1) Seymour Sinclair Investments Limited is authorised and regulated by the Financial Services Authority (FSA) and are bound by the rules of the FSA. Our FSA regulation Number is 177616. If business is carried out using our services, it is done so on the basis of these Terms and our clients are bound by them.

2) We are able to offer independent advice but, if we are aware that either ourselves or one of our other customers has a material interest in business which we are transacting for you, we will advise you in writing of that interest and obtain your consent before proceeding. Although we are called Independent Financial Advisers and are regulated to give financial advice we have chosen not to give advice and work solely on an Execution Only basis for all types of business.

No advice or recommendations will be given on any investment product.

3) Execution Only - This means that we carry out and transact your instructions as regards any business arranged through ourselves. We do not give investment advice, or recommendations on any product and do not advice on the suitability of an investment product. We do not risk rate investment products. We do not give tax advice as we are not tax experts. As all business is carried out on this basis, it is the clients responsibility to ensure that the investment product is clearly understood, including the risks and advantages. All business processed through ourselves can only be done if accompanies by an Execution Only Investment Confirmation Form, which confirms that clients understands the basis under which we carrying out their instructions.

4) Mailing - Unless otherwise informed we will send mailings to you to give information on investment products. Any information included in our newsletters must not be relied upon when making an investment. An investor must always read the Key Features on any investment product before proceeding with it. If you wish to be removed from our mailing list, it is the clients responsibility to inform us. Your data will be protected under the Data Protection Act.

5) Your responsibilities - Acquisition costs, currency conversion costs and tax arising in connection with investment transactions will be your responsibility.

     - We are not liable for any depreciation of any investment or devaluation of currency. - We do not accept liability for default by any third party who is the nominal holder of your registered investment or holds documents of title or certificates evidencing title to any of your investments.

     If policy documents, Contract Notes or any other expected document etc. are not received by the client within 30 days of sending out your investment, it is the clients responsibility to contact either ourselves or the investment company concerned to confirm details of the investment. We cannot be held responsible in any way for items lost or delayed in the post. If documents are lost in the post it is usually possible for copies to be obtained via ourselves.

Clients are asked to give us instructions regarding their investments in writing to avoid possible disputes. This is usually done by the completing of an Execution Only Investment Confirmation Form. You, or we, may terminate authority to act on your behalf at any time without penalty. Notice of this termination must be given in writing and will not affect the completion of any transactions already initiated on your behalf.

     We reserve the right to refuse investments to be made through ourselves and refuse commission from investment companies. If this is the case, investors will not receive a discount and will be informed immediately in writing. If an investment is made through ourselves we will require the client to complete and sign and Execution Only and Direct Offer Investment Confirmation Form. This form will be required for each investment made.

6) Commissions - Seymour Sinclair Investments Limited receives commission from companies with whom life assurance or investments are arranged. We are required to inform a client at the point of sale the amount of the commission we will receive. This will be done either in letter form, Contract Note or as part of the key features documents that we or the relevant investment company will provide. We can rebate initial commissions paid but will retain in full any trail (renewal) commission.

     We can retain or rebate commission and usually, therefore, make no charge to clients for our advice or services. The investment company will supply you with information about the commission after the completion of each transaction. However, there are occasions when we reserve the right to charge fees and in such circumstances the basis of assessment for any charges payable will be agreed with you and confirmed in writing prior to carrying out any work on your behalf.

     As we carry out business on an “Execution Only” basis, whereby we are not offering financial advice, if you are unsure as to the suitability of an investment for your particular financial circumstances, you should seek expert financial advice before proceeding further. If you are unsure in any way about an investment we would urge you not to proceed.

     If an investment is made on an “Execution Only” basis we reserve the right to refund part or all of the initial commission received on a gross basis. The rate of rebate will be provided and agreed prior to an investment being made. Any renewal or trail commission payable from an investment will be retained in full by ourselves. If no commission is payable to us we will make no rebate or reinvestment even if informed otherwise initially.

7) Seymour Sinclair Investments Limited acts as your agent in arranging investments. We never own the investments or policy you arranged through us and the contract made is not with ourselves, but with the investment/insurance company. If a purchase telephone deal is placed by ourselves on behalf of a client, the client is responsible for paying for the deal and the amount paid must be the gross amount. Should we receive commission from another intermediary who is party to a transaction we must disclose this fact to you, but not the amount.

