1. Important Information

      1. These terms and conditions govern your use of the Services available through the Munnypot website at and your relationship with us. Please read these terms and conditions carefully as they affect your rights and liabilities under the law.

      2. If you do not agree to these terms and conditions, please do not apply to use the Services.

      3. You should not treat any part of this document or the contents of the Munnypot website at, which is provided by Pavis Financial Management Limited, as constituting advice to you on taxation, legal or other matters and you should consult your own professional advisers accordingly.

      4. These Terms and Conditions and other documents referred to in them (including our Complaints Policy and Conflicts of Interest Policy) constitute a legal contract between you and us (" Agreement "), which sets out both your and our rights and obligations under the Agreement and important information regarding the Services that we will provide to you. For your own protection you should read them carefully before accepting them. You should read these Terms and Conditions in conjunction with our Privacy Notice.

      5. In these Terms and Conditions:

        1. references to "us" and "we" means Pavis Financial Management Limited providing the Munnypot service. References to "you" means any person operating an Account with us.

        2. references to statutes, statutory instruments, rules or regulations are to such statutes, statutory instruments, rules or regulations as amended or replaced from time to time.

        3. the following definitions apply:"Account" means the account you open with us in connection with the provision of the Services and which is accessible via the Munnypot website at "Agreement " has the meaning given in clause 1.4; "Applicable Law" means, as applicable to the provision of the Services described in these Terms and Conditions, all laws, rules (including the FCA Rules and any rules of any market or central counterparty or any default arrangements of any system, including any order routing system, or any trading rules or conventions in the relevant markets), regulations, rules, directives, customs, practices, decisions and usages of any relevant exchange, market, multi-lateral trading facility, central securities depository and/or clearing house or system and/or central counterparty, if any, and all applicable procedures, guidance, codes of conduct of any market or governmental or regulatory authority or any self-regulatory organisation, including without limitation, any accounting rules, fiscal regulations, anti-money laundering, terrorist financing and sanctions laws, rules, procedures, guidance and regulations, in each case as amended from time to time;"Business Day" a day (other than Saturdays, Sundays and public holidays) on which banks in London are generally open for business."FCA " means the Financial Conduct Authority, whose address is Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN ( or telephone 0845 6061234);"FCA Rules" means the conduct rules contained in the FCA Handbook, as amended from time to time."Financial Crime" means money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions, and/or any acts or attempts to circumvent or violate any Laws relating to these matters."FSCS " has the meaning given in clause 27.1; "FSMA" means the Financial Services and Markets Act 2000."ISA" means an Individual Savings Account as defined under the Individual Savings Account Regulations 1998."SEI" means SEI Investments (Europe) Ltd (Company number 03765319), a company incorporated in England and Wales, with registered offices at 1st Floor Alphabeta, 14-18 Finsbury Square, London EC2A 1BR."SEI Agreement" means an agreement we have entered into with SEI under which SEI provides clearing and settlement, safe custody and other associated services to our clients on our behalf."SEI Terms and Conditions" means the agreement entered between SEI and us, on your behalf and which is set out in Appendix 4; and"Services " has the meaning given in clause 16.2; "Terms and Conditions" means this document, together with its appendices.

    2. About Us

      1. We are Pavis Financial Management Limited (Pavis). Our registered address is 22 Cross Keys Close, London, W1U 2DW. We are registered in England & Wales and our company number is 02625986.

      2. Pavis Financial Management Limited (Pavis) is authorised and regulated by the Financial Conduct Authority. Financial Services Register No: 153871.

      3. The Munnypot service provides restricted advice. This means that we only recommend products from one provider which is currently the Vanguard Group. We have the right to be able to change the product provider by giving you 28 days' notice in writing to agree to change the product you hold, whether or not recommended by us to switch.

    3. This Agreement

      1. This Agreement will become legally binding, and we will start providing the Services to you, once:

        1. you click your acceptance to these Terms and Conditions.

        2. satisfy our suitability criteria in accordance with clause 8; and

        3. we have received confirmation of your completed Account and satisfactory money laundering verification information as set out at clause 14.

      2. We may amend these Terms and Conditions at any time. Usually, we will give you at least ten (10) Business Days' notice by email prior to amending these Terms and Conditions, however, if we are required to amend this Agreement to comply with the FCA Rules or any other Applicable Law, we may do so with immediate effect. Any amendment to these Terms and Conditions will not apply retrospectively. You will not be required to accept the amendment, which will apply automatically.

      3. A person who is not a party to this Agreement cannot enforce or enjoy the benefit of any term of this Agreement under the Contracts (Rights of Third Parties) Act 1999.

      4. This Agreement constitutes the entire agreement and arrangement between you and us and supersedes and extinguishes all previous agreements and arrangements between you, Munnypot Limited and us, whether written or oral, relating to its subject matter.

    4. Governing Law

      1. This Agreement and any dispute or claim arising out of or in connection with it (including non- contractual disputes or claims) will be governed by and construed in accordance with the laws of England & Wales

      2. The parties irrevocably agree that the courts of England (or, if you live in Northern Ireland, Scotland or Wales, the courts of that territory) will have exclusive jurisdiction to settle any dispute or claim that arises out of or in connection with this Agreement (including non- contractual disputes or claims).


  1. Our Duties to You

    1. No provision of this Agreement will be deemed to restrict, qualify or exclude any duty owed by us to you under FSMA, the FCA Rules or other Applicable Law. We do not, however, owe you any further duties except as expressly set out in this Agreement.

    2. Please note that we do not provide advice as part of the Munnypot service on any of your other investments. If you have any questions regarding your other investments, including the risks associated with investing in a particular service, product, or market, you should consider seeking independent advice. This might include, but may not be limited to, financial advice, investment, legal and tax advice. We cannot give you any legal, taxation or other advice in connection with your investments.

  2. Your Duties to Us

    1. You will be legally bound by the terms in this Agreement so it is important that, on entering it, and on a continuing basis, you agree that you have and will maintain full legal capacity and all necessary authorities, permissions, consents and powers, and have taken all necessary actions to enable you to:

      1. enter into this Agreement lawfully.

      2. give us orders and instructions and provide us with complete, true and accurate information.

      3. enter into any transactions; and

      4. grant any security interests, rights and powers referred to in this Agreement.

    2. You agree that you will:

      1. co-operate with us without delay in all matters relating to the Services and this Agreement.

      2. provide us with such information and materials as we may reasonably require in order to supply the Services and comply with FSMA, the FCA Rules or other Applicable Law. You shall ensure that such information is complete, true and accurate; and

      3. notify us without delay of any changes to your circumstances or information you provide (including in relation to your personal details).

    3. You confirm that:

      1. there is no pending or, to your knowledge, threatened, action, suit or proceeding before any court, tribunal, governmental body, agency or official, or any arbitrator that might affect, the legality, validity or enforceability of this Agreement against you or your ability to perform your obligations under this Agreement.

      2. you are now (and will be at all material times in the future) in compliance with all Applicable Laws concerning the detection of Financial Crime and you acknowledge that any transaction made by us on your instructions will be covered by statutory and other requirements relating to Financial Crime; and

      3. you are able and willing to receive the Services.

    4. You will indemnify us against any liability, cost, expense, loss or any damage incurred by us (including but not limited to professional advisors' fees) arising from your breach of this Agreement, negligence, deliberate default or fraud.

  3. Customer Categorisation

    1. For the purpose of the FCA Rules (which require us to categorise our customers into groups so that we can treat them according to their level of knowledge about investments), we will treat you as a Retail Client. This means that you are entitled to the protections that must be provided to Retail Clients under the FCA Rules. If you would like further information on the nature of these protections, please notify us by contacting the Pavis Compliance Officer at

  4. Suitability

    1. We will provide you with a suitability report based on the information you have provided to us about your knowledge and experience of investing, your financial situation and your objectives, in accordance with the relevant FCA Rules.

