conjunction with MBS’ senior compliance individual and MBS will aim to keep reasonably comprehensive records appertaining to all conflicts of interest in accordance with MBS’ Record-keeping and data destruction policies and related regulations for a minimum of 6 years after the cessation of the relationship with any employee, external consultants, contractors and temporary personnel working for MBS. Further details can be found in MBS’ Data Protection policy which sets out all other minimum retention periods and in addition requires certain records of information to be retained indefinitely.

•

Training, Advice and Further Questions We provide training to all relevant individuals on conflicts of interest including refresher training at least annually to ensure continuing awareness and details of any updates to the requirements.

All individuals are registered to access our e-learning arrangement managed by RWA Compliance Services Ltd. In the event that individuals are unable to gain access individuals have authority to contact RWA Compliance Services limited directly on 0845 020 0291 or helpdesk@rwagroup.co.uk.

In the event that individuals require more generalised advice and guidance, the our Compliance function or Senior Compliance Individual should be contacted

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Conflicts of Interest Notification Form Conflicts of Interest Notification Form Director Reporting to: Conflicts of Interest Reference Number: Date:

Department:

Reporting individuals Name:

Question:

Comments and resulting actions, including person taking accountability:

Date potential or actual conflict of interest was identified: Type of potential or actual conflict of interest: Details of all parties involved: Name of customers involved: High-level summary of the potential or actual conflict of interest: Supporting materials to suggest there is a potential or actual conflict of interest including evidence of the potential or actual conflict of interest: Have MBS policies and procedures been breached and where necessary reported?

For Completion by Compliance: Compliance judgement – nature and scale and details of escalation or additional controls necessary?

Full details of any further action taken or agreed:

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Financial Crime

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Introduction The purpose of this policy is to describe MBS’ approach towards fighting financial crime and to ensure that MBS mitigates the risks that emanate from financial crime which require robust systems and controls to prevent the products and services provided by MBS being used for criminal purposes.

MBS has taken a risk-based approach to the development of its financial crime prevention policies and procedures and has therefore set out different controls according the risks posed by its business operation.

This means MBS’ financial crime procedures are specific and apply to all MBS employees and AR’s, considering the scale of financial services activities being undertaken by its employees and AR’s and the nature and complexity of the MBS business.

The establishment of this financial crime policy enables MBS to describe how it fulfils its regulatory and legislative obligations in combating financial crime.

This policy provides an outline of the legal and regulatory framework within which we operate and the systems and controls across the business to help: • Interpret requirements as they are applied across MBS; • Show the practices adopted by MBS and the standards expected from all our staff and AR’s; • Design and implement systems and controls, necessary to mitigate the risks of financial crime.

Financial crime involves any act of fraud or dishonesty, market abuse (e.g. insider dealing), handling the proceeds of crime, money laundering or financing terrorism. As a business we have developed specific policies and procedures listed below. Every member of staff will receive initial and ongoing training on all such policies. The purpose of this document, however, is to set out the structure of how we go about ensuring that we are not exposed to financial crime in any of its forms.

This policy is designed to work in conjunction with the individual polices detailed below: • Anti Money Laundering • Data Security • Anti bribery & Corruption • Financial Sanctions (and PEP’s) • Whistleblowing • Gifts and Hospitality • Conflicts of Interest This policy has been adopted by the MBS Board of Directors and applies to everyone involved in our business.

Policy Statement MBS is committed to meeting its obligations for the prevention of financial crime required by the Proceeds of Crime Act 2002, and Bribery Act 2010 (and associated legislation) and as highlighted in the FCA Handbook under Systems and Controls (SYSC 6):

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“A firm must establish, implement and maintain adequate policies and procedures sufficient to ensure compliance of the firm including its managers, employees and appointed representatives (or where applicable, tied agents) with its obligations under the regulatory system and for countering the risk that the firm might be used to further financial crime.”

The aim of this policy is to prevent the proceeds of crime from being placed in the financial system, and to prevent bribery and corrupt activity through MBS and to detect suspicious activity, transactions and identify wrongdoing and report them to the authorities.

MBS encourages all its employees to be vigilant in combating financial crime and recognise that adopting a culture and value of intolerance to such activity, will enable it to protect its business in the event anyone attempts to commit financial crime through MBS. The MBS business and anyone operating on behalf of MBS is required to abide and operate in accordance with its financial crime policies and procedures and within MBS’ systems of control.

This ensures that all employees meet all appropriate compliance obligations. MBS shall monitor its compliance with those controls and deal with any matters identified in accordance with this policy and or MBS’ Breaches policy and procedures or similar as required.

This policy is designed to ensure that we identify the financial crime risk areas of our business and ensure that we have sufficiently robust systems and controls in place to mitigate that risk.

We will do this by: 1) Risk assessing financial crime and the ways in which they may affect our business, taking into consideration: a) Electronic Crime – online fraud b) Money Laundering c) Corruption d) Bribery e) Market Abuse 2) Evaluating the risks identified and the creation of systems and controls which will mitigate them.

3) Considering situations where our own activity may be contributing to the risk of financial crime. i.e. segregation of duties to avoid a single individual initiating, processing and controlling transactions e.g. that one individual should not be able to order goods, approve the invoice and write the cheque to settle the account.

4) Continuously monitoring our processes and procedures to ensure that they are effective at identifying and dealing with financial crime.

5) Having robust Data Security systems and procedures in place to prevent unauthorised access to our data.

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6) Appointing a nominated office for reporting Suspicious Activity Reports (SAR) and incidences of fraud to the relevant regulatory authorities.

There are two aspects to this issue; the need for us to guard against financial crime being perpetrated by someone within or associated with MBS (e.g. embezzlement) and the risk of us being used to further financial crime by other people or firms (e.g. customers making fraudulent claims or money laundering).

In the insurance and consumer credit markets, the potential for customers to commit fraud is well known, for example through deliberate underinsurance, falsification in application forms or exaggerating or falsifying claims.

We will undertake to mitigate the potential for us or our clients to be subject to financial crime through a number of individual policies and procedures: 1) We will allocate responsibilities for these individual policies to a number of different senior personnel, where possible, to ensure that all parts of the business contribute to the prevention of financial crime by providing real life examples of the issues to be aware of.

2) Where financial crime and money laundering are suspected or have been identified (either explicitly or through observed customer/employee behaviour), we will subject the files involved to ongoing investigation.

3) Where investigations confirm or increase our suspicions that financial crime or money laundering is being attempted, we will report this to the relevant regulatory authorities via a fraud report or SAR. 4) Where fraud or money laundering is suspected or identified, we will cease to deal with the account in question, making sure to avoid “tipping off” the client to our suspicions.

5) Customers will be screened against PEPs and sanctions lists and any matches escalated and reported to the relevant regulatory authorities.

6) We recognise that financial crime applies both externally and internally and we will audit customer files taking this into consideration.

7) Where incidences of financial crime and money laundering are found, we will undertake route cause analysis to identify whether enhancements can be made to our current systems and controls to aid prevention in the future.

8) We will put policies in place around the engagement of any services from third parties.

Application of Policy This policy applies to compliance with all MBS company and FCA rules, principles, policies, procedures, guidance, standards and other applicable regulations to MBS employees e.g. the Proceeds of Crime Act, Bribery Act, and Data Protection Act. MBS’ financial crime policies apply to all MBS employees’, AR’s, external consultants, contractors and temporary personnel while working for MBS. Combatting financial crime is a separate duty to giving financial advice which can help protect MBS, its individuals and the country from illegal acts. Ultimately everyone is responsible for reporting suspicious activity and MBS encourages all staff to be aware and alert to the potential risks of financial crime.

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Where necessary MBS expect all individuals identify and recognise suspicious activities and report their concerns, no matter how slight to MBS’ financial crime officer or Senior Compliance Individual.

MBS’ systems and controls are designed to prevent financial crime and are part of MBS’ commitment to treating customers fairly (TCF), operating in compliance with the customer’s best interests, whilst ensuring the delivery of good customer outcomes. MBS recognise that ultimately all customers pay for the consequences of illegal activities and are either directly or indirectly affected by the criminal activity from which the proceeds of crime, corruption or terrorist financing are generated.

