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Plum GIA/ISA: Investment Terms and Conditions

for users opening a Plum Investment Account for GIA and/or ISA

Contents

Section 1 – General Terms of the Plum Investment Account

Section 2 – GIA/ISA Product Provider Terms

Section 3 – Plum’s Conflicts Management Policy

Section 4 - Order Handling and Best Interest Policy

Section 5 - Customer investments and risks

Section 6 - Glossary

Section 1 - General Terms of the Plum Investment Account

This page tells you about the legal terms and conditions ("Investment Terms") on which we provide Plum users with access to a Plum Investment Account.

These Investment Terms, together with the Plum General Terms and Conditions and any terms to which these documents refer, will apply to any contract between us relating to our Investment Services ("Investment Contract"). Please read these Investment Terms carefully and make sure that you understand them, before applying for a Plum Investment Account. Please note that before you can open a Plum Investment Account you will be asked to agree to these Investment Terms. If you refuse to accept these Investment Terms, you will not be able to open a Plum Investment Account.

If there is anything contained in these Investment Terms that you do not understand, please do not hesitate to get in touch with us. You can email us at help@withplum.com.

We may amend these Investment Terms from time to time as set out in clause 13.7 of the Plum General Terms and Conditions.

These Investment Terms, and any Investment Contract between us, are only in the English language.

  1. General

    1. In these Plum Investment Terms, references to "Plum", "us", "our" and/or "we" and/or "GIA/ISA Product Provider" means Saveable Limited.
    2. References to "client", "you" and/or "your" mean any person who opens a Plum Investment Account with us.
    3. In these Investment Terms "WithPlum" means the interface we provide to access the Investment Services and any other product or service offered by us from time to time.
    4. In these Terms, capitalised terms and expressions shall have the meanings given to them in the Glossary below or the Plum General Terms and Conditions, unless the context requires otherwise.
  2. Our regulated status

    1. In respect of our Investment Services, these are provided by Saveable Limited, a company registered in England and Wales under company number 09777255 and registered at 2-7 Clerkenwell Green, EC1R 0DE London. Saveable Limited is authorised and regulated by the Financial Conduct Authority ("FCA") (registration number 739214).
  3. Our Investment Services

    1. We will provide services (the "Investment Services") that integrate with your Plum Account including the following:
      1. opening GIA/ISA Platform Products and making available to you the tools to manage your GIA/ISA Platform Products;
      2. relaying your instructions you have made through WithPlum to us to transact in investments and execute in accordance with the investment selections;
      3. providing information (including the value of your portfolio) about your Platform Product(s) and investments held by us (including the value of your portfolio);
      4. the provision of the features and services that help you to make decisions and place instructions with or through WithPlum in relation to your Plum Account and your Investment Account; and
      5. making arrangements for you to be provided with dealing, safe-custody, settlement and post-execution transaction services by us.
  4. Complaints

    1. Should you have any complaint(s) in relation to the Products and Services, please notify us in accordance with this clause. Your complaint will be acknowledged within one (1) Business Day after receipt and arrange for the matter to be investigated in accordance with the applicable laws and rules of the FCA.
    2. In the first instance please contact Plum at help@withplum.com. If your complaint relates to a service provided by Plum and not by a Third Party Provider of Plum, we will immediately carry out an investigation of your complaint in line with our complaints policy and will provide a written response, communicating the outcome of the investigation with you.
    3. If your complaint relates to a service provided by any of our Third Party Providers, we will notify them of your complaint, they will investigate the complaint and we will then respond to you with a final response no later than by the end of eight weeks after receipt of the complaint.
    4. Complaints must be submitted to us either via email or via our help widget in our in-app.
    5. If your complaint is unresolved or not settled to your satisfaction within the applicable timeframe, you may refer it directly to the Financial Ombudsman Service (FOS) within six months of the date of the sent (or should have been sent) final response to you. Details of the FOS:


      Financial Ombudsman Service

      Exchange Tower London, E14 9SR

      Email: complaint.info@financial-ombudsman.org.uk

      Telephone Numbers:  0800 023 4567 (helpline),  0207 964 1000  (switchboard),  +4420 7964 1000  (for calls from outside the UK),  020 7964 1001  (main fax)  0300 123 9 123  (calls to this number cost no more than calls to 01 and 02 numbers)