    2. The suitability report will set out the basis for our service, as required by FCA Rules.

    3. You will receive a suitability report before you choose to go ahead with setting up a Munnypot account. The suitability report is based on and summarises the information you supplied duringthe setting up of your online account and also summarises the advice and recommendations that we have provided to you. It is designed to ensure that you understand the recommendation(s) that we make and that you are comfortable with the proposed recommendations.You will also receive a suitability report for each goal that you set up and also when you:

      • Change the investment amount

      • Change the time frame of your goal

      • Change the risk profile of your goal

      • Make a new lump sum deposit or transfer-in an amount from another provider

    4. The decision whether to allow you to open an Account is entirely ours and we may decide for any reason, or no reason, not to allow you to open an Account. We may, at our discretion, permit you to apply for an Account again but we are under no obligation to do so and you should assume that our initial determination not to allow you to open an Account will apply to you in perpetuity. We will not be liable to you for any losses, damages or costs arising from our decision not to authorise you, or not to permit you, to open an Account.

  5. Conflicts of Interest

    1. We (and anyone connected with us) may carry out certain transactions for you where we, or another customer of ours, have a duty that may conflict with our duty to you. We will manage any such conflict or potential conflict to ensure that it does not materially affect the transactions we carry out for you. We will inform you if we consider that we cannot manage a conflict adequately.

  6. Liability

    1. We accept responsibility for any loss, damages or costs suffered or incurred by you only to the extent that such loss arises directly from our gross negligence, deliberate default, fraud and/or our wilful breach of any duties that we owe you under this Agreement, FSMA, the FCA Rules or Applicable Law. We will not be liable for any other losses, damages or costs suffered or incurred by you.

    2. We will take reasonable care in the assessment and appointment of sub-custodians, pension scheme administrators, bankers, counterparties, agents and other third parties. We accept responsibility for any loss, damages or costs incurred by you only where these arise from our, negligence, deliberate default, fraud or wilful breach of our duties in the assessment or appointment of such persons. We will not be responsible in any other circumstance for the actions of any such third parties.

    3. We do not accept responsibility for any loss, damages or costs you may incur as a result of any cause beyond our reasonable control including (but not limited to) any failure, interruption or delay in the performance of our obligations resulting from a breakdown, failure or malfunction of any internet, telecommunications or computer service or system, or any riot, civil unrest, commotion or rebellion; war or civil war (whether or not declared) or armed conflict, invasion and acts of foreign enemies, blockades, embargoes (including as to trade); any act (or credible threat) of terrorism, acts of government, local authority or regulatory body; explosion or fire, earthquake, extraordinary storm, flood, abnormal weather conditions or other natural catastrophe; any nuclear, chemical or biological contamination; or any strikes, lockouts or other industrial disputes. If such an event happens, we will take reasonable action, in accordance with the FCA Rules on business continuity, in an attempt to mitigate its effect on our ability to perform our obligations to you.

    4. All tax matters relating to your own tax position are your own responsibility and we have no responsibility towards you with regard to your personal tax position.

    5. If our performance of any of our obligations under the Agreement is prevented or delayed by any act or omission by you, we shall (without limiting our other rights or remedies):

      1. have the right to suspend performance of the Services until you remedy that default.

      2. have the right to rely on your default to relieve use from the performance of any of our obligations to you to the extent your default prevents or delays us; and

      3. not be liable for any costs or losses sustained or incurred by you arising directly or indirectly from our failure or delay to perform any of our obligations.

  7. Transfer

    1. This Agreement is personal to you, and you may not transfer or assign your rights and obligations to any third party.

    2. We may subcontract, assign or transfer our rights and obligations under this Agreement. If this occurs, you will be notified by email. Where we do this, you may authorise us to transfer any of your money/assets to a third party or to someone nominated by that person. We will only transfer your money and/or assets with your authority to another person who we believe will hold them under the FCA Rules or in respect of whom we have exercised all required skill, care and diligence in assessing whether that person will apply adequate measures to protect it. Where we intend to do this, we will give you at least ten (10) Business Days’ prior written notice.

    3. If you object to such an assignment, you may terminate this Agreement and close your Account in accordance with clause 28.1 (if applicable) or clause 28.2.


  8. Notifications

    1. We may communicate with you as reasonably necessary by telephone and/ or email. If, as a result of any unsolicited communication from us, you enter into any investment transaction you will not have the right under Section 30 of FSMA to treat that investment transaction as unenforceable.

    2. We will act only on specific and clear instructions given by you, or by a person you have notified us has the authority to act on your behalf, via the Munnypot service. You can give us instructions to make transactions on your behalf electronically using the Munnypot website at, or electronically in writing. We are not obliged to act on any instruction and, in particular we will not act on any instruction where it is unclear, illegal or against Applicable Law to do so. Where we do act on your instructions, we will do so as soon as reasonably practicable once we have received them.

    3. We may act on any instruction which we believe in good faith is from you (or someone authorised by you) without carrying out any further checks or investigations. We will not be liable for following an instruction which is not in fact genuine or for not following or investigating further any instruction we believe may not be genuine. We will not be liable for any error of transmission or misunderstanding or for the fraud of any other party (except in the case of our negligence, deliberate default or fraud as described in clause 10 of this Agreement).

    4. We will send all notices, information and other correspondence to you by email at the email address that you designated in your Account from time to time. You agree to notify us as soon as possible if you change your email address by updating it in your on-line Munnypot Account. We are entitled to rely on the last email address you provided, and an email sent to that email address by us shall be good service under this Agreement. In the event any notice, information or other correspondence is sent to you via letter, the letter will be sent to the postal address that you designated in your Account and will be deemed to be delivered on the second Business Day after posting.

    5. We may record any telephone conversations between you and us. Please see our Privacy Notice for details of how we process your personal data. These recordings are our property, and we may use them for training our staff, for managing your Account, as evidence if there is a dispute between you and us or for any other matter. We will store recordings for the period required by law or for as long as we consider appropriate.

    6. We cannot guarantee that electronic communications will be delivered successfully or that they will be secure and virus free. We will not be liable for any loss, damage, expense, harm or inconvenience caused as a result of an email being lost, delayed, intercepted, corrupted or otherwise altered or where an email is not delivered for any other reason.

    7. All communications in relation to Services provided under this Agreement will be in English.


  9. Responsibility for information

    1. You are wholly responsible for the accuracy of any information that you provide to us and we accept no liability whatsoever should incorrect information received from you result in financial loss or damage (including any costs, expenses or liabilities) of any kind. You will notify us immediately if you discover that any information, we hold for you is out of date, obsolete, incorrect, misleading, inconsistent and/or irrelevant in any way.

  10. Money Laundering, Credit Checks and Law Enforcement

    1. We have certain responsibilities under the FCA Rules and other applicable regulations to verify the identity of, and run anti-money laundering checks on, our customers prior to their investing. In order to fulfil these responsibilities, we may use a third-party identification checking service to confirm your identity when you first seek to invest and we will carry out regular monitoring checks while you remain a customer. We may also use credit reference agencies for this purpose. This will place a search footprint on your electronic file and your personal details may be accessed by third parties for the specific purpose of anti-money laundering, credit assessment, identity verification, debt collection, asset reunification, tracing and fraud prevention.

    2. By entering into this Agreement, you expressly agree that we or credit reference agencies may run any and all of these checks on you which may result in a record, and that you will not be able to make investments until and unless we are able to complete these checks to oursatisfaction. We will not be liable for any losses, damages or costs arising from the conduct of these checks, your inability to make investments while the checks are pending or as a result of the unsatisfactory completion of the checks.

    3. We are legally obliged to keep your affairs confidential. However, we may be required to make a disclosure to the National Crime Agency where we know or suspect that a transaction may involve Financial Crime. If we make a disclosure in relation to you, we may not be able to tell you that a disclosure has been made. We may have to stop providing Services to you for a period of time and may not be able to tell you why. We accept no liability whatsoever for any loss, damage or costs of any kind incurred by you as a result of having to make such a disclosure or having to stop providing Services to you.