Financial Crime Reducing financial crime is a statutory objective of the UK financial services regulator.

A financial crime is not a physical violent offence that is committed. It is an unlawful crime against property involving the unlawful conversion of the ownership of property (belonging to one person) for personal use and benefit of another.

‘It is an act committed by or against an individual or corporation and results in a financial loss. When a financial institution is involved, the crime is referred to as a financial sector crime’ Financial crimes typically include fraud (cheque fraud, credit card fraud, mortgage fraud, corporate fraud, insider trading), bank fraud, payment fraud, theft; scams or confidence tricks; tax evasion; bribery; embezzlement; identity theft; money laundering; forgery and counterfeiting, and consumer goods to mention a few.

These crimes may involve additional criminal acts carried out by individuals, corporations, and organised crime groups, such as computer crime, burglary, armed robbery, and even violent crimes such as murder and the victims of such activities can include individuals, small and large firms and corporations, governments, and entire economies.

MBS’ Inter-Related Financial Crime Policies This policy set’s out MBS’ collective approach towards combatting financial crime. It describes its interrelated financial crime policies and procedures which is what enables all individuals to take responsibility for effectively managing financial crime risks faced by MBS and comply with its various systems and controls as detailed within its respective financial crime policies and their supporting procedures.

The policies include: • Anti Money Laundering Policy which describes and sets out how to report and deal with any suspected or actual money laundering incident in accordance with the direction and requirements of MBS’ Senior Manager with overall responsibility for Money Laundering.

Money Laundering is the process by which criminals attempt to hide the proceeds of crime or terrorism through the financial system, it is a description of various methods by which criminals or terrorists ‘clean’ their money through financial system to make the proceeds of crime appear legitimate.

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The Proceeds of Crime Act 2002 (as amended) (POCA) sets out a series of criminal offences in relation to money laundering. There is a maximum sentence that could be applied to any individual for the offence of money laundering of 14 years and or an unlimited fine.

• MBS’ Data Protection and Terrorist Assets Freezing controls. MBS operates strictly in accordance with the Data Protection Act (2018) and Terrorist Assets Freezing Act 2010 which form an integral part of MBS internal operating systems and procedures.

The purpose of the Data Protection Act is to define the law on the processing of data on identifiable living people. It is the main piece of legislation that governs the protection of personal data in the UK. The Terrorist Assets Freezing legislation makes provision for UK Parliament to impose financial restrictions on, and in relation to, persons suspected of involvement in terrorist activity; and for connected purposes.

• MBS’ Anti-Bribery Policy which describes and sets out MBS’ Anti Bribery & Corruption measures undertaken in accordance with the requirements of the Bribery Act 2010 to assist MBS in protecting individuals from unnecessary exposure to individuals, groups or organisation who would seek to circumvent the legislation.

In broad terms a Bribe is defined as giving an individual financial or additional advantage to encourage that individual to perform their functions or activities improperly or rewarding individuals for having already done so. This would include seeking to influence a decisionmaker by way of offering or giving any kind of financial or additional benefit to influence a decision.

Knowing your customer MBS’ approach towards combating financial crime is to prevent, and identify, and or report the wrongdoing or suspicious activity in the financial system in the first instance.

MBS’ controls include preventing criminals from accessing the financial system by verifying their identity through a process of ‘knowing your customer’ both at the beginning and throughout the lifecycle of its relationship with customers.

This is typically a risk-based approach considering the circumstances surrounding the customer, the type of policy, the service, product, monetary values and methods of financial payments.

Systems are designed to collate as much intelligence as reasonably possible about a customer in order to give suitable advice but at the same time prevent the advent of financial crime. MBS adopt a policy of on-going training to ensure all individuals within MBS are aware of crime legislation and adopt the necessary procedures to prevent MBS from inadvertently colluding with an illegal act.

Responsibilities and Obligations

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The specific responsibilities and obligations of individuals and others in relation to appropriate financial crime policies which MBS operate is detailed in each of its individual policy documents.

In short, all individuals must: ‘not knowingly assist, carry on any transaction, ignore, conceal, disguise, convert, transfer or remove suspected criminal property and report the suspected or actual activity identified; importantly individuals must not take any further action themselves, and after making a report to the appropriate MBS reporting officer not discuss the matter, unless otherwise required by MBS’ reporting officer.

We wish to ensure that we identify, manage and mitigate (where possible) any Financial Crime activity. We will achieve this through the following controls: • A standing agenda item within the Board Meetings (or equivalent e.g. Senior Management meeting) which considers the effectiveness of our policies and procedures as well as incident management • Management information including: o Client and Third-party due diligence o Any relationships that were terminated due to financial crime concerns (including any SAR’s that were submitted as a result) o Number of transaction monitoring alerts o Gifts, hospitality and inducement reports • Periodic risk assessment of MBS’ financial crime exposure, including any information on emerging risks • Ensuring named individuals within in our senior management team take responsibility for all our Financial Crime policies and procedures • Reviewing the effectiveness of MBS’ individual financial crime policies on a regular basis • Separation of Functions and responsibilities e.g.: o Separate Compliance Function o Internal Audit/Quality Control o Countersigning cheques, cash handling processes, approving expenses etc The following individuals have responsibility for the areas listed below and should be contacted through your line manager in the event of any queries or concerns.

Anti Money Laundering/Fraud Data Security Anti bribery & Corruption Financial Sanctions Whistleblowing Gifts, Inducements and Hospitality

Hazel Westwood and Steve Walton Hazel Westwood and Steve Walton Hazel Westwood and Steve Walton Hazel Westwood and Steve Walton Hazel Westwood and Steve Walton Hazel Westwood and Steve Walton

Training, advice and further guidance

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MBS provides training to all relevant individuals on financial crime including refresher training at least annually to ensure continuing awareness and details of any updates to the requirements.

The recruitment, induction and ongoing training and performance management processes in place are designed to ensure: • The conduct and integrity of the individual appropriate to the nature of the role • That all employees will be able to identify financial crime and suspicious activity and have recognised processes and procedures in place to escalate these issues for further investigation.

• That all employees will be competent and capable of doing so.

• Training will be proportionate and differentiated to take account of varying risks associated with specific roles and responsibilities within the company.

Staff will be trained in identifying and mitigating customer facing financial crime. There will be mechanisms in place to allow all employees to report suspicious activity in confidence and staff will be trained to know when to do so.

All individuals are registered to access MBS’ e-learning arrangement managed by RWA Compliance Services Ltd. In the event that individuals are unable to gain access individuals have authority to contact RWA Compliance Services limited directly on 0845 020 0291 or helpdesk@rwagroup.co.uk In the event that individuals require more generalised advice and guidance, MBS’ Compliance function or Senior Compliance Individual should be contacted.

Money Laundering reporting, Anti Bribery and Data Protection Officer MBS has designated (overall to Hazel Westwood – Operations Director and Steve Walton – Quality and Compliance Director as deputy, the responsibilities of Money Laundering oversight, Anti Bribery and Data Protection, with the purpose of controlling the day to day management of financial crime prevention.

These individuals are free to act on their own authority and have adequate resources to devote to Anti-Money Laundering, Bribery and Counter Terrorism; in addition, they will receive any reports submitted and make any external reports to the National Crime Agency ‘NCA’ as necessary.

They will be the focal point and co-ordinator for all financial crime activity within MBS and are responsible for: • receiving and reviewing internal disclosures and making external reports • overseeing compliance with Policy and Procedures, • providing oversight of MBS requirements in respect of training, and • working closely with MBS’ Senior Compliance Individual and or Consultant

Records Centralised records are in place and include all Financial Crime notifications; these are maintained by MBS’ Senior Compliance Individual.

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MBS will in addition keep the records appertaining to customer identity and details of their transactions in accordance with the Data Protection Act and related regulations for a minimum of 6 years after the cessation of the customer relationship.

Records demonstrating the adequacy of MBS’ financial crime systems and controls including detection and prevention (in compliance with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017) will also be kept for a minimum of 6 years.

