TERMS OF BUSINESS

These Terms of Business set out the general terms under which we will provide financial services to you and the respective duties and responsibilities of both the firm and you in relation to same. Please ensure that you read these Terms thoroughly and if you have any queries we will be happy to clarify them. We will notify you if any material changes are made.

REGULATORY & AUTHORISED STATUS

John F. Loughrey Financial Services is the trading name of John F Loughrey & Associates Ltd. Our registered office is Crossview House, Letterkenny, Co. Donegal. Company registration number - 99163.

We are regulated by the Central Bank of Ireland (C5233) as an -Insurance Intermediary registered under the European Communities Insurance Distribution Regulations, 2018 and as an Investment Intermediary authorised under the Investment Intermediaries Act, 1995.

Copies of our regulatory authorisations are available on request or from the Central Bank of Ireland who hold registers of regulated firms. They can be contacted on 1890 777 777 or alternatively visit their website www.centralbank.ie to verify our credentials.

CODES OF CONDUCT

John F. Loughrey Financial Services is subject to the Consumer Protection Code, Minimum Competency Code and Fitness and Probity Standards which offer protection to consumers. These codes can be found on the Central Bank’s website www.centralbank.ie.

OUR SERVICES

John F. Loughrey Financial Services is a member of Brokers Ireland. Our principle business is to provide advice and arrange transactions on behalf of clients in relation to Protection (Life Assurance, Serious Illness Cover & Income Protection), Investments, Pensions, Savings and Deposit Accounts. A full list of insurers and product producers that we deal with is available on request.

INSURANCE INTERMEDIARY SERVICES

In relation to Protection, Life Wrapped Investments, Pensions and Savings John F. Loughrey Financial Services provides advice on the basis of fair and personal analysis.The concept of fair and personal analysis describes the extent of the choice of products and providers offered by an intermediary. The number of contracts and providers considered must be sufficiently large to enable an intermediary to recommend a product that would be adequate to meet a client’s needs.

The number of providers that constitutes ‘sufficiently large’ will vary depending on the number of providers operating in the market for a particular product or service and their relative importance in and share of that market. The extent of fair analysis must be such that could be reasonably expected of a professional conducting business, taking into account the accessibility of information and product placement to intermediaries and the cost of the search.

In order to ensure that the number of contracts and providers is sufficiently large to constitute a fair analysis of the market, we will consider the following criteria:

§the needs of the customer,

§the size of the customer order,

§the number of providers in the market that deal with brokers,

§the market share of each of those providers,

§the number of relevant products available from each provider,

§the availability of information about the products,

§the quality of the product and service available from the provider,

§cost,

§any other relevant consideration.

We will provide assistance to you on any queries you may have in relation to any policies we arrange for you or in the event of a claim during the life of a policy and we will explain restrictions, conditions and exclusions attached. However, it is your responsibility to read the policy documents, literature and brochures to ensure that you understand the nature of the policy cover; particularly for Income Protection and Serious Illness policies.

Specifically, on the subject of permanent health insurance policies we will explain to you;

A – The meaning of disability as defined in the policy

B – The benefits available under the policy

C – The general exclusions that apply to the policy

D – The reductions applied to the benefit where there are disability payments from other sources.

For a Serious Illness policy, we will explain clearly to you the restrictions, conditions and general exclusions that attach to that policy.

INVESTMENT INTERMEDIARY SERVICES

John F. Loughrey Financial Services is remunerated by commission for its investment intermediary services. Due to the extensive size of the market we provide advice on Deposits and structured productssuch as Deposit Based Tracker Bondson a Limited Analysis basis. Our advice in regard to this type of product is based on a limited number of contracts and product producers available on the market. We provide advice on the following product providers: KBC Bank, Permanent TSB, Wealth Options, Merrion Solutions, BCP, Davys, BlackBee, Broker Solutions, ITC, Conexim and Cantor Fitzgerald.

REMUNERATION

John F. Loughrey Financial Services is remunerated by commission and other payments from product producers on the completion of business; however, you may elect to deal with us on a fee basis. Where we receive recurring commission, this forms part of the remuneration for initial advice provided and the ongoing servicing of your policies.

Where fees are chargeable, or where you choose to pay in full for our service by fee, we will notify you in writing in advance and agree the scale of fees to be charged. We reserve the right to charge additional fees if the number of hours relating to on-going advice/assistance exceeds the agreed timeframe.

However, in general terms the following fees will apply.

Financial Advisor: €150 - €250 per hour (depending on the complexity and specialist skills required)

Technical Support: €75 per hour

Additional fees may be payable for complex cases or to reflect value, specialist skills or urgency. We will notify you in writing if these cases arise. If we receive commission from a product provider, this will be offset against the fee which we will charge you. Where the commission is greater than the fee due, the commission will become the amount payable to the firm unless an arrangement to the contrary is made.

CLIENT RESPONSIBILITIES & ONGOING SUITABILITY

As a client of John F. Loughrey Financial Services we will contact you to review your policies; however it is in your best interests that you also regularly review the policies we arrange for you. As your circumstances change, your needs will change. You must advise us of these changes and request a review so that we can ensure you are provided with up to date advice and products best suited to your needs. Failure to inform us of changes in your circumstances may result in you having insufficient insurance cover and/or inappropriate products.

Also, failure to disclose material information or to maintain premiums onprotection policies may result in loss of cover, invalidate a claim and render your policy void.