  11. Privacy and your data

    1. Your privacy is important to Pavis. You explicitly consent to us and Munnypot Limited accessing, processing and retaining any information you provide to us for the purposes of providing our services to you. This does not affect any rights and obligations you or we have under data protection legislation. You may withdraw your consent by closing your account. If you do this, we’ll stop using your data for this purpose but may continue to process your data for other purposes and we may have other lawful grounds on which to continue processing your data (including to comply with statutory and regulatory requirements and court orders). In addition to this consent, we may have other lawful grounds for controlling and processing your personal data (including for our legitimate interests).

    2. Our Privacy Notice explains how we collect, use, disclose, transfer and store your information. It also sets out your rights regarding your information. You can find our Privacy Notice here Privacy Policy


  12. Services

    1. The Services that we will provide under the terms of this Agreement are only available to UK residents, partnerships formed under the laws of the UK or bodies incorporated in the UK that may include corporate bodies, charitable foundations and trusts (in each case who are also UK taxpayers).

    2. We will provide you with a number of different types of Services under the terms of this Agreement as follows:

      1. investment advisory services.

      2. arranging safe custody of your assets with our nominated Custodian

      3. ISA advisory services, and

      4. advisory services for your General Investment Account, (together, the "Services").

  13. Investment Advisory Service

    1. Your Account comprises personal data about you and your risk profile, and each fund that is attached to each risk profile for each of your goals within your overall investment Account.

    2. You have advised us of your risk profile(s) in your Account. On your instructions, we will use these to arrange investments in your Account. You may change your risk profile at any time by updating it on-line within your Account. We reserve the right to amend and reissue the Agreement following such change. You agree that the Account is fair and reasonable and an accurate reflection of your risk profile and savings and investment objectives, unless you notify us of any change you wish to make or where we consider changes are necessary following a periodic review.

    3. We will aim to utilise your available ISA allowance for the current tax year based on the information you provide to us in your Account relating to your existing ISA arrangements. The extent to which we can do this is limited by the products we offer. This means that we will administer your account in accordance with the cash/assets in each of your pots within your Account and in accordance with information in your Account..

    4. Once you have set your investment goal and risk profile with us for a particular fund, it is your responsibility to review your investment goals, risk profile and any ongoing contributions on an ongoing basis against your current needs and circumstances. We recommend that you carry out such a review at least once a year, although you are not obliged to do so. Please note that we will report on investment performance by reference to your goals and/or risk profile but we will not monitor your personal circumstances and will rely solely on you to inform us of any changes to your investment goals and/or risk profile.

    5. We have the right to change the investment fund range that we offer at any time. We can also add to the fund range or reduce the range available. If we decide to do this, we will notify you by email giving you reasonable notice. If we change the fund range, we may offer you the opportunity to switch your existing fund holdings into the new fund range. We will do this in writing electronically giving you reasonable notice to inform us that you wish to make the switch.

    6. Please see the general description of the nature and risks of the investments in which you may invest contained in Appendix 3 of these Terms and Conditions. Please note that we are unable to provide any guarantee as to the performance of any particular investments, or an Account as a whole.

  14. Best Endeavours

    1. Where we deal with instructions from you we will normally be required to provide best endeavours, meaning that transactions entered into should be on the best terms reasonably available. To achieve best endeavours, we will deal in accordance with our best endeavours policy, as detailed in Appendix 2.

  15. Delegation And Referrals

    1. We reserve the right to perform any of our obligations to you through the agency of an associate or any third party of our choosing. This means that we may appoint another person or entity to provide the Services to you under this Agreement. We will take all reasonable steps to satisfy ourselves that any person whom we appoint to provide any Services to you or to perform any of our obligations on our behalf is suitably competent to do so. We will ensure that all such parties commit to provide you with best endeavours as set out in the FCA Rules where this is applicable.

    2. Where appropriate in light of your Account, we may offer to refer you to third parties to provide certain additional services. We will not make any such referral without your agreement. We may also accept referrals of business from third parties.

  16. Account Statements

    1. We will provide valuation reports to you electronically. These reports will include details of all transactions during the relevant period, details of the contents of your Account, the current market value and the basis of valuation, income and interest and fees charged.

  17. Custody And Nominee Companies

    1. Pavis has selected a Custodian, SEI, to provide clearing and settlement, safe custody, post execution services and other associated services in respect of the Services we provide to you under this Agreement.

    2. Our appointed Custodian will act on instructions from us, as your agent, in providing safe custody, post execution services and other associated services to you under the SEI Terms and Conditions at Appendix 4. These Terms and Conditions form a binding agreement between you and the Custodian.

    3. We are not responsible for the provision of any post execution services although we may assist you and the Custodian in providing those services. Our responsibilities to you will cease as and from the point at which we confirm to you the execution of any order we have instructed the Custodian on your behalf.

    4. Both we and the appointed Custodian have the right to terminate the Custody Agreement. We are not obliged to provide prior notice to you before terminating the Custody Agreement or appointing a replacement of Custodian. We will notify you of the identity of any replacement we may appoint.


  18. Initial and Minimum Investment

    1. For each fund in your Account, we require an initial investment above one of the following minimum amounts:

      1. for an initial investment without a regular monthly payment, a minimum amount of £250; or

      2. for a regular payment without an initial investment amount, a minimum of at least £25 per month

    2. If you subsequently withdraw money to bring the value of a fund in your Account below a minimum investment of £250, we reserve the right to ask you to close your Account and withdraw the remaining balance due to the value being below the permissible minimum amount allowable.

  19. Fees And Charges

    1. Our fees and charges are calculated on the basis and at the rates shown and are payable as set out on the Munnypot website (which can be accessed by following this link). We reserve the right to change these rates from time to time and will notify you of any such changes by email.

    2. Any outstanding fee amounts payable by you will be deducted from your Account.

    3. We may pay (or receive from third parties) fees in relation to referrals of business.

    4. We may receive payment from or share charges with a third party. Further information about such payments or shared charges is available on request.

  20. Customer Money

    1. Any cash from time to time held in your Account will be held by the Custodian in accordance with the FCA customer money rules in one or more segregated accounts with an approved bank. Customer money accounts may include the balances of more than one customer. Customer money may also be placed on overnight or short-term deposit.

    2. We reserve the right to only make external payments to and to accept payments from the bank account stated in your Account.

  21. Tax

    1. All tax matters relating to your tax position are your responsibility and we have no liability towards you with regard to your personal tax position.

    2. If you are a resident of the UK and are investing with us, your investments will be subject to the UK taxation regime. For UK residents invested in a non-ISA account, tax will be deducted from any funds that you are invested in, by the fund provider.


  22. Complaints process

    1. Should you have any complaints in relation to the Services, please notify us by emailing the Pavis Compliance Officer at We will aim to acknowledge your complaint promptly, investigate the circumstances and report the results to you.

    2. If your complaint is unresolved eight (8) weeks from the date you first made the complaint you may refer it directly to The Financial Ombudsman Service ("FOS "). The address of FOS is Exchange Tower, London E14 9SR and the email address is Certain customers, such as larger companies and trusts may not have access to FOS.

  23. Compensation

    1. We are covered by the Financial Services Compensation Scheme ("FSCS"). You may be entitled to compensation from the FSCS in the event that we have stopped trading or are declared to be in default, and we cannot meet our obligations. This depends on the type of business and the circumstances of the claim. The FSCS offers different levels of cover for different types of business. Most types of investment business are covered up to a limit of £85,000. Further information about compensation arrangements is available from the FSCS (

    2. In the event that an investment is unable to meet its obligations, this will not in itself entitle investors to compensation from the FSCS. Likewise, if the performance of a fund does not match any illustrated benefits, investors will not, for that reason alone, be entitled to any compensation under the FSCS.