In addition, further details can be found in MBS’ Data Protection policy which sets out more generally all other minimum retention periods and defines the records MBS retains indefinitely.

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Whistle Blowing Policy September 2023

History of changes to this document Location of change

Description of change

When

Entire Document

New document draft created

10/2023

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Whistle Blowing Policy

Policy Governance: Overall Responsibility

Hazel Westwood - Operations Director

Deputy Responsibility

Steve Walton – Quality and Compliance Director

Policy Controls: Period from: Version: Last Review: Next Review:

October 2023 2.0 October 2023 October 2024

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What is Whistle Blowing: Our firm has obligations under the Public Interest Disclosure Act (PIDA) to provide protection to staff who report concerns they may have about our firm’s activities; reporting such concerns is commonly referred to as ‘whistleblowing’.

It is our policy to train all staff about our Whistleblowing procedure and specifically to tell our staff: • That we take failures seriously.

• What conduct is regarded as a failure.

• That their confidentiality will be respected if they raise concerns.

• How they may report their concerns.

We also have a procedure (see below) which is available to every member of staff and which they must comply with. This procedure: • Sets out that concerned staff will be supported and protected from reprisals.

• Nominates a senior member of staff as an alternative route to line management and tells our staff how they can contact that individual in confidence.

• Makes it clear that false and malicious allegations will be penalised by our firm.

• Tells our staff how they can whistle blow to sources outside our firm if necessary (e.g. to the Regulator).

• Provides access to an external body such as an independent charity for advice.

This policy applies to all staff including permanent and temporary employees, officers, directors (executive and non-executive), consultants, contractors, agency workers, AR’s and anyone else undertaking work on behalf of, or with, the firm e.g. employees of third party suppliers, outsource providers and corporate partners.

Maintenance and communication of the whistleblowing policy and procedure is the responsibility of Steve Walton – Quality and Compliance Director, who is also responsible for ensuring that any report is investigated impartially and objectively, and for ensuring the firm acts to ensure timely resolution and, where of sufficient materiality, escalation of reports received to the MBS board.

MBS understands that whistleblowing is relevant to all organisations and all people. This is because every business and every public body faces the risk of things going wrong internally. Where such a risk arises, usually the first people to realise or suspect the wrongdoing will be those who work in or with the organisation.

In general, employees should be able to make disclosures about wrongdoing to their employer, so that problems can be identified and resolved quickly within the company.

The organisation operates an open approach to whistleblowing. Our policy and procedure is intended to be in line with the Public Interest Disclosure Act 1998 (PIDA).

PIDA provides protection for whistleblowing in the public interest on wrongdoing. It encourages you to raise concerns with us in the first instance.

Everyone at some point in their career may be concerned about issues they see or hear during the course of their work. Usually, these concerns are easily resolved and we have a number of other Employee Handbook procedures to deal with them.

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However, where there is no other relevant procedure, or you have genuine concerns about using a particular procedure at either the outset or the end of the process, and your concern is about conduct likely to harm the reputation of the organisation, it can be difficult to know what to do.

You may be worried about raising such issues or may want to keep the concerns to yourself, perhaps feeling it's none of your business or that it's only a suspicion. You may feel that raising the matter would be disloyal to colleagues, managers or to the firm.

This policy has been introduced to enable you to raise genuine concerns about such malpractice at an early stage and in the right way. We would rather you raised the matter when it is just a concern, rather than wait for proof.

What does this policy cover: This policy covers the following: • Who and what is covered by the whistleblowing policy.

• Which procedure to use.

• Other wrongdoing • Independent advice • Our and your responsibilities • How to raise a concern • Protection • What happens if you may be implicated • Confidentiality • What happens during an investigation • What happens after an investigation • Where you can get further information Disclosing a concern, which, in your reasonable belief, suggests that wrongdoing has been committed, is in the process of being committed or is likely to be committed, would qualify for protection under PIDA, and that whistleblowing is in the public interest.

Wrongdoing includes (but is not limited to): • Bullying or harassment • Fraud • Failure to comply with a legal duty • Miscarriages of justice; • Criminal offences; • Endangering the health and safety of any person; • Damage to the environment; and • Deliberate concealment of any of the above.

It does not cover private grievances, including complaints about individual employment matters that may be referred to an Employment Tribunal. Additionally, disciplinary action may be taken against anyone deliberately raising false and malicious allegations.

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Which procedure should I use?

There are existing Employee Handbook policies designed to resolve many of these types of concerns. The procedures to be followed in raising issues under these policies are set out in the relevant entry in the Employee Handbook. They are: •

Grievance policy

•

Equal Opportunities policy

•

Disciplinary policy

•

Health and Safety policy

Additionally, the organisation has procedures regarding Money Laundering and these can be found in the Employee Handbook.

If one of the procedures set out above is relevant, that process should be used unless you have genuine concerns, at either the outset or the end of the procedure, about following the relevant employee handbook process.

In that event, the whistleblowing policy may be used. The whistleblowing procedure is not an appeal mechanism for other procedures, unless, exceptionally, you think when you have been through another procedure, that process was compromised.

The whistleblowing procedure is for all other cases involving conduct which appears likely to harm the reputation of the organisation, including but not limited to the examples set out above.

Where can I get independent advice?

If you feel you need independent advice at any stage of the process, you may contact the independent charity - Protect (formerly Public Concern at Work) www.protectadvice.org.uk on 020 3117 2520 or via email the UK advice line https://protectadvice.org.uk/contact-protect-advice-line/ They provide free and confidential advice on whistleblowing matters. But remember not to disclose any confidential information which the organisation has received.

Responsibilities Staff and others working with the organisation have a responsibility: • to be aware of this policy and procedures.

• when making any disclosure, to tell us if you have a direct personal interest in the matter.

Managers within the organisation have a responsibility: • to make their staff aware of this policy and procedures.

• to encourage a positive open working culture for staff and others working at the organisation to easily express their concerns.

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• • •

to take concerns seriously. to guide staff to the most appropriate route. to refer concerns raised under this whistleblowing procedure to the Quality and Compliance Director within 1 working day.

The Quality and Compliance Director has a responsibility: • to acknowledge receipt of disclosure to the whistleblower.

• to indicate to the whistleblower, where possible, how management proposes to investigate the disclosure and the likely timescales.

• to keep the whistleblower informed of progress on a regular basis.

• to take concerns seriously, to consider them fully and fairly.

• to resolve issues as expeditiously as possible.

• to communicate the findings to you and the individual(s) under investigation and, if appropriate, relevant members of the MBS management team or other external authorities.

• to keep a confidential log to assess effectiveness of policy and any emerging trends.

• to provide periodic anonymised reports on disclosures to the MBS board • to keep the policy under review.

How do I go about raising a concern Option One: normal route Tell your immediate manager or your Head of Department. This can be done either face to face or in writing.

Please make it clear that you are raising your concern as part of the whistleblowing procedure.

At any stage you can be accompanied by a fellow employee of your choice. The matter will then be referred to the Quality and Compliance Director.

Option Two: If the concern involves your immediate manager, Head of Department or a Director, or for any reason you would prefer them not to be told, you may raise the matter directly with the Quality and Compliance Director.

Option Three: If you have disclosed your worry internally and you are concerned either by the response or lack of response, or you feel unable to talk to anyone internally for whatever reason and the concern falls within the descriptions provided above, you can contact MBS’ nonexecutive Director.

They will investigate in whatever way they consider appropriate, but are likely to contact the senior management of the organisation, normally the Operations Director and the Quality and Compliance Director, to discuss the disclosure.

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The main purpose of this policy is to give you the opportunity and protection you need to raise your concerns internally.

MBS would expect that in almost all cases raising your concerns internally would be the most appropriate action for you to take.

If however, you have reasonable grounds to believe that the internal reporting structure would be insufficient and you feel you cannot raise your concerns internally and you honestly and reasonably believe the information and any allegations are true, you should consider raising the matter with the appropriate regulator.