8) Seymour Sinclair Investments Limited has chosen NOT to be authorised to handle client's money. This means that we cannot accept cheques made payable to us nor will we handle client's cash. DO NOT MAKE CHEQUES PAYABLE TO OURSELVES If cheques are received payable to ourselves, they will be returned immediately to the investor which will delay the investment being made. No responsibility will be accepted for this delay.

     All investments will be registered in your names unless otherwise agreed in writing. We will forward all Policy Documents / Contract Notes to you within seven days of receipt. Even if requested we will not retain clients cheques for longer than 48 hours. If retained they will be held in our company safe.

9) Money Laundering - As of 1st September 2002 all applicants are required to submit three documents along with their application forms for any investment taken out. The Financial Services Authority (FSA) anti-money laundering regulations require that we satisfy ourselves as to the identity of any person(s) entering an investment. This includes 3rd party payers, Trustees, Power or Attorney and change of legal owner of policy.

     The FSA assumed responsibility for monitoring anti money laundering procedures from 1st December 2001 and new industry guidance notes were issued in the first quarter of 2002. Since then the industry has been assessing what is now required, and an agreed date of 1st September 2002 has been set for all changes to be in place.

     Independent Financial Advisers (IFAs) have a responsibility to ensure that adequate identification verification is undertaken on all relevant parties to a transaction and that satisfactory evidence of that identification is maintained. Under the Joint Money Laundering Steering Group guidance notes, IFAs are required to submit, with all application forms, an Intermediary Introduction Certificate for each party identified, along with documentation verifying both your name and address. This applies in all cases for both new and top-up business and the “Pre-1994 customer” exemption no longer applies.

     Details of the items required are as follows - Current signed full UK Driving Licence, Gas, Electricity or Telephone Bill, National Identity Card Council Tax Bill,Retirement Pension Book/Travel Pass Mortgage Statement,

10) Records - We are required to keep records of all your business transactions for seven years. You (or your agent) may inspect policies and data kept whether manually or electronically. We treat all clients' records as confidential so reserve the right to give copies of your particular records rather than allow access to files containing records about other clients. We are regulated under the Data Protection Act. We will not release any client information to third parties unless otherwise instructed to by the client. We will not sell or pass client information to any other party.

11) Locum arrangements - In the event of the absence, illness, disability or death of your financial adviser, unless alternative arrangements have already been made (in which case you will already have been advised of them), HRI Investments Limited of 2 Blade Mews, London SW15 2NF, who work in close association with Seymour Sinclair Investments Limited, will ensure that urgent transactions are carried out and unfinished transactions are completed.

12) Complaints - Under the rules of the FSA we will investigate any complaints immediately. In the first instance, please address your complaint to Mr P Rouse at Seymour Sinclair Investments Limited. We will write confirming receipt of the complaint and carry our an investigation. We will then write to the complainant a final letter giving the findings of our investigations. If after two months your complaint has not been resolved to your satisfaction, you have the right to refer your complaint to the FSA Ombudsman. Please remember when making a complaint that Seymour Sinclair Investments Limited does not give investment advice or make recommendations on any investment product and that the value of investments changing due to market forces cannot be investigated by the Ombudsman.

     Seymour Sinclair Investments Limited maintains Professional Indemnity Insurance that satisfies the level of cover stipulated by the FSA. If you make a valid claim against us in respect of the investment we make for you and we are unable to meet our liabilities in full, you may be entitled to redress from the Investors Compensation Scheme (ICS). Further information on the details covered can be obtained from the FSA or ICS.

Seymour Sinclair Investments Limited, 2 Blade Mews, London SW15 2NF.
Tel: 020 8870 7072 Fax: 020 8875 1911
Email: info@seymoursinclair.co.uk FSA No: 177616 1/04
Seymour Sinclair Investments Limited work on an 'Execution Only' or 'Direct Offer' basis, whereby no advice is given as to the suitability of particular products. As we work on this basis we rebate or reinvest most of the commission payable. The rebate or cash-back bonus will be paid to the investor by way of a cheque or if applicable reinvested back into the investment. We do not charge you fees for our services as we are remunerated by the company with whom you make your investment by way of a commission. This is paid to us either initially, or annually by what is known as 'trail commission'. This money is paid to us from the normal charges taken from your investment and not as an additional charge, and as such does not effect your investment.

If you are unsure as to the suitability of an investment for your particular financial circumstances, you should seek expert financial advice before proceeding further. If you are still unsure in any way about a type of investment or policy we would urge you not to proceed.