  24. Cancellation by You

    1. You have a fourteen (14) day cooling off period, starting when we open your Account or the date on which you receive a copy of these Terms and Conditions (whichever occurs latest). You can terminate this Agreement immediately during this fourteen (14) day cooling off period by giving us notice. If you terminate this Agreement during the fourteen (14) day cooling off period, we will arrange to return the value of your fund as it stands at that date. You will not be liable to pay any fees or charges due up to the date of termination, but you understand and agree that we will not be responsible for any market loss that you may incur as a result of the termination.

    2. You may terminate this Agreement at any time after the fourteen (14) day cooling off period by giving us notice, to take effect fourteen (14) days after we receive notice from you via email sent to In this case, the termination will be subject to the settlement of all outstanding transactions and fees and charges (as set out on the Munnypot website, which can be accessed by following this link). Also, we may pass on to you, any charges levied by third parties as a result of the termination of this Agreement. Transactions already in progress will be completed in the normal course of business.

  25. Cancellation by Us

    1. We may terminate this Agreement by giving you fourteen (14) Business Days' notice by email, subject to the settlement of all outstanding transactions.

    2. We may terminate this Agreement and/ or suspend your Account immediately (and, in which case, we will not be obliged to provide notice to you) if (a) you seriously or persistently breach this Agreement or the terms of use applicable to the Munnypot website at;(b) there has been, or we have reasonable grounds to suspect there has been, Financial Crime involving your Account or any transactions on your Account; (c) there has been, or we have reasonable grounds to suspect there has been, suspicious activity on your Account; (d) there has been, or we have reasonable grounds to suspect that you have committed or are about to commit a crime in connection with your Account or that your acts or omissions may cause us to cease to comply with Applicable Laws; (e) you do not satisfy any anti-money laundering requirements; (f) the amount in your Account falls below £250; (g) there is a change in law or regulation that requires us to do so or which prevents us from performing any of our obligations under this Agreement (in whole or in part); (h) you are no longer eligible for an Account; (i) you give us false, incomplete or misleading information; (j) you cease to be a resident of the UK; or(k) you or our nominated Custodian close your Account held with the Custodian (see the SEI terms and Conditions in Appendix 4).

    3. No additional amount will be payable solely for terminating the Agreement, except that you will pay a due proportion of our fees to the date of termination, the transfer charges (as set out on the Munnypot website, which can be accessed by following this link), any expenses reasonably incurred by us in giving effect to such termination and any losses incurred in settling or concluding outstanding obligations.

    4. We may charge these fees and expenses following notification to you and your subsequent instruction to us to cover such fees and expenses.

    5. On termination of this Agreement, we will, following payment of our fees and settlement of all outstanding transactions, re-register your assets and transfer your cash as you reasonably instruct us to do so. If you make no reasonable request, we will take steps to re-register your assets in your name and to transfer your cash to you.

  26. Inactive Accounts

    1. We will mark any Account as dormant if it has been inactive for at least two (2) years to protect both you and us, provided that we notify you first and you fail to respond within thirty (30) days. If you ask us, we will tell you how you can access your Account. If you have money in a dormant Account, it will remain your property (or if you die it will form part of your estate).

  27. Death

    1. In the event of your death, your Account immediately ceases to be exempt from UK income tax and capital gains tax. We will act upon instructions from an officially appointed Executor.


  1. Important Information

    1. This section contains additional terms and conditions applicable to the Stocks and Shares ISA. It should be read in conjunction with the Terms and Conditions.

    2. You are subscribing to this Stocks and Shares ISA for the current tax year and each subsequent tax year in which you subscribe to the Stocks and Shares ISA, and/or transferring to us a current tax year and/or previous tax year ISA from another ISA manager.

    3. You cannot subscribe to a Stocks and Shares ISA if you have already subscribed to any other Stocks and Shares ISA in the same tax year.

    4. To subscribe for a Stocks and Shares ISA you have to be a UK resident and a UK taxpayer aged 18 or over. Munnypot Pavis Financial Management Limited is currently unable to offer Stocks and Shares ISAs to US passport holders or US taxpayers even if they are resident in the UK.

    5. This Agreement will commence on the day we have both a valid application and receipt of your first subscription, or where you are transferring to us from another ISA manager, on the day we have both a valid transfer application form and receipt of the proceeds of transfer from your previous ISA manager.

  2. Investment Strategy

    1. Your Stocks and Shares ISA will be invested in one of the funds that we recommend to you as is in accordance with your selected risk profile set out by you in your Account, subject always to the requirements of HM Revenue and Customs.

    2. For each new tax year, all contributions to your Account will be allocated first to your Stocks and Shares ISA until the maximum subscription is reached for that year, or until your own pre-set limit. Once the maximum subscription or your own pre-set limit is reached, future contributions are allocated to the non-ISA remainder of your Account.

  3. Investing In a Stocks and Shares ISA

    1. Investments into a Stocks and Shares ISA may be by transfer of cash from an existing Account held with us or by transfer from another ISA manager (subject to HM Revenue & Customs’ ISA transfer rules).

    2. You will at all times be the beneficial owner of any investments held in your ISA. You must not use the investments and/or cash in your ISA as security for a loan except to the extent permitted by the Individual Savings Account Regulations 1998 ("Regulations").

    3. Your investments will be registered in the name of, or otherwise held to the order of SEI, as the ISA Manager's Nominee. You will at all times remain the beneficial owner of any of your investments that are held by SEI.

    4. The total of contributions to be invested in any tax year will not be more than the maximum permitted to be invested in stocks and shares by the Regulations for that tax year.

  4. Shareholders' Rights

    1. If you so request in writing, we will arrange for you to:

      1. receive the report, accounts and other information issued by a company, attend and vote at such shareholders’ meetings or unit holders’ meetings. Where you do this, we shall use reasonable endeavours, where possible, to make appropriate arrangements on the terms and within the timescales we may impose; and

      2. exercise any voting rights attached to your investments, whether exercisable at an AGM or otherwise. We are not obliged to but we may notify you of any AGMs applicable to your investments.

  5. Withdrawing Your ISA Investment

    1. You will not incur tax liabilities by withdrawing. We will send an acknowledgment of your instructions to you at the email address you designate in your Account.

    2. At your request, we will transfer all or part of your ISA investments (with the associated rights and obligations) to another ISA manager, subject to HM Revenue & Customs' ISA transfer rules.

    3. We will process your withdrawal or transfer request promptly and normally within the thirty (30) day maximum period stipulated by HM Revenue & Customs, subject to circumstances outside our control. Should you wish the withdrawal or transfer to take place at a particular time, we will endeavour to meet this request. However, in the case of transfers, we are reliant on the receiving manager and cannot guarantee to do so.

    4. You are not able to transfer in an Additional Permitted Subscription (APS) allowance to your Account on the death of your spouse or civil partner.

  6. ISA Regulations

    1. You authorise us to disclose to HM Revenue & Customs all such information as required by Applicable Law. We will notify you by email if, by reason of any failure to satisfy the provisions of the Regulations, your Stocks and Shares ISA becomes void.

  7. Delegation

    1. We will satisfy ourselves that any person to whom we delegate any of our functions or responsibilities under the terms agreed with you is competent to carry out any of those functions and responsibilities.


  1. Treating Customers Fairly

    1. We are dedicated to treating customers fairly.

    2. We are obligated by the EU Markets in Financial Instruments Directive to undertake bargains without disadvantaging its customers. In particular, Article 21.1 of this Directive specifies that we "must take all reasonable steps to obtain the best possible result, taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order."

  2. Best Endeavours

    1. We have developed procedures with our execution venue to both achieve and record that each bargain has been fulfilled according to the principle of best endeavours. The procedures will be reviewed periodically to ensure customers are treated fairly.

    2. Upon receipt of an order, relevant factors will be considered by our execution venue to achieve best endeavours including stock liquidity, ability to deal on more than one market trading system choices and any specific conditions attached to the order by the customer. If these factors and any other pertinent information are duly considered, we anticipate best endeavours will be attained for the customer. We will inform the customer if any particular bargain conditions are attached which may restrict the achievement of best endeavours.