Caution: If you have good reasons for not using the internal disclosure procedures set out in this policy, you may consider making wider disclosure to the police.

Whistle blowers who make wider disclosures of this type will only be protected (from victimisation and suffering detriment) in certain circumstances.

MBS therefore recommends that you take you own independent legal advice before following this course of action since we believe it will be in your own interest to do so.

What sort of response can I expect from the organisation?

Regardless of which procedure you use: • First and foremost, if you tell us in good faith about a concern about wrongdoing, you will be treated fairly and justly and any matter will be taken seriously.

• We will take all reasonable steps to ensure that no person under our control victimises you.

• If you disclose to us in good faith an incident in which you are not involved or implicated, we undertake that you will not lose your job because you did so.

• As far as possible, the organisation will keep you informed of the decisions taken and the outcome of any enquiries and investigations carried out. However, the company will not be able to inform you of any matters which would infringe the duty of confidentiality owed to others.

What happens if I’m implicated?

If you blow the whistle and actively co-operate with an investigation in which you may be implicated in any wrongdoing, your cooperation will be considered in the event of any disciplinary proceedings (unless the misconduct is so serious that no amount of cooperation or other mitigating conduct can justify a decision not to bring any action).

Confidentiality In raising a concern about wrongdoing, you may assume that only those individuals in the organisation who are investigating it will know your identity. We will not reveal your identity outside this group except: • Where we are under a legal obligation to do so.

• Where that information is already in the public domain.

• On a strictly confidential basis to a professionally qualified lawyer or accountant for the purposes of obtaining advice; or • To the police or as otherwise required under anti-money-laundering requirements Whistle Blowing Policy

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If there are any other circumstances in which we are required to reveal your identity outside those identified above, we will discuss this with you first.

What takes place during an investigation?

In order to give full consideration to your disclosure it is likely that one or more fact finding meeting will take place. If we need you to attend these meetings you can be accompanied by a fellow employee of your choice who may be a friend or colleague. You will be able to confer with your companion during the course of the meeting and he/she may address the meeting but may not answer questions on your behalf.

Individuals under investigation may also be accompanied by a fellow employee of their choice.

We will not ask you to attend a meeting where they are also present. The Quality and Compliance Director may be accompanied by any member of staff to assist with the investigation.

The Quality and Compliance Director will conduct a full investigation to establish whether wrongdoing has occurred. The format of the investigation may vary depending upon the circumstances.

What happens after the investigation?

The Quality and Compliance Director will ensure that the findings of the investigation are communicated to: • You, as the person raising the wrongdoing concern, subject to our duty of confidentiality to others; • The individual(s) under investigation; and, if appropriate, • Members of the organisation’s management or other external authorities who may need to consider whether action should be taken on the basis of the findings.

Where can I obtain further information If you would like further information the following websites may be of interest to you www.protect-advice.org.uk or http://www.fca.org.uk/site-info/contact/whistleblowing Alternatively, you can contact the Quality and Compliance Director.

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Breaches and Issues Policy Policy Statement This Breaches and Issues Policy applies to all staff including permanent and temporary employees, officers, directors (executive and non-executive), consultants, contractors, agency workers, AR’s and anyone else undertaking work on behalf of, or with, the firm e.g. employees of third party suppliers, outsource providers and corporate partners ; it is the procedure we rely on to ensure that all incidents are investigated, resolved and responded to effectively and promptly.

It is designed to enable us to identify and record any breaches (whether material or not) of regulatory rules, principles, guidance and policies under which we operate. It contributes towards our business efficiency, effectiveness, service provision and client retention as well as enabling us to fulfil our regulatory obligations.

Principle 11 of the FCA Principles for Businesses states: “A firm must deal with its regulators in an open and cooperative way, and must disclose to the FCA appropriately anything relating to the firm of which that regulator would reasonably expect notice.”

Furthermore, FCA rules (SUP 15) require us to notify a significant breach of a rule (which includes a Principle, or a Statement of Principle) or a significant breach of any requirement imposed by the Consumer Credit Act and its regulations or orders.

What is a breach?

The definition of a breach is ‘an act of breaking or failing to observe a law, agreement, or code of conduct’. Examples of activities which could be classed as a breach may include but are not limited to: • Any breach of a regulatory or legal requirement (e.g., a breach of FCA rules or principles such as insurance conduct of business rules (ICOBS) or Code of Conduct Rules (COCON), a breach of the principles and requirements of the Data Protection Act 2018, commitment of an offence under the Bribery Act 2010 etc.)

• Any significant incident of loss of IT systems • Any breach of our procedures • Any breach of client confidentiality • Any incident of employee fraud (whether successful or attempted) • Any breach of company policies and procedure

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A data protection / security breach means a breach of information security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. This includes breaches that are the result of both accidental and deliberate causes. It also means that a breach is more than just about losing personal data.

Examples of specific breaches may include: • A failure to provide customer with documentation within the required timescales.

• Omission of required regulatory disclosures in telephone calls.

• A Conduct Rules breach.

• A failure of systems and controls such as an IT failure.

• A failure to recognise and respond to a Subject Access Request within the mandated timescale.

The significance of a breach is determined having regard to potential financial losses to customers or to the firm or to other market participants, the frequency of the breach, implications for the firm's systems and controls and if there were delays in identifying or rectifying the breach.

Material breaches Material breaches are significant breaches of the firm’s rules, FCA rules or other applicable policy, guidance, procedures, operating procedures or legislation (such as a breach of Data Protection). This might include systemic compliance failings of colleagues, fraud or misconduct. Our requirement is to report such breaches to the FCA in line with keeping the regulator appropriately informed (Principle 11).

Non-material breaches Non-material breaches are one-off breaches of the FCA rules that are not material breaches. An example may be where an adviser has failed to send a Demands and Needs Statement to a client.

If these turn out to be a string of failings – where a team has repetitively or systemically failed to send Demands and Needs Statements - then this will become a material breach.

It is not possible to be prescriptive about this; a one-off breach where fraud or misconduct has occurred or is suspected can be a material breach and is required to be reported to the FCA under Principle 11.

What is an issue?

An issue is a failure of internal standards and controls which, although is a matter of concern, does not lead to a breach of regulatory or legislative rules and requirements.

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An example of an issue may be: • A failure to provide a customer with documentation within our service levels but where the documentation is provided within the required regulatory and legislative timescales • A failure to comply with company service levels • A failure to comply with wider company policies.

For the purposes of this policy, an issue also includes a ‘near miss’. A near miss is an incident where normal controls did not work as anticipated, but the matter did not escalate, and wider impact was avoided. The reporting of a near miss allows mitigation actions to be taken to avoid further instances.

Reporting breaches and issues All issues and breaches should be reported and escalated quickly to ensure fast and effective resolution to prevent or reduce customer detriment.

We have three different processes for handling breaches and issues depending on whether or not the matter relates to Data Protection / Security, Conduct Rules breaches or any other breaches / issues. These different processes are set out in this policy.

Process One - Breaches and Issues relating to all matters other than data protection / security and the Conduct Rules.

All staff including permanent and temporary employees, officers, directors (executive and non-executive), consultants, contractors, agency workers, AR’s and anyone else undertaking work on behalf of, or with, the firm e.g. employees of third party suppliers, outsource providers and corporate partner, and any other member of staff identifying or suspecting a breach must bring the matter immediately to the attention of their line manager and / or Hazel Westwood -Operations Manager or Steve Walton – Quality and Compliance Director.

Overall responsibility Overall responsibility for managing breaches and issues rests with Senior Management and in particular Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director.

Both individuals maintain operational oversight and will ensure that appropriate details are recorded on our Breaches log / register and acted upon as quickly as possible.

The firm requires that any breach or issue should be logged on the Breaches Register without exception.

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Responsibility for resolution The resolution of breaches and issues is owned by the Team Leader or Manager of the department to which the breach or issue relates. It is considered part of their role and responsibility to manage, mitigate and close such incidents.

Hazel Westwood – Operations Director and Steve Walton = Quality and Compliance Director, have oversight and reporting responsibility to Senior Management.