The firms’ services in relation to Pension, Investment and Savings products will include ongoing suitability assessments by way of issuing an annual schedule of business held and/or offering an annual client review meeting where ongoing suitability will be part of the review process and discussion held.

ANTI-MONEY LAUNDERING & CLIENT IDENTIFICATION

John F Loughrey Financial Services reserves the right to request additional information that may be required in order to comply with the AML requirements of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (as amended).

We shall not be held responsible if we are unable to effect transactions for clients due to any delay in presenting the required AML verification documentation required by Legislation.

Where the identity checks are delayed either by a failure on the part of the client or any other reason, we shall not be responsible for any loss incurred due to the delay in investing client monies.

CONFLICTS OF INTEREST

It is our policy to avoid any conflict of interest when providing business services to our clients. However, should an unavoidable conflict arise we will advise you of this in writing as soon as we become aware of the conflict of interest. If you have not been advised of any such conflict you are entitled to assume that none arises.A full copy of our Conflict of Interest Policy is available on request.

COMPENSATION SCHEME

We are members of the Investor Compensation Company Ltd (ICCL) established under the Investor Compensation Act 1998. The Scheme allows for payment, in certain circumstances, of compensation to certain clients (known as eligible investors) of authorised investment firms, as defined in that Act. A right to compensation would only arise where client money or investment instruments held by this company on your behalf cannot be returned either for the time being or for the foreseeable future and where the clients fall within the definition of eligible investor as contained in the Act and to the extent that the clients loss is recognised for the purpose of the Act. In the event that a right to compensation is established, the amount payable will be the lesser of 90% of your loss which is recognised as being liable for compensation or €20,000. Contact details for the ICCL are 01-2244955 and www.investorcompensation.ie.

We are also members of the Brokers Ireland Compensation Fund. Subject to the rules of the scheme the liabilities of its members firms up to a maximum of €100,000 per client, or €250,000 in aggregate, may be discharged by the Fund on its behalf if the member firm is unable to do so, and where the above detailed Investor Compensation Scheme has failed to adequately compensate any client of the member. Further details are available on request.

DISCLOSURE OF INFORMATION

We must gather and record sufficient information from you in order to make an offering, recommendation, arranging or providing a product or service appropriate to your needs. The information required is general personal details, needs and objectives, and your current and past financial situation. This information is not shared with external companies other than where we intend to place the business and is primarily taken so we can provide you with a suitable product. You are not obliged to give us this information, but this may result in us not being able to transact any business with you.

DATA PROTECTION

John F. Loughrey Financial Services complies with the requirements of the General Data Protection Regulations (GDPR) 2018 and the Irish Data Protection Act 2018. The data which you provide to us will be held on a computer database and in paper files for the purpose of arranging transactions on your behalf.

We are committed to protecting and respecting your privacy and take great care with the information provided by you, keeping it secure and ensuring it is only processed in ways compatible with the purposes for which it was given. To fulfil these objectives we may share information with other affiliated professionals always within the EU.

John F. Loughrey Financial Services wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.

You have the right at any time to request a copy of any ‘personal data’ within the meaning of the GDPR that our office holds about you. You have the right to have any inaccuracies in that information corrected, information erased, object to direct marketing from our office, restrict the processing of your information and any automated decision making affecting your data and portability of your data if required. These requests should be made in writing.

In accordance with legal and regulatory requirements we will retain your data on file for a minimum period of 9 years following the termination of any relationship with our office.

CCTV recording facilities are in place in our Offices. These facilities are in place for security, quality, training and verification purposes. All data captured by these facilities are managed in accordance with the General Data Protection Regulation 2018 and the Irish Data Protection Act 2018.

Detailed information regarding data protection is set out in our Privacy Statement which we will make available to you at the time of data collection. Please refer to our website www.jfl.ie for updates. If this medium is not suitable a hard copy will be provided on request.

COMPLAINTS

Whilst we are happy to receive verbal complaints, it would be preferable that any complaints are made, in writing. We will acknowledge your complaint within 5 working days and we will fully investigate it. We shall investigate the complaint as swiftly as possible and the complainant will receive an update on the complaint at intervals of not greater than 20 business days starting from the date on which the complaint

is made. On completion of our investigation, we will provide you with a written report of the outcome. In the event that you are still dissatisfied with our handling of, or response to your complaint, you are entitled to refer the matter to the Financial Services and Pensions Ombudsman (FSPO).A full copy of our Complaints procedure is available on request.

DEFAULT ON PAYMENTS BY CLIENTS:

Our firm will exercise its legal rights to receive payments due to it from clients for financial services provided. Insurers and other product producers/providers may withdraw benefits or cover in the event of default on payments due under policies of insurance or other products arranged for you. We would refer you to policy documents/product terms & conditions for details of such provisions.

ACCEPTANCE OF THESE TERMS

By signing your Factfind document you are acknowledging that you have been provided with a copy of the Terms of Business for John F. Loughrey Financial Services and you agree to the terms set out therein. In addition you agree to the provision of these services to you and in doing so you will become a client.

Our Contact details - Telephone: 074-9124002 email: info@jfl.ie

John F. Loughrey & Associates Ltd. trading as

John F. Loughrey Financial Services is regulated by the Central Bank of Ireland

Version 8- Effective date 01/03/2020