    3. Any customer limit order will be accepted on a best endeavours basis.

    4. The principles of best endeavours apply equally to single bargains or orders which are aggregated.

    5. The principles of best endeavours do not extend to bargains for direct commodities, currency or unit trust funds should this apply.

  3. Investments

    1. Eligible investments can include:

      1. UK equities: bargains may be transacted via electronic order books, retail service providers, agency crosses, direct telephone engagement and electronic algorithmic systems.

      2. Non-UK equities: the firm's execution venue will make use of appointed market representatives to deal in overseas markets. Such representatives are also committed to achieving best endeavours for customers. When dealing in overseas investments extra factors will be considered including extra commissions incurred, applicable local taxes etc which will be reported to the customer.

      3. Bonds: Gilts may be traded on the London Stock Exchange thus price information is readily publishable. Other bonds and debt instruments may require off-market trading. Liquidity and variety of counterparties may limit the achievement of best endeavours in such instruments. The Company will keep record of such bargains.

      4. Derivatives: Derivative investments traded on an exchange and over the counter (OTC) derivatives both require a specific risk warning consent and trade details may be published in the case of exchange traded items. OTC trades may not necessarily be published thus establishing achievement of best endeavours may be restricted by the extent to which information is available.

      5. Other items: Those which do not fall into the above categories may have restricted liquidity or trade venues. Our execution venue will assume best endeavours has been achieved with reference to any information provided by the market counterparty at each transaction.

    2. Our appointed Custodian will execute the bargain as soon as reasonably practicable unless any delay will better serve the customer's interest. Bargains will be transacted in the same order as they were received unless specific bargains have conditions attached which may alter the order of priority.


  1. Investing

    1. We have set out below a summary of the nature and risks associated with the types of investments, subject to your Objectives as notified to us. This information is not intended to constitute a comprehensive statement of all the risks to which investors might be exposed and there may be others that exist now, or which may arise in the future.

    2. The main general risks associated with investing are as follows:

      1. past performance is not an indicator of future performance.

      2. the value of investments may go down as well as up.

      3. you are not certain to make a profit. You may make a loss. You may lose your entire investment.

      4. the price or value of investments may fluctuate significantly.

      5. if there are income distributions, they may also fluctuate significantly.

      6. we do not provide advice as to the suitability of transactions.

      7. inflation and deflationary pressures.

      8. tax liabilities; and

      9. shortage of liquidity.

  2. Collective Investment Funds

    1. We may offer units/shares issued by collective investment funds both in the UK and overseas, that are authorised by an approved regulator or are unauthorised.

    2. The main risks associated with investing in collective investment funds are:

      1. there are no recognised markets for collective investment funds as units/shares are issued and redeemed by the managers/operators/administrators of the funds.

      2. funds may be valued for pricing and dealing purposes either daily, weekly, fortnightly, monthly or even less frequently by the managers/operators/administrators.

      3. the prices of the underlying investments of the funds will vary according to the markets on which these are listed or traded.

      4. unregulated funds are not subject to the supervision by a regulatory body as authorised funds, and some authorised funds are subject to greater supervision than others depending on their structure; and

      5. with regard to funds in currencies other than Sterling foreign exchange rates may move in an unfavourable direction affecting adversely the valuation of investments in base currency terms.

  3. Investments Denominated In A Currency Other Than The Base Currency Of Your Account

    1. We may effect transactions on your behalf in an investment denominated in a currency other than the agreed base currency of your Account (which is the currency in which your Account is valued).

    2. A movement in exchange rates may have a separate effect, unfavourable as well as favourable, on the gain or loss otherwise experienced on the investment concerned. In addition, if you deposit collateral denominated in one currency, you may be subject to margin calls in circumstances where the obligations secured by such collateral are denominated in another currency (in addition to the risk of margin calls for fluctuations in relative values). Some currencies are not freely convertible, and restrictions may be placed on the conversion and/or repatriation of your funds including any profits or dividends.

    3. The base currency of your Account will be Sterling.


SEI Investments (Europe) Ltd
Terms and Conditions for Custody Services ("Terms")

  1. Background

    1. Pavis Financial Management Limited (the "Investment Service Provider") provides investment services to you, its customers (each a "Customer"); and has appointed SEI Investments (Europe) Ltd ("SEI"/ the "Custodian") to provide dealing and custody services for this purpose, on the basis that SEI will be directly responsible to each Customer for the custody services.

    2. These Terms set out the basis on which SEI agrees to provide custody services to the Customers and constitute a separate legal agreement between SEI and each Customer.

    3. The table at the end of these Terms sets out various expressions used with special meanings in these Terms and the meaning attributable to each of them. These expressions are used with capital letters in these Terms.

  2. Appointment

    1. These Terms take effect between the Custodian and a particular Customer from the point when the Custodian first receives Client Assets and/or Client Money to hold on behalf of that Customer.

    2. These Terms will continue to apply in relation to a particular Customer until terminated in accordance with clause 18.

    3. The Custodian will act on instructions from the Investment Service Provider, as agent for the Customer, in providing its services under these Terms.

    4. Where the consent of the Customer is required in order to provide certain services under these Terms, the Investment Service Provider will explain the position to the Customer and obtain the necessary consent. The Customer will have provided the Investment Service Provider with such consent when signing terms of business with the Investment Service Provider.

  3. Responsibilities of the Custodian

    1. The Custodian will provide the following services (the "Services"):

      • holding all Client Assets or arranging for them to be held in safe custody;

      • collecting all distributions and other entitlements arising from Client Assets and accounting for them to the Customer;

      • settling transactions to acquire or dispose of Client Assets on the instructions of the Investment Service Provider and using funds provided for the purpose by the Customer;

      • informing the Customer or the Investment Service Provider of corporate actions and other events affecting Client Assets;

      • holding money on behalf of the Customer where required for the purpose of providing the above Services; and

      • transferring all Client Assets and Client Money held on behalf of the Customer to the Customer or as the Customer or the Investment Service Provider may direct on termination of the appointment pursuant to these Terms.

    2. The Services will not include advising on or managing investments or executing transactions, which will be the responsibility of the Investment Service Provider.

    3. The Custodian will use reasonable care and due diligence in providing the Services.

    4. The Custodian will comply with the FCA Rules that apply to it as holder of Client Assets and Client Money. Nothing in these Terms will override its obligations under the FCA Rules.

    5. The Custodian will settle all transactions undertaken by it subject to the Custodian holding or receiving all necessary documents or funds and will do so on such basis as is good market practice for the type of Securities and market concerned and normally on the basis of "delivery-versus-payment" ("DVP"). In respect of transactions that the Custodian settles for the Customer on a DVP basis through a commercial settlement system the Custodian will use the DVP exemption in the FCA Rules excluding cash and securities from Client Money and Client Asset respectively. In the event that the Custodian is not able to rely on the DVP exemption (for example because settlement has not occurred by the close of business on the third business day following payment or delivery by the Customer), the Custodian will treat cash and Securities held for the Customer in accordance with the FCA Rules. The Custodian’s obligation to account to the Customer for any Securities or the proceeds of sale of any Securities will be conditional upon receipt by the Custodian of the relevant documents or sale proceeds.

  4. Responsibilities of the Customer

    1. The Customer is responsible for ensuring that all of the Client Assets are, at all times when they are held in the custody or under the control of the Custodian, free from any rights in favour of any third party (including but not limited to rights of security granted to a creditor or beneficial interests under a trust), except for:

      1. rights in favour of the Custodian or any third party engaged by the Custodian under these Terms;

      2. rights of beneficiaries under an express trust that are notified to and acknowledged by the Custodian; and

      3. rights in favour of a third party arising in the normal course of a transaction settled by the Custodian pursuant to these Terms.

    2. The Customer will pay or will reimburse the Custodian for any liability to a third party which the Custodian may suffer or incur as a result of a breach of these Terms by the Customer, except if and to the extent that the relevant expenses or liabilities arise from any negligence or breach of duty or these Terms by the Custodian.