The impact of breaches and issues for both our customers and our business can be mitigated if: • They are reported and escalated quickly.

• Effective root cause analysis is carried out and timely action taken to manage incidents and improve process and controls.

• Potential ‘hot spots’ across the business areas are identified.

• Lessons are learnt from incidents to prevent them from occurring in other areas.

Notification of a breach or issue We are obliged to make the notification to the FCA immediately if we become aware, or have information which reasonably suggests, that any material breach has occurred, may have occurred or may occur in the foreseeable future.

Our policy is to report as soon as we can, even if not all the facts and consequences are yet ascertained; a long delay between identification and notification must be avoided.

Where a member of staff identifies a breach or issue, they should report it immediately to their Team Leader / Manager. The notification should include as much information as possible including the: • Nature of the breach / issue.

• When it occurred.

• Who identified it.

• Whether it has been resolved.

• Number of customers impacted.

• Whether any remedial action has been taken and the nature of that action.

The Team Leader / Manager will inform Hazel Westwood – Operations Director and Steve Walton – Quality and Compliance Director, as required and will update and maintain the breach register.

The business, in conjunction with the relevant Team Leader / Manager will carry out remedial action and provide ongoing updates to Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director who have oversight responsibility.

The significance of the breach or issue will be rated by Hazel Westwood – Operations Director and Steve Walton – Quality and Compliance Director, and where the breach is deemed to be of appropriate significance, they will provide updates to MBS’ Senior Management so that they may track appropriate resolution of the matter.

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Depending on the significance of the breach or issue, either the relevant Team Leader / Manager or Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director will be responsible for deciding if the breach / issue can be closed.

Record keeping Hazel Westwood – Operations Director and Steve Walton – Quality and Compliance Director will maintain the Breach Register and associated documentation which will include details of the actions taken in respect of each matter reported. The Register will be held securely at all times.

Hazel Westwood – Operations Director and Steve Walton – Quality and Compliance Director will: • Log all incidents and include them on the Breach Register (and the Risk and Conflicts of Interest Registers if applicable).

• Consider whether the matter is to be reported as a Material Breach (see above).

• Report incidents to MBS’ Senior Management and, where relevant, to the FCA. • Ensure that incidents are processed and resolved satisfactorily.

If there is any doubt as to whether or not an incident needs reporting, you should refer to Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director.

Process Two - Breaches and Issues relating only to the Conduct Rules.

All staff including permanent and temporary employees, officers, directors (executive and non-executive), consultants, contractors, agency workers, AR’s and anyone else undertaking work on behalf of, or with, the firm e.g. employees of third party suppliers, outsource providers and corporate partner, and any other member of staff identifying or suspecting a breach must bring the matter immediately to the attention of their line manager and / or Hazel Westwood -Operations Manager or Steve Walton – Quality and Compliance Director.

Overall responsibility Overall responsibility for managing Conduct Rules Breaches and Issues rests with Senior Management; Hazel Westwood – Operations Director and Steve Walton – Quality and Compliance Director are responsible for oversight of the firm’s compliance with the Conduct Rules and maintain operational oversight. They will ensure that details are recorded on our Breaches log / register and acted upon as quickly as possible.

The firm requires that any breach or issue should be logged on the Breaches Register without exception.

Responsibility for resolution The resolution of Conduct Rules breaches and issues is owned by the Team Leader or Manager of the department to which the Conduct Rule breach or issue relates. It is

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considered part of their role and responsibly to manage, mitigate and close such incidents.

However, Hazel Westwood – Operations Director and Steve Walton – Quality and Compliance Director have oversight and reporting responsibility to Senior Management.

The impact of breaches and issues for both our customers and our business can be mitigated if: • They are reported and escalated quickly.

• Effective root cause analysis is carried out and timely action taken to manage incidents and improve process and controls.

• Potential ‘hot spots’ across the business areas are identified.

• Lessons are learnt from incidents to prevent them from occurring in other areas.

Notification of a breach or issue Where a breach of the Conduct Rules is identified and specific disciplinary action is taken, we are required to report the breach to the FCA. Breach reporting is applicable for Senior Managers, Certification Staff and NEDs from 9th December 2019 and from 9th December 2020 for all other applicable employees.

The Breach reporting requirements are set out in the FCA Handbook section SUP 15.11.

Disciplinary action is defined as: • issuing a formal written warning.

• suspending or dismissing the individual, or • a reduction or recovery of remuneration.

Breaches can arise from an action, inaction / failure to act or other circumstances that amounts to a breach. Breach reporting for Senior Managers must be made to the FCA within 7 business days of concluding disciplinary action by submitting Form D. If as a result of the breach the Senior Manager will no longer be approved as a Senior Manager, then we are required to also submit a Form C. Breaches for all other applicable employees must be reported annually via the FCA RegData system. We will report in October, for the reporting year 1 September to 31 August.

This applies even if there haven’t been any breaches within the reporting period. It is important to remember that we must declare that we have had no breaches by making a nil return.

In circumstances where an individual is appealing, or plans to appeal, the breach should still be reported but must include information about the appeal in the notification. Once an outcome has been reached, we must update the FCA. It is important to remember that an incident may not be deemed a reportable breach of FCA Conduct Rules as defined in FCA Handbook COCON, but may be an informal breach (i.e., the Conduct Rules have not been met but the specific disciplinary action detailed

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above has not been taken) and / or a breach of another FCA rule as defined in the FCA Handbook (such as ICOBS or CONC) and should be dealt with appropriately.

Appropriate action will include: • to invoke our breaches and issues procedure.

• to investigate the matter.

• to take all appropriate action • to record within our breaches and issues register.

• to notify all relevant parties.

• to consider invoking our disciplinary procedures where appropriate, and • if the breach identified meets FCA wider existing breach reporting criteria, report the breach to the FCA within the applicable timescales.

The requirements in relation to notification of breaches of COCON do not remove or change our current obligations in relation to reporting concerns about an individual’s actions, inactions, behaviour or any issues under existing rules and principles and neither is it intended to result in us increasing disciplinary action that may be taken against individuals.

We should not over-report and only do so where the circumstances and the conclusions of any investigation and resulting actions are clear.

We are obliged to make the notification to the FCA immediately when we become aware, or have information which reasonably suggests, that any material breach has occurred, may have occurred or may occur in the foreseeable future.

Our policy is to report as soon as we can, even if not all the facts and consequences are yet ascertained; a long delay between identification and notification must be avoided.

Where a member of staff identifies a breach or issue, they should report it immediately to inform their Team Leader / Manager. The notification should include as much information as possible including the: • Nature of the breach / issue.

• When it occurred.

• Who identified it.

• Whether it has been resolved.

• Number of customers impacted.

• Whether any remedial action has been taken and the nature of that action The Team Leader / Manager will inform Hazel Westwood – Operations Director and Steve Walton – Quality and Compliance Director who have oversight responsibility, as required and will update and maintain the breach register. Where appropriate, the incident will also be fed into the risk and conflicts of interest registers.

The business in conjunction with the Team Leader / Manager will carry out remedial action and provide ongoing updates to Hazel Westwood – Operations Director and Steve Walton – Quality and Compliance Director.

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The significance of the breach or issue will be rated by Hazel Westwood – Operations Director and Steve Walton – Quality and Compliance Director and, where the breach is deemed to be of appropriate significance, they will provide updates to MBS’ Senior Management so they may track resolution of the matter.

Depending on the significance of the breach / issue either the relevant Team Leader / Manager or Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director will be responsible for deciding if the breach / issue can be closed.

Record keeping Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director will maintain the Breach Register and associated documentation which will include details of the actions taken in respect of each matter reported. The Register will be held securely at all times.

Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director will: • Log all incidents and include them on the Breach Register (and the Risk and Conflicts of Interest Registers if applicable).

• Consider whether the matter is to be reported as a Material Breach (see above.

• Report incidents to MBS’ Senior Management and, where relevant, to the FCA • Ensure that incidents are processed and resolved satisfactorily.

If there is any doubt as to whether or not an incident needs reporting, you should refer to Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director.

Process 3 – All matters relating only to data protection / security.

