Please read the following declaration and undertaking carefully;

I understand it is a term of engagement of the Firm that;

1. I agree to comply with the Statement of Principles and FCA Rules, which affect the conduct of my role.
2. I agree to cooperate in order to enable the Firm to comply properly with any restriction or prohibition as to its business, which may be imposed under FCA rules.
3. I agree to comply with the requirements as to the acceptance of mandates and Powers of Attorney and (where acceptance is permitted by this rule) notify the Firm before any such acceptance.
4. I agree not to act on any inside information that may come to my attention, nor pass on such information, except informing the individual responsible for compliance within the Firm.
5. I agree to abide by the procedural processes and requirements of the Firm and those applicable to my role. I understand that I must undertake my role with due regard to these processes and in particular with regard to the following areas which can be of a higher risk/sensitive nature;

• Compliance Plan
• T&C Plan
• Anti Money Laundering
• Complaints
• Execution Only
• Treating Customers Fairly
• Conflicts of Interest
• Vulnerable Persons Policy
• Code of Ethics
• Data Security Procedures and GDPR rules

You agree you will conduct business on behalf of the Firm only in;

1. Circumstances where you do not carry on (or purport to carry on) in the United Kingdom any investment business where you are not an authorised or exempted person.
2. A way which ensures the business you conduct on behalf of the Firm is, and is held out as being, clearly distinct from any financial business which you carry on which is not investment business, unless that other financial business is being conducted by an approved Bank or is covered by authorisation as a Building Society.

I confirm I have not been subject to any of the following;

Charges and convictions in respect of any criminal offence of dishonesty, fraud, financial crime, or violence or other offence under legislation relating to banking and financial services, companies, insurance and consumer protection.

• Bankruptcy or bankruptcy proceedings.
• Withdrawal of authorisation on approval by another regulator
• Disqualification as a Company Director.
• Disciplinary investigation by a regulator or government body or agency.
• Dismissal.
• Outstanding judgement debts or awards.

I confirm I have no other business interests – if applicable, please give details in the above “Additional Information” box.

I authorise the Firm to make such enquiries and seek further information as it thinks appropriate. This could include the taking up of references.

Furthermore, I authorise the Firm to verify any of the information/statements provided within this declaration and within an application for employment or Form A (where applicable) of the FCA on an ongoing basis.

I declare that the information provided within this declaration and within an application or Form A (where applicable) of the FCA is complete and accurate and I undertake to immediately inform the Firm of any changes in the information provided.

I confirm that I have not resigned, or been dismissed, from my previous appointment for any reason connected with a breach (or alleged breach) of the rules of the FCA or any other regulatory body, or a conviction involving fraud, dishonesty or violence.

Fit and Proper Test Declaration

Honesty, Integrity & Reputation

I confirm when acting under any capacity, I have not been subject to any of the following;

Charges and convictions in respect of any criminal offence of dishonesty, fraud, wrongful trading, financial crime, violence or other offence under legislation. (Senior Managers and NEDS should disclose spent and unspent convictions. Certified Persons are only required to disclose unspent convictions.)

• The subject of civil proceedings or litigation, including judgement debts or arbitration.
• Knowingly been subject to an investigation into allegations of misconduct or malpractice in connection with any business activity.
• Any civil action which has resulted in findings against me by a Court.
• Disciplinary investigation by the FCA or any other regulator, professional body, government body or other agency.
• Contravention of any of the requirements and standards of the FCA regulatory system or any other regulator, professional body, government body or other agency.
• The subject of a justified complaint relating to any regulatory activities.
• Refusal of or had revoked, withdrawn or terminated any registration, authorisation, membership, licence or application to carry out a trade, business or profession.
• Involvement as a director or partner or concerned in the management of a business which has gone into insolvency, liquidation or administration.
• Involvement in any other business which has been investigated, disciplined, censured, suspended or criticised by a regulatory body, professional body, Court or Tribunal whether publicly or privately.
• Been dismissed, asked to resign or resigned from employment, or from a position of trust, fiduciary appointment or similar.
• Disqualified as acting as a director or other managerial role.

Principles and Rules of the Financial Conduct Authority

I confirm that I understand and agree to abide by the requirements and standards of the Financial Conduct Authority and in particular the FCA’s Conduct Rules.

I confirm that I have always been candid and truthful in my dealings with the FCA in the past.

Conflicts of Interest, other Business Interests and / or other Directorships

I confirm that I do not have any conflicts of interest or other business interests, which may affect my role as an Approved person.

Financial Soundness

I confirm that I am not subject to any undue financial pressures and I am able to service my liabilities as they fall due. I also agree to the firm obtaining a credit check as independent verification.

I also confirm I have not been subject to any of the following:

• I have not been subject to a bankruptcy order, an individual voluntary agreement/trust deed or arrangement with a creditor.
• Been involved with any business that has been put into liquidation, been wound up, had a petition for bankruptcy, been declared bankrupt or had an arrangement with creditors.

Reduction of Financial Crime

I am aware of my duties and responsibilities under the Anti-Money Laundering and UK Financial Sanctions guidance & legislation and will comply with the requirements at all times.

General Data Protection Regulation

I am aware of my duties and responsibilities under the General Data Protection Regulation.

Insider Dealing / Personal Account Dealing

I agree not to act on any inside information that may come to my attention, nor pass on such information except as a report to the Compliance Officer. I also confirm that all personal account dealings will be conducted in accordance with the agreed procedures and reported to the Compliance Officer at the required times.

Market Abuse Declaration (Personal Account Dealing)

Definition

Where any individual within the firm transacts, on his or her own account, in a designated investment.

Exclusions

• Government and public securities, e.g. Gilts
• Life policies
• Units within a regulated collective investment schemes, e.g. Unit Trust
• Discretionary transactions where the employee has had no prior awareness and where the firm has not exercised the discretion

Application

In essence, the rules on personal account transactions are to protect the interests of the consumer. For example, fact-finding discussions with a customer may reveal sensitive information about his/her employer; information, which could have a positive or detrimental affect on the employer’s share price. Any individual within the firm could use this to his or her advantage and may not, therefore, be acting in the interests of the customer. Furthermore, the customer could be in breach of ‘Insider Dealing’ rules as a result. Such conflicts are rare, however it is important that they are identified and that the firm always puts the client’s interests first.

Approval

All personal account transactions must be approved, in advance, by your Compliance Officer. Under no circumstances may a personal account transaction be initiated without prior approval. Approval must be granted in writing.

Back-door Personal Account Transactions

It is not permissible for any individual within the firm to procure any other person to enter into a personal account transaction with a view to circumventing. Furthermore, it is not permissible for any individual within the firm to communicate any information or opinion to any other person if he knows, or ought to know, that the other person will, as a result, enter into such a transaction, or procure any other person to do so.

Record-keeping

Personal account transactions must be notified to your Compliance Officer using a ‘request for personal account transaction approval form’.

All records must be retained by the firm and its Appointed Representatives, where relevant, for a period of not less than three years from the date the individual ceases to be engaged by the firm.

The Compliance Officer will maintain a record of received approval forms.

Declaration

I confirm that I have read and understood the above Personal Account Dealing procedures and acknowledge that these form part of my contractual obligations to the firm. Furthermore, I undertake to seek a determination from the Compliance Officer should there be any situation where it is unclear as to whether the transaction is deemed a personal account transaction or otherwise.