    3. The Customer shall deliver to the Custodian or the Investment Service Provider any necessary documentation to ensure the timely processing of Securities transactions as the Custodian may reasonably require.

    4. The payment of cash or release or delivery of Securities shall be made upon receipt of instructions where relevant, and (i) in accordance with the customary or established practices and procedures in the relevant jurisdiction or market or (ii) in the case of a sale or purchase made through a Securities System, in accordance with the rule, regulation and conditions governing the operation of the Securities System.

    5. The Custodian and its sub-custodians shall not be obliged to accept Securities under these Terms which in the opinion of the Custodian are not in good deliverable form. The Custodian is not responsible for checking or otherwise responsible for the title or entitlement to, validity or genuineness, including good deliverable form, of any property or evidence of title to property received by the Custodian under these Terms.

  5. Holding and Registration of Investments

    1. The Customer authorises the Custodian to arrange for title to Client Assets to be registered or recorded in the name of: (i) the Customer (ii) a nominee company controlled by the Custodian; an affiliated company of the Custodian or; a third party with whom financial instruments are deposited; as bare trustee for each Customer or (iii) the Custodian or one or more sub-custodians chosen by it, provided the Custodian or sub-custodian is prevented from registering or recording legal title as set out in (i) or (ii).

    2. Client Assets may be held in omnibus accounts and be registered collectively in the same name for all customers and therefore the individual entitlements of each Customer may not be identifiable by separate certificates or other physical documents of title. If the Custodian or sub-custodian were to become insolvent, any shortfall in Securities so registered would be shared pro rata among all of the Custodian’s customers concerned.

    3. Where instructed to do so, or where the Custodian considers it is in the best interest of the Customer to do so, the Custodian may arrange for a third party to provide custody and/or settlement services in relation to certain Client Assets. Where the third party is an Affiliate of the Custodian, the Custodian will be responsible for the custody service provided by the third party to the same extent as if the service had been provided by the Custodian itself.

    4. Where custody services are provided by a third party which is not an Affiliate of the Custodian, the Custodian will exercise reasonable care and due diligence in selecting them and monitoring their performance, but does not guarantee proper performance by the thirdparty and will not itself be responsible if the third party fails to meet its obligations. This means that if the third party defaults or becomes insolvent, the Customer may lose some or all of their assets and will not necessarily be entitled to compensation from the Custodian. Including, in circumstances where it is not possible under the relevant national law and the registration under clause 5.1 to identify the Client Assets from the proprietary assets of the third party firm.

    5. Where the Custodian provides services in respect of Securities which are held by a third party in, or which are subject to the law or market practice of, a country outside the United Kingdom, the settlement, legal and regulatory requirements in the relevant overseas jurisdiction may be different from those in the United Kingdom and there may be different practices for the separate identification of securities.

    6. The Custodian is covered by the Financial Services Compensation Scheme (FSCS). The Customer may be entitled to compensation from the scheme up to a maximum of £85,000 (or such other value covered from time to time by the FSCS) for investment claims if the Custodian cannot meet its obligations. Further information about compensation arrangements is available from the FSCS directly. Website: Telephone: 0800 678 1100Address: Financial Services Compensation Scheme PO Box 300 Mitcheldean GL17 1DY

  6. Right of Lien Sale, Set Off and Unclaimed Assets

    1. The Customer hereby grants the Custodian a security interest in and a lien on any Client Asset and Client Money to facilitate the clearing and settlement of transaction and for debts related to the provision of Services under these Terms. The Customer further agrees to grant a security interest to third parties over Client Assets in order to recover debts where the debts relate to (i) the Customer and (ii) the provision of service by that third party to the Customer.

    2. The Custodian may divest itself of unclaimed Client Assets in accordance with the requirements as set out in FCA Rules. Under the FCA Rules the Custodian may either (i) liquidate an unclaimed Client Asset it holds, at market value, and pay away the proceeds or(ii) pay away an unclaimed Client Asset it holds, in either case, to a registered charity of its choice provided it has held that Client Asset for at least 12 years; in the 12 years preceding the divestment of that Client Asset it has not received instructions relating to any Client Asset from or on behalf of the Customer concerned; and it has taken reasonable steps to trace the Customer concerned. Any such action taken by the Custodian does not stop the Customer from making a claim in the future in accordance with the FCA Rules.

  7. Client Money

    1. Subject to the following paragraphs, the Custodian will hold Client Money in one or more of its client bank accounts with one or more deposit takers in accordance with the FCA Rules. The Custodian will pay credit interest to Customer on sterling balances in accordance with the rate of interest disclosed to Customer in the custody statement from the Custodian. The current interest rate formula used by the Custodian to calculate the rate of interest is also available on the Custodian’s website: The Custodian will not pay any credit interest on balances in any other currency. Customer acknowledges and agrees that where the rate of interest received by the Custodian is more than what is credited to Customer, the Custodian may retain such balance.

    2. The Custodian does not allow Customer cash accounts to be overdrawn, where overdrawn accounts occur the Custodian may at its discretion charge an overdraft rate at the appropriate Central Bank official interest rate.

    3. In the event of a charge being incurred by the Custodian for holding a cash balance (a negative interest rate) in its client bank accounts, the Custodian reserves the right to pass such charges to the Customer.

    4. The Custodian may hold Client Money with a third party deposit taker in an unbreakable time deposit account up to the maximum allowed by the FCA Rules. Each Customer’s cash may be placed on a mix of terms – between instant access and unbreakable term deposit up to 90 days (or the maximum). The mix of terms will be balanced by the Custodian to deliver an appropriate combination of interest, diversification of risk and timely access to cash at the individual Customer level. In the event that the Custodian places too much money on a time deposit it may take longer to return some cash to Customers.

    5. Any subsequent shortfall may be covered by the Financial Services Compensation Scheme for bank deposits up to a value of £85,000 (or such other value covered from time to time by the FSCS), depending on the individual circumstances for each Customer. (See FSCS contact information in clause 5.6 above).

    6. The Custodian will hold qualifying money market funds the Customer or the Investment Service Provider elects to purchase as safe custody assets and not as Client Money. As a result, the qualifying money market funds will not be held in accordance with the client money rules but instead in accordance with the custody rules as set out by the FCA.

    7. The Custodian may allow another person such as an exchange, a clearing house or an intermediate broker, to hold or control Client Money, but only where this is required for the purpose of a transaction for the Customer through or with that person or to meet an obligation of the Customer to provide collateral for a transaction. In the event of a shortfall following any default of such person, the Customer may not receive their full entitlement and may share in that shortfall pro rata. The Investment Service Provider will inform the Customer and provide further details if this is to occur.

    8. The Custodian may arrange for Client Money to be held in a bank outside the United Kingdom. Where it does so, the rights of the Customer in relation to that money will differ from those applicable under the United Kingdom regulatory regime.

    9. Where the Customer has instructed the Custodian to pay charges to the Investment Service Provider on the Customer’s behalf, the Custodian may use Client Money for this purpose.

    10. To the extent that an amount is due from the Customer to the Custodian or a third party provider under clause 6 in connection with these Terms, the Custodian may use Client Money or Client Assets to pay that amount.

    11. In the event that the Custodian determines that there is a legal and/or regulatory requirement for it to rebate to a Customer any commission received, then the rebate will become due and payable to the Customer at such time as is determined by the Custodian in accordance with its internal procedures.

    12. Where the Custodian transfers any part of the custody services it provides to a Customer to another appropriately authorised institution chosen by the Custodian, the Customer authorises the Custodian to transfer any Client Money held for that Customer to that appropriately authorised institution provided the transferee agrees to hold the Client Money in accordance with the FCA Rules.