Overall responsibility for managing breaches and issues rests with Senior Management and in particular Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director.

All staff including permanent and temporary employees, officers, directors (executive and non-executive), consultants, contractors, agency workers, AR’s and anyone else undertaking work on behalf of, or with, the firm e.g. employees of third party suppliers, outsource providers and corporate partner, and any other member of staff identifying or suspecting a breach must bring the matter immediately to the attention of their line manager and / or Hazel Westwood -Operations Manager or Steve Walton – Quality and Compliance Director.

Every individual working for, in partnership with, or under contract to MBS is responsible for reporting breaches and issues.

The firm requires that any breach or issue should be logged without exception.

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Responsibility for resolution The resolution of breaches and issues relating to data protection / security is the responsibility of Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director and have responsibility for reporting to Senior Management.

The impact of breaches and issues for both our customers and our business can be mitigated if: • They are reported and escalated quickly.

• Effective root cause analysis is carried out and timely action taken to manage incidents and improve process and controls.

• Potential ‘hot spots’ across the business areas are identified.

• Lessons are learnt from incidents to prevent them from occurring in other areas.

Notification of a breach or issue - internal All data protection / security breaches must be reported Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director immediately. Reporting should be done by telephone or face to face to ensure it is received in the shortest possible timescale.

The notification should include as much information as possible including: • What has happened.

• How and when the firm became aware • The category of data • The significance of the incident (this is determined by the category of data that has been lost).

• Potential impact to the Company and data subjects • Initial actions including timescales.

• Next steps, including whether data subjects and the relevant supervisory authority need to be informed, including timescales.

• Follow-up actions Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director will update, and keep up to date, the breach register. Where appropriate they will also feed the incident into the risk and conflicts of interest registers.

The business, in conjunction with Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director will complete remedial action as well and providing ongoing updates to MBS’ Senior Management.

The significance of the breach or issue will be rated by Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director and where appropriate the resolution will be tracked by MBS’ Senior Management.

Depending on the significance of the breach / issue either Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director or MBS’ Senior Management will decide if the breach / issue can be closed.

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Notification of a breach or issue – external All reportable data protection / security breaches must be reported to the Information Commissioners Office (ICO) within 72 hours (NOTE – hours, not working hours) of the breach being identified.

Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director are responsible for advising MBS’ Senior Management if a breach is reportable and for reporting the breach to the ICO. If the breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms, we must also inform those individuals without undue delay. Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director are responsible for advising MBS’ Senior Management if individuals need to be informed and will be responsible for ensuring that appropriate communications are sent to the individuals affected as quickly as possible.

We are required by law to keep a record of all data protection / security breaches regardless of whether these are ultimately classed as reportable to the ICO or not. We need to be able to evidence our decision making when deciding whether or not to report a breach to the ICO. The relevant section of the MBS breach register should record the relevant information as follows: • The event.

• How and when the firm became aware.

• The category of data involved.

• Event materiality (i.e., the seriousness of the event, this is determined by the category of data that has been lost).

• Potential impact to the Company and data subjects.

• Initial actions.

• Next steps, including whether data subjects and the relevant supervisory authority need to be informed.

• Follow-up actions Where Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director establishes that we need to notify the ICO of the breach they will also need to collect and provide the following information to the ICO: • A description of the nature of the personal data breach including, where possible: o the categories and approximate number of individuals concerned, and o the categories and approximate number of personal data records concerned, o The name and contact details of the MBS Data Protection Officer / Representative from whom more information can be obtained, o A description of the likely consequences of the personal data breach, and

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o

A description of the measures taken, or proposed to be taken, to deal with the personal data breach, including, where appropriate, the measures taken to mitigate any possible adverse effects.

Record keeping Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director will maintain the relevant section of the MBS Breach Register and associated documentation which will include details of the actions taken in respect of each matter reported. The Register will be held securely at all times.

Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director will: • Log all incidents relating to data protection / security and include them on the Breach Register (and the Risk and Conflicts of Interest Registers if applicable) • Report incidents to the MBS Senior Management for robust oversight • Ensure that incidents are processed and resolved satisfactorily

Significant and material breaches Under FCA Principles of Business 11 – Relationships with our Regulator, a breach will be reported to the FCA where there is a significant and material breach of an FCA Rule or Principle and: • There is a significant consumer detriment including client confidentiality issues.

• The breach relates to the capital resources of the firm.

• There is a systemic failure of processes or systems including data security issues.

If a staff member is concerned that a breach may be a significant breach, they should contact Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director by phone.

Where a significant or material breach has been identified, and it is considered appropriate to report this to the FCA, MBS’ Senior Management must sign off prior to FCA notification.

MBS Senior Management will review the details of the breach, and if they endorse the view that notification to the FCA is required, Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director will be responsible for liaising with the FCA and will contact and deal with the FCA in all matters regarding the Breach.

If a significant or material breach relates to data protection, Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director will be responsible for updating the MBS Senior Management team and responsibility for reporting a significant / material breach involving data protection / security matters to the FCA will also remain their responsibility.

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AR Business partners Where a breach has been identified and it affects any AR business partners and or their customers, then Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director should be notified, and they will agree next steps and determine what action should be taken in line with agreed contracts.

Press and publicity Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director will deal with the press and public in all matters regarding Breaches. If any person discloses any related information to the media without the express authority of Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director, this will be treated as a breach of this policy and may lead to disciplinary action.

The police Where the matter involves potential legal activity Hazel Westwood – Operations Director or Steve Walton – Quality and Compliance Director will have responsibility for requesting Police involvement and for arranging liaison with staff during their investigations

MI and root cause analysis Staff are encouraged to report any and all incidents and breaches.

As well as allowing us to address the specific problem identified, reporting all items allows us to monitor for any trends and to explore root causes so that if a breach or incident is a result of a systemic issue such as, for example, an ineffective process or inadequate training, this underlying issue may also be addressed.

MBS reviews MI around breaches and issues on at least an annual basis, in order to identify trends, mitigate risks and manage the business.

The MI reported includes data relating to numbers of open and closed issues, trends, root cause and departments / processes impacted.

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Contract Certainty Policy October 2023

Introduction This high-level policy outlines MBS’ approach to the management and control of Contract Certainty. This policy will be reinforced through the delivery of guidance, standards, processes and procedures, which are documented within this policy framework and in conjunction with the firms existing guidance standards, processes and procedures documents.

MBS understands that the management and control of Contract Certainty requirements needs to be delivered in an efficient, appropriate, structured and accountable manner.

The purpose of this Contract Certainty policy is to provide guidance and support relating to the management and control of Contract Certainty requirements and the achievement of corporate objectives. The MBS Contract Certainty policy has also been developed to ensure that MBS staff and its AR’s are provided with the appropriate information and guidance.

MBS is fully committed to being open and transparent whilst maintaining its regulatory responsibilities, ensuring individuals adhere to its operating standards where applicable to assist in demonstrating good standards of Contract Certainty management and governance control.

Scope of Policy This policy documents the firms Contract Certainty Policy and Procedures to enable all individuals to take responsibility for effectively managing and controlling Contract Certainty requirements when placing and arranging insurance contracts whilst adhering to management systems, controls and principles as detailed within this policy and other supporting procedures.

This summary is intended to provide key information and controls that all MBS staff and its AR’s must be aware of and adhere to in order to assist MBS in meetings its Contract Certainty compliance requirements.

In addition, this policy explains how to access further training, guidance and support and how to report and deal with any identified Contract Certainty related issues within the direction and requirements of this policy.

In designing the Contract Certainty management and control programme, the company has taken into account the guidelines set by the Financial Conduct Authority (FCA) and the Contract Certainty Code of Practice and also the internal requirements for managing and controlling Contract Certainty within the business.

Operating a Contract Certainty policy is an integral part of the requirements of the FCA Sourcebook and is relevant for all the regulated entities, as well as good business practice.

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Policy Statement Contract certainty is achieved by the complete and final agreement of all terms between the insured and insurer at the time that they enter into the contract, with contract documentation provided promptly thereafter.