    13. The Custodian may cease to treat any unclaimed balance allocated to an individual Customer as Client Money in accordance with the requirements as set out in the FCA Rules. The Custodian may pay away to a registered charity of its choice a Client Money balance which is allocated to a Customer and if it does so the released balance will cease to be Client Money provided the Custodian has held the balance concerned for at least six years following the last movement on the Customer’s account (disregarding any payment or receipt of interest, charges or similar items); and the Custodian has taken reasonable steps to trace the Customer concerned to return the balance. Any such action taken by the Custodian does not stop the Customer from making a claim in the future in accordance with the FCA Rules.

  8. Contractual Settlement


    1. The Custodian may make available a provisional credit of settlement, maturity or redemption cash proceeds, or income and dividends on a contractual settlement basis or predetermined income basis, as the case may be ("Contractual Settlement"), in markets and for Securities deemed appropriate for that practice by the Custodian and agreed with the Customer.

    2. Where Contractual Settlement is extended on a sale, redemption or maturity event, the corresponding Securities shall be debited from the securities account and held by the Custodian or sub-custodian pending settlement. Securities purchased will not be available for use until actual settlement.

    3. The Custodian reserves the right to reverse any such credit at any time before actual receipt of the item associated with the credit when the Custodian determines in its reasonable judgement that actual receipt may not be received for that item. Where it is possible theCustodian will give advance notice of the reversal (but it shall not be obliged to do so where the Custodian determines it need to act sooner or where the Custodians ability to recover may be compromised). Where there is any requirement of reversal of previously advanced cash the Custodian may charge the appropriate Client Money account for the expense of providing funds associated with the advance pursuant to clause 7.2 and 7.3 of these Terms.

    4. Any provisional credits provided under these Terms shall be considered as cash advance for the purposes of clause 6 of these Terms to the extent they cannot be reversed in accordance the preceding clauses.

  9. Conflicts of Interest

    1. The Custodian has adopted a formal policy with a view to ensuring that in any situation in which its interests conflict with those of Customers and /or the Investment Service Provider, all parties receive fair treatment. A summary of that policy is set out in Appendix 1.

  10. Custody Fees

    1. The Customer will not have to pay any fees to the Custodian for the provision of the Services provided the Customer continues to use the Services via the Investment Service Provider. The Custodian will receive fees and be reimbursed for expenses as agreed between the Custodian and the Investment Service Provider.

  11. Reporting & Valuation/Pricing

    1. The Custodian will provide each Customer with periodic statements of their Client Assets and Client Money held by the Custodian at least once per quarter in accordance with the FCA Rules.

    2. To the extent that the Custodian provides values of, and pricing information in relation to Securities, the Custodian may use generally recognised pricing services including brokers, dealer, market makers and the Investment Service Provider. The Custodian shall not be liable for, and makes no assurance or warranties in relation to, the accuracy or completeness of such value or information.

  12. Limits on Liability

    1. Neither the Custodian nor the Customer will be liable to the other under or in connection with these Terms for any:

      1. loss of profit;

      2. loss of revenue, loss of production or loss of business (in each case whether direct, indirect or losses that are not directly associated);

      3. loss of goodwill, loss of reputation or loss of opportunity; or

      4. loss of anticipated savings or loss of margin.

    2. The Custodian and the Customer will only be liable for costs which are incurred as a direct consequence of the event which led to the other making a claim under these Terms.

    3. The Custodian will not be liable to the Customer for any inaccurate, misleading or unfair information issued or produced by fund managers under these Terms.

    4. Nothing in these Terms will exclude or limit a party’s liability that:

      1. the Custodian or the Customer may incur to the other in respect of death, personal injury, fraud, under the FCA rules or any other kind of liability that by law cannot be excluded;
        or in the case of:

      2. any failure by the Custodian or an Affiliate to account for assets or cash to the person entitled to them under these Terms or otherwise to comply with its obligations under the FCA Rules, unless any such failure by the Custodian or an Affiliate is the result of the acts or omissions of Customer or the Investment Service Provider.


    5. Each of the Custodian and the Customer will take reasonable steps to mitigate any loss for which the other may be liable under these Terms.

    6. Neither the Custodian nor the Customer will be liable under or in connection with these Terms for any breach of these Terms resulting from any reason or circumstances beyond the reasonable control of the Custodian or, as the case may be, the Customer.

  13. Data Protection and Confidentiality

    1. In order to provide the Services, the Custodian may store, use or process personal information about the Customer that is provided to it from the Customer and/or the Investment Service Provider in accordance with and subject to the Data Protection Legislation. The Custodian collects and uses the personal information because it has contractual, legal and regulatory obligations it has to discharge. Further information about the personal information the Custodian collects and uses is set out within the Custodian’s privacy notice available on its website: .

    2. Any information about the Customer that the Custodian has access to that is of a confidential nature shall be treated as such, provided that it is not already in the public domain. The confidential information will only be used as necessary for the provision of the Services. The Custodian may also disclose the information about the Customer to third parties (including its Affiliates) in the following circumstances:

      1. if required by law or if requested by any regulatory authority;

      2. to investigate or prevent any illegal activity;

      3. in connection with the provision of the Services; or

      4. at the Customer’s request or consent.

    3. By entering into these Terms, the Customer acknowledges and agrees that the Custodian is allowed to send personal information about the Customer internationally including to countries outside the European Economic Area (EEA) such as the United States of America. Where transfers outside the EEA are made, the Custodian will always take steps to ensure that information about each Customer is protected in a manner that is consistent with how personal information will be protected in the EEA. Any such transfers outside the EEA will be made in accordance with the Data Protection Legislation.

  14. Disputes

    1. If the Customer has any questions or comments in relation to the Services, these should be raised in the first instance with the Investment Service Provider. If the Customer wishes to make a formal complaint about the Services this should be sent to the Investment Service Provider marked for the attention of SEI or directly sent to SEI at the following address:
      The Compliance OfficerSEI Investments (Europe) LtdP.O. Box 73147London EC2P 2PZ

    2. If SEI do not deal with the Customer’s complaint about the Services to his/her satisfaction, the Customer may be able to refer the matter to the Financial Ombudsman Service at:
      The Financial Ombudsman Service Exchange TowerLondon E14 9SR
      Telephone: 0800 023 4567 Email:

    3. Subject to the above, any dispute or difference arising out of or in connection with these Terms or the provision of the Services will be subject to the jurisdiction of the English courts.

  15. Regulatory Information

    1. SEI is authorised and regulated by the Financial Conduct Authority ("FCA") and entered on the FCA’s register with number 191713. The FCA’s address is:
      12 Endeavour Square LondonE20 1JN

    2. SEI will treat each Customer as a retail client under the FCA Rules, giving them the greatest level of protection under the FCA Rules.

    3. SEI’s contact details are:
      SEI Investments (Europe) LtdP.O. Box 73147London EC2P 2PZ

  16. Law and Language

    1. These Terms are governed by and shall be construed in accordance with the laws of England.

    2. All communications from SEI to Customer under these Terms will be in English.

  17. Variation

    1. The Custodian may change these Terms by giving the Customer at least 60 days’ written notice, unless shorter notice is required in order to comply with the FCA Rules. This would be for reasons such as:

      • to take account of changes in legal, tax or regulatory requirements;

      • to fix any errors, inaccuracies or ambiguities we may discover in the future;

      • to make these Terms clearer; and/or

      • to provide for the introduction of new or improved systems, methods of operation, services or facilities.

    2. If the Customer does not agree with any change that the Custodian proposes to make, the Customer should inform the Custodian by communicating its concerns with the Investment Service Provider.

  18. Termination

    1. The Custodian may terminate these Terms at any time by giving the Customer 60 days’ written notice (subject to applicable law and regulatory requirements). There is no minimum duration of these Terms.

    2. The Custodian may also terminate these Terms with immediate effect by written notice if required to do so for legal or regulatory reasons or on instructions from the Investment Service Provider.