3.1 Contract Certainty Principals: When entering into a contract, the insurer and broker must ensure that all terms are clear and unambiguous before making any offer to enter into a contract or accepting such an offer.

All terms must be clearly expressed, including any conditions or subjectivities.

After entering into the contract, the contact documentation must be provided to the insured promptly.

The insurer and broker must demonstrate their achievement of both principals.

In respect of contract changes, these need to be certain and documented promptly.

Where the contract has not met the principles of Contract Certainty, the insurer and broker have a responsibility to resolve expectations to any of the above principles as soon as practicable and without undue delay.

3.2 When Entering into a Contract The insurer and broker (where applicable) must ensure that all terms are clear and unambiguous by the time the offer is made to enter into the contract or the offer is accepted.

All terms must be clearly expressed, including any conditions or subjectivities.

The proposed contract is the document which contains the offer and can take many forms.

Individual market protocols define these and examples include: • completed presentation templates; • proposal forms; • slips or other placing documents.

Terms are the contractual provisions of the contract and should be clear and unambiguous.

Contract terms should comply with all relevant regulations and codes of practice.

All terms should either be expressed in full or unambiguously identified; for example, by specific reference to bespoke or model material.

Wherever possible, the insured and insurer should enter into the contract prior to inception.

In circumstances where this is not possible, Contract Certainty can still be achieved by applying the Contract Certainty principles.

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MBS should therefore be able to demonstrate the extent to which contracts are being entered into later than inception, their causes and actions being taken to reduce their frequency.

The contract should clearly identify all parties to the contract Insurers should: • Check that the proposed contract clearly identifies all of the terms by the time it formally commits to the contract.

• Where there is more than one participating insurer, each insurer should satisfy itself that adequate contract checking has been completed.

• Where the contract is to provide cover that will commence prior to the contract being entered into, the insurer should ensure that this is permissible, having regard to the class of business and all appropriate laws and regulations and the scope of coverage for any claims which arise in respect of the period between the start of the insurance period and the date on which they enter into the contract is clear.

Brokers should: • Provide the necessary risk and contractual information that represents the insured’s demands and needs, to enable the agreement of all terms.

3.3 After Entering into a Contract Contract documentation contains all the agreed terms of the contract between the insured and the insurer and details of the insurers’ participations.

The insurer must provide contract documentation to the insured (or their agent).

Contract documentation must be sent to the insured promptly. The documentation provided may be the insurer authorised contract document and/or other contract documentation which may not be insurer authorised.

An insurer may delegate authority for the provision of contract documentation, e.g. to the holder of a delegated underwriting arrangement or to a service provider, but remains responsible in these cases.

Promptly is defined as: • within 7 working days for Consumers.

• and for all other client classifications, within 30 calendar days.

These timescales are measured from the later of the following: • the inception date of the contract.

• the date on which the insured and insurer enter into the contract.

• where there is more than one participating insurer, the date on which the final insurer enters into the contract.

Where a broker, intermediary or service provider is involved in the preparation or delivery of the contract documentation, sufficient time should be allowed for any associated

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checking and onward provision of the documentation within the period defined as promptly.

The following are examples of insurer authorised contract documentation: • Insurance Policy.

• Schedule of Cover.

• Certificate of Insurance.

• A copy of the complete slip.

Unless expressly authorised by the insurer(s), any further documentation provided by the broker, such as the schedule of insurer participations, is provided in its capacity as agent of the insured and remains the broker’s responsibility.

The following are examples of other contract documentation which may be provided by the broker as a record of the contract: Broker insurance document.

A broker insurance document contains the terms and conditions of the insurance contract as well as details of the insurer(s). Unless expressly agreed by insurer(s), a broker insurance document is contract documentation provided by the broker in its capacity as agent of the insured and must not be represented as insurer authorised.

Other broker produced documents A broker may choose to send other documentation to the insured e.g. adding the full text of a clause or wording as defined in the contract. However, unless expressly agreed by the insurer(s), the broker is responsible for the accuracy and completeness of such documentation.

Insurers should: • Ensure that the type of contract documentation to be provided to the insured (or their agent) is clear.

• Provide contract documentation to the insured (or their agent) promptly.

• Observe any protocols relating to the checking and onward provision of documentation where a broker, intermediary or service provider is involved. For example, some market sectors have established protocols of 2 working days for Retail customer contracts and 9 calendar days for all other client classifications.

Brokers should: • Ensure that the type of contract documentation to be provided to the insured (or their agent) is clear.

• Where responsible, provide contract documentation to the insured (or their agent) promptly.

3.4 Demonstration of Performance The insurers and brokers (where applicable) are each responsible for, and need to be able to demonstrate, performance of: • the agreement of all terms by the time of entering the contract.

• the achievement of the above by inception date.

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• •

the prompt provision of contract documentation for which they are responsible. how exceptions are identified and resolved, and the actions taken to reduce occurrence.

The methodology for demonstrating performance should be consistent and typically based on the following: • the inception date of the contract.

• the date on which the insured and insurer enter into the contract.

• for brokers and where there is more than one participating insurer, the date on which the final insurer enters into the contract.

Examples of how Contract Certainty can be demonstrated include the following: • Verification against a checklist - A checklist could be applied to each contract and a record kept of whether or not Contract Certainty was achieved. The checklist criteria may need to vary, depending upon client classification or class of business.

Hence an organisation may require more than one checklist to cater for specific circumstances.

• Sample or File audits - Statistically credible samples of contracts may be reviewed to verify whether or not Contract Certainty was achieved.

• System or Process controls - Where controls are in place which ensure that all or part of the principles have been met. For example, where an e-Trading platform is used to automate and validate the collection of required data or to provide contract documentation in specific formats and timeframes.

Insurer’s should: • Where the broker sends contract documentation to the insured (or their agent), the insurer is not required to establish or record the date of provision.

Broker should: Where the insurer provides the contract documentation directly to the insured or has delegated this role other than to the broker, the broker is not required to establish or record the date of provision.

3.5 Contract Changes Contract changes need to be certain and documented promptly.

This means: • complete and final agreement of the change by the insured (or their agent) and insurer, by the time that the parties commit to it, while: o maintaining the certainty of the contract; and o providing documentation in respect of the change to the insured (or their agent) promptly thereafter.

Changes to the contract can only be made by documented mutual agreement and in accordance with any provisions in the original contract, clearly identifying the effective date of the change.

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Contract Certainty need not be separately demonstrated for any changes to existing contracts.

3.6 More than one participating Insurer When entering into a contract: • The contract must include an agreed basis on which each insurer’s final participation will be determined • Ensure that the method of calculating insurer participations (signed lines) is clearly stated in the contract.

This is achieved by the inclusion of signing provisions, which result in clearly defined participations throughout the time on risk.

Insurers should: • Ensure that any proposed signing provisions achieve clearly defined participations throughout the time on risk.

• Ensure that a suitable several liability clause is present.

Brokers should: • Propose suitable signing provisions, which reflect any client requirements, for inclusion within the contract.

• Complete the placement as soon as practicable and without undue delay.

• Include a suitable several liability clause.

After entering into a contract: • The final participation must be provided to each insurer promptly.

In relation to this principle, promptly means that: • at the request of the insurer an insurer’s participation on the contract will be made available by inception or upon completion of the risk placement if this occurs postinception.

• where the insurer needs the insurer participations to prepare the contract documentation then insurer participations should be provided by the broker in sufficient time to allow for this; • where the contract denotes that contract documentation is to be prepared by the broker, then the insurer participations should be provided in sufficient time to allow for insurer authorisation of the contract documentation.

• each insurer’s participation on the contract will be provided within 30 calendar days of either inception or completion of placement, whichever is the later.

Insurer participations are available to insurers at the time of placement by writing “line to Stand”.

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Insurers should: • Write “line to stand”, or request insurer participation from the broker, where there is a requirement to know the exact participation at an early stage.

Brokers should: • Calculate insurer participations by either inception or completion of placement, whichever is the later.

• Respond to insurers’ requests for provision of insurer participation information.

• Provide insurer participation information to insurers within the specified timescales.

3.7 Not meeting Contract Certainty Principles The insurer and broker (where applicable) have a responsibility to resolve exceptions to any of the above principles as soon as practicable and without undue delay.

If all terms have not been agreed by the time of entering into the contract, then every effort should be made to do so as soon as practicable thereafter.

Similarly, wherever accurate contract documentation has not been provided promptly, the insurer and broker (where applicable) must use their best endeavours to ensure that the provision of contract documentation is delayed as little as possible.

Some market sectors have established protocols for the rectification of inaccurate contract documentation; for example, which require corrections to be made within a 14day timescale.

If the delay is likely to be significantly beyond the required timescales, then it is the responsibility of the insurer or broker (if applicable) to keep the insured informed of the position.

The above actions will help prevent the creation of a backlog of contract documentation.

Where insurers and brokers already have a legacy of contract documentation, this needs to be resolved.

3.8 Subjectivities The objective of Contract Certainty is to provide clarity for both insured and insurer on the terms of the insurance contract.

Sometimes, information that the insurer requires is not available and as a result the insurer may impose a subjectivity on the contract.

In the past, subjectivities have given rise to uncertainty in relation to the contract since the precise terms of the relevant requirement, and the consequences if the requirement was not met, were insufficiently specified by the time of entering into the contract.

The proposed contract may include subjectivities as part of its terms, and these should be clearly expressed.

Principle A of the Contract Certainty Code of Practice requires that:

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“The insurer and broker (where applicable) must ensure that all terms are clear and unambiguous by the time the offer is made to enter into the contract or the offer is accepted. All terms must be clearly expressed, including any conditions or subjectivities.”

You must ensure that a subjectivity is expressed as an unambiguous condition (specifying the responsibilities and timescales for resolution, and any consequences of failure) of the contract.

A subjectivity should set out all of the following: • the condition/action that needs to occur, by whom and to what standard; • the applicable timescale, if any, within which the condition is to be met.

• the terms which are to apply until the condition is met; • any consequences which follow if the condition is not met.

3.9 Subjectivities Contract Certainty Principles

Contract Certainty Checklist - Are all parties to the contract clearly identified?

Y/N

A: When entering into the contract The insurer and broker (where applicable) - Is the period of cover clearly expressed? must ensure that all terms are clear and - Are the sums insured and/or limits clearly unambiguous by the time the offer is accepted. expressed?

All terms must be clearly expressed, including - Is the premium or rate (together with any relevant any conditions. deductions) clearly expressed?

B: After entering into the contract Contract documentation must be provided to - Are any necessary taxes clearly expressed? the insured promptly.

- Are any payment terms clearly expressed?

C: Demonstration of performance Insurers and brokers must be able to - Are the currencies for any monetary amounts demonstrate their achievement of principles A clearly identified? and B. D: In respect of contract changes Contract changes need to be certain and - Does the contract contain or reference the specific documented promptly. wordings and/or clauses?

Where there is more than one participating - Can it be confirmed that there are no remaining insurer terms to be agreed?

E: When entering into the contract The contract must include an agreed basis on - Are any provisions for the notification and which each insurer’s final participation will be agreement of claims clearly expressed? determined. The practice of post-inception over-placing compromises Contract Certainty and must be avoided.

F: After entering into the contract The final participation must be provided to - Does the contract define the applicable Law and each insurer promptly.

Jurisdiction, unless agreed otherwise?

G: Where the contract has not met the principles

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The insurer and broker (where applicable) have a responsibility to resolve exceptions to any of the above principles as soon as practicable and without any undue delay.

- Where a wording is dependent on another wording (e.g. As expiring or As original) is the latter clearly identified or attached?

Are any relevant provisions for the agreement of changes to the contract clearly expressed?

Application of Policy MBS’ Contract Certainty policy applies to all employees’ external consultants, contractors and temporary personnel while working for the firm and its AR’s including their respective permanent and short-term employees.

All individuals should ensure they are aware of their obligations for managing and controlling Contract Certainty requirements.

Training, Advice and Guidance MBS provides training to all relevant individuals on Contract Certainty and will provide refresher training at least annually to ensure continuing awareness and details of any updates to the requirements.

All individuals are registered to access MBS’ e-learning and development platform managed by RWA Compliance Services Ltd. In the event that individuals are unable to gain access individuals have authority to contact RWA Compliance Services limited directly on 0845 020 0291 or helpdesk@rwagroup.co.uk In the event that individuals require more generalised advice and guidance, Steve Walton – Quality and Compliance Director, should be contacted or alternatively, you should email the compliance team: compliance@momentumsolutions.co.uk, or call 0116 478 3803.

Record Keeping Centralised records and management of Contract Certainty shall be maintained in place.

Records demonstrating the adherence to Contract Certainty requirements by MBS shall be overseen by our internal compliance function.

Policy Review This policy will be reviewed annually with any unscheduled reviews to take place where necessary as prompted by any event of significant change.

The review process for this policy will be led by the Individual Responsible for Compliance, reporting to the Board of Directors for final sign off and ratification of any required changes.

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INDEX Policy Statement: In conjunction with the Momentum Broker Solutions (MBS) Quality and Compliance Director, MBS has designated the above-named individuals as most suitable for the day-to-day management of MBS’ Compliance Policies.

MBS’ Quality and Compliance Director is also responsible for regularly reviewing regulatory and legislative guidance and interrelated policy statements for rule changes and requirements. This will ensure that MBS’ systems and controls in relation to this policy incorporates such amendments and that these are notified to all relevant persons as may be appropriate.

The MBS Quality and Compliance Director is responsible for ensuring that up-to-date copies of our Financial Crime Policy is readily accessible from MBS’ compliance records and available for all staff. This policy is to be available for reference and to provide guidance to any relevant employee of MBS who may require access to such information.

For the avoidance of doubt the application of this policy applies to MBS’ Appointed Representatives (AR) as is required and defined by the Financial Services Markets Act 2000 (FSMA) and Financial Conduct Authority (FCA) for the purpose of a person carrying out regulated activities.

In this context, MBS is the authorised firm referred to as the 'Principal' and MBS takes full responsibility for ensuring that the AR complies with this policy and FCA rules as appropriate.

History of changes to this document ANTI MONEY LAUNDERING (AML) Description of Location of change change

Entire Document

New document draft created

Overall Deputy Responsibility Responsibility Policy Governance Steve Walton – Quality Hazel Westwood – and Compliance Operations Director Director

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Policy Controls September 2023

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COMPLAINTS POLICY Location of change

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Description of change New Document draft created

Overall Deputy Responsibility Responsibility Policy Governance Steve Walton – Quality Hazel Westwood – and Compliance Operations Director Director

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Version

Policy Controls September 2023

September 2024

2.0

CONFLICTS OF INTERESTS Location of change

Description of change

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New Document draft created

Policy Governance Overall Deputy Responsibility Responsibility Steve Walton – Quality Hazel Westwood – and Compliance Operations Director Director

Policy Controls Last Reviewed

Next Review

Version

September 2023

September 2024

2.0

FINANCIAL CRIME Location of change

Description of change

Entire Document

New Document draft created

Policy Governance Overall Deputy Responsibility Responsibility Steve Walton – Quality Hazel Westwood – and Compliance Operations Director Director

Policy Controls Last Reviewed

Next Review

Version

September 2023

September 2024

2.0

WHISTLE BLOWING POLICY Location of change

Description of change

Entire Document

New Document draft created

Policy Governance Overall Deputy Responsibility Responsibility Steve Walton – Quality Hazel Westwood – and Compliance Operations Director Director

Policy Controls Last Reviewed

Next Review

Version

October 2023

October 2024

2.0

BREACHES AND ISSUES POLICY Location of change

Description of change

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Policy Governance Overall Deputy Responsibility Responsibility Steve Walton – Quality Hazel Westwood – and Compliance Operations Director Director

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CONTRACT CERTAINITY POLICY Location of change Entire Document

Description of change New Document draft created

Policy Governance Overall Deputy Responsibility Responsibility Matt Brunton – Howard Pepper – Broking Director Managing Director

Policy Controls Last Reviewed

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