    3. On termination, the Investment Service Provider will instruct the Custodian where to transfer the Client Assets and Client Money. If the Investment Service Provider does not do so promptly, or if the Investment Service Provider no longer represents the Customer, then the Customer will on request give the relevant instruction. The Custodian will transfer Client Assets and Client Money in accordance with the relevant instruction or, if it is unable toobtain instructions, it will transfer them to the Customer. These Terms will continue to apply until such transfer of the Client Assets and Client Money is complete.

    4. The Customer can withdraw the Client Assets and Client Money from the Custodian at any time.

  19. Interpretation and Table of Defined Expressions

    1. The Custodian’s duties and responsibilities are those expressly set out in these Terms and are limited to those set out in these Terms unless agreed otherwise in writing.

    2. The headings in these Terms are only for convenience and do not affect its meaning.

    3. The singular shall include the plural and vice versa.

    4. In these Terms, each of the expressions defined below has the meaning set opposite it.




      means any body corporate in the same group (as defined in the Financial Services and Markets Act 2000) as SEI.

      "Central Bank"

      interest rates.

      "Contractual Settlement"

      as defined in clause 8.1


      means each individual or legal entity that enters into a Customer Account Application with the Investment Service Provider and whose accounts are serviced by the Investment Service Provider appointing SEI to provide dealing and custody services.

      "Customer Account Application"

      means the forms used by the Investment Service Provider to provide SEI information in relation to each Customer for the purposes of enabling SEI to open each account.

      "Client Assets"

      means Securities held by SEI on behalf of the Customer from time to time in any form in accordance with these Terms.

      "Client Money"

      means cash in any currency held by the Custodian on behalf of the Customer from time to time in accordance with these Terms.

      Data Protection Legislation

      means all applicable data protection and privacy legislation in force from time to time in the UK including the General Data Protection Regulation ((EU) 2016/679); the Data Protection Act 2018; the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003 No. 2426) as amended; any other European Union legislation relating to personal data and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data.


      means the Financial Conduct Authority of the United Kingdom and any of its successor to all or part of its functions.

      "FCA Rules"

      means the Handbook of Rules and Guidance of the FCA as amended from time to time.


      means securities, financial instruments and such other similar assets as the Custodian may from time to time accept into custody under these Terms and shall, where appropriate to the context, include certificates evidencing title to Securities.

      "Securities System"

      means a generally recognised book-entry or other settlement system or clearing house or agency, acting as a securities depository, or transfer agent, the use of which is customary for securities settlement activities in the jurisdiction(s) in which the Custodian carries out its duties under these Terms and through which the Custodian may transfer, settle, clear, deposit, or maintain Securities whether in certificated or uncertificated form and shall include any services provided by any network service provider or carriers or settlement banks used by a Securities System.

Further information about SEI and frequently asked questions about its custody services are available on the SEI website.



SEI Investments Europe Limited (SIEL) - Summary Conflicts of Interest Policy

(A) Introduction

SEI Investments Europe Limited ("SIEL"), as a global multi-service firm, is likely to find itself in situations where the interests of one client of SIEL may compete with:

    • those of another client of SIEL; or

    • the interests of SIEL (or members of the Group to which SIEL belongs (i.e. the "SEI Group")); or

    • the interests of SIEL’s managers, employees, appointed representatives (or where applicable, tied agents) or any person directly or indirectly linked to them by control ("Relevant Persons").

In accordance with Article 47(1)(h) of Commission Delegated Regulation (EU) 2017/565 (the "MiFID Org Regulation") and the Financial Conduct Authority ("FCA")’s Conduct of Business sourcebook ("COBS") 6.1ZA.2.1 EU 47(1)(h), this document represents a summarised version of SIEL’s Conflicts of Interest policy, which SIEL maintains in accordance with Article 34 of the MiFID Org Regulation, the FCA’s Principles for Businesses – Principle 8 and relevant applicable rules contained in Chapter 10 of the FCA’s Senior Management Arrangements, Systems and Controls sourcebook ("SYSC").

This summary document sets out SIEL’s approach to identifying and preventing or managing conflicts of interest which may arise during the course of its business activities. Further details of SIEL’s Conflicts of Interest policy can be provided upon request.

(B) What are conflicts of interest?

During the course of investment services and activities and ancillary services carried out by or on behalf of SIEL, there are a number of circumstances which constitute, or may give rise to, or may beperceived to be, a conflict of interest entailing a risk of damage to the interests of one or more clients. The three main categories of potential conflicts of interest include:

  • Situations may arise where the interests of SIEL (or the SEI Group) conflict with those of a SIEL client. This includes, for example, any instances where SIEL (or SEI) is likely to make a financial gain, or avoid a financial loss, at the expense of the SIEL client or where it has an interest in an outcome which differs from SIEL’s client’s interest.

  • Situations may arise where the interests of a client conflict with those of other clients. This includes, for example, where there is a financial or other incentive to favour the interest of another client or group of clients over the interests of the client, or a situation where confidential information about one client could be provided to another.

  • Situations may arise where the interests of Relevant Persons conflict with the interests of a client of SIEL. For example, a conflict of interest may arise where Relevant Persons receive from a person, other than the client, an inducement (in the form of monies, goods, or services) in relation to a service provided to the client other than the standard commission or fee for that service.

(C) Identification of conflicts of interest

SIEL has appropriate internal controls (including a periodic review of business activities and specific transactions) to identify and record circumstances which constitute, or may give rise to, or may be perceived to be, a conflict of interest and whose existence may damage the interests of a client. These arise or may arise in the course of SIEL providing certain investment and ancillary services or a combination thereof and include those caused by the receipt of inducements from third parties or by SIEL’s own remuneration and other incentive structures. SIEL has an ongoing management reporting process for potential and existing conflicts of interest.

(D) Records of conflicts of interest

As required, SIEL keeps and regularly updates its record of the types of services or activities carried out by or on behalf of SIEL in which circumstances, which constitute, or may give rise to, or may be perceived to be, a conflict of interest and whose existence may damage the interests of one or more clients, have arisen or, in the case of an ongoing service or activity, may arise.

(E) Circumstances in which conflicts of interest may occur

  • SIEL or a Relevant Person is likely to make a financial gain or avoid a financial loss, at the expense of the client;

  • SIEL or a Relevant Person has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;

  • SIEL or a Relevant Person has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client;

  • SIEL or a Relevant Person carries on the same business as the client; and

  • SIEL or a Relevant Person receives or will receive from a person other than the client an inducement in relation to a service provided by SIEL, in the form of monetary or non-monetary benefits or services.

(F) Arrangements to prevent or manage of conflicts of interest

As part of SIEL’s organisational and administrative arrangements, SIEL has specified procedures, which are followed, and measures that have been adopted, to prevent or manage conflicts of interest.In addition to the existence of relevant governance arrangements, escalation procedures to senior management (including SIEL’s Board, where appropriate), relevant guidance and specific training provided to SIEL employees and appropriate segregation of SIEL employees’ duties and responsibilities, the following are examples of SIEL policies which, among other things, specify measures and controls adopted by SIEL in order to prevent or manage conflicts of interest:Conflicts of Interest policy (internal guidelines for employees, related to identification, prevention

and management of conflicts of interest)

Remuneration policy

Suitability policy

Order Handling & Execution policy

Client Communications policy

Incidents, Breaches and Complaints policies and procedures (including SIEL’s Route Cause Analysis policy)

Personal Account Dealing policy

Inducements (including Gifts & Benefits) policy

(G) Disclosure of conflicts of interest

To the extent that the organisational and administrative arrangements established by SIEL to prevent or manage its conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of the client will be prevented, SIEL will disclose this fact to the relevant client(s) together with a specific description of the conflicts of interest that arise in the provision of the relevant investment and/or ancillary services. Such description will explain the general nature and sources of conflicts of interest, as well as the risks to the relevant client(s) that arise as a result of the conflicts of interest and the steps undertaken to mitigate these risks, in sufficient detail to enable that client(s) to take an informed decision with respect to the investment or ancillary service in the context of which the conflicts of interest arise.Last Updated 29/09/2022