      Website: www.financial-ombudsman.org.uk

  5. Compensation

    1. You may be entitled to compensation from the Financial Services Compensation Scheme ("FSCS") in respect of certain Investment Services ch The FSCS pays compensation for financial loss only to eligible claimants when an authorised firm is in default and will carry out an investigation to establish whether or not this is the case. The scheme provides protection if an authorised investment firm is unable to pay claims against it. The amount of compensation depends on the basis of your claim. The current maximum levels of compensation for investments are £85,000 per person per firm. Compensation levels are subject to change and for up to date details please refer to www.fscs.org.uk.
    2. If your investment underperforms or loses value because of market movements, this is not covered by the FSCS. Your capital is at risk when investing in a Fund through Plum.
    3. The FSCS will only be relevant to ‘protected claims’ which may arise from our Investment Services.
    4. Further information about compensation arrangements is available here and from the Financial Services Compensation Scheme website (www.fscs.org.uk).
  6. The GIA/ISA Product Provider

    1. References to “GIA/ISA Product Provider” means Saveable Limited.
    2. Saveable Limited, provides the “GIA/ISA Platform Products”, being General Investment Account (or “GIA”) and the “Individual Savings Account” (or “ISA”) that are made available to you through WithPlum.
    3. This Investment Contract (as it applies to the GIA/ISA Product Provider) and in particular Section 2, Part A and B – GIA/ISA Product Provider Terms, together with
      1. the information we have provided to you about the GIA/ISA Product Provider services and costs and charges; and
      2. the information you have provided to you us under these Investment Terms in respect of the GIA/ISA Platform Products; and
      3. any applicable Key Features Document constitute the agreement (the "GIA/ISA Product Provider Agreement") between us.
  7. Commencement and status of the GIA/ISA Product Provider

    1. The GIA/ISA Product Provider Agreement will be legally binding when you accept these Investment Terms. However, we will only start to provide the Platform Services to you if, and when, you open a Platform Product and, accordingly, those terms relating to the Platform Product will only be applicable after that time. The GIA/ISA Product Provider Agreement has no minimum duration period.
    2. The GIA/ISA Product Provider Agreement is governed by the laws of England and Wales. If any provision of the GIA/ISA Product Provider Agreement is or becomes invalid or unenforceable, the relevant provision will be treated as if it were not in the GIA/ISA Product Provider Agreement, and the remaining provisions will still be valid and enforceable.
  8. The GIA/ISA Product Provider

    1. You have entered into an agreement with us for the provision of the GIA/ISA Platform Products and dealing, safe custody, settlement and post-execution services. The additional terms that apply to the services provided to you and the GIA/ISA Platform Products are set out in Section 2, Part A (the "GIA and ISA Product Provider Terms") of these Terms and where you choose to invest in an ISA, the provisions in Section 2, Part B (the "Additional ISA Terms").
      1. we are authorised to agree and enter into the GIA/ISA Product Provider Agreement (in accordance with your instructions);
      2. the GIA/ISA Product Provider Agreement forms a legally binding agreement between you and us. Accordingly, we will be responsible for providing you the GIA/ISA Platform Products and with safe custody, settlement and post-execution services;
      3. we are authorised to take instructions (as provided in these Investment Terms, including the GIA and ISA Product Provider Terms) and is entitled to rely on such instructions and information without further contacting you directly;
      4. we are authorised to hold cash and investments on your behalf and is authorised to transfer cash and/or investments from your GIA/ISA Platform Products to meet your settlement and other obligations under these Terms; and
      5. we are authorised to terminate the appointment with us and to transfer the GIA/ISA Platform Products and the assets and cash in relation to your GIA/ISA Platform Products to an alternative provider selected and appointed by us, provided in doing so we act in your best interests and in accordance with the FCA Rules and all applicable laws.
    2. This arrangement means that you will remain a client of ours, and we will continue to be responsible to you for the Investment Services. We are directly responsible to you for the provision of the GIA/ISA Platform Products and the related dealing, safe-custody, settlement and post-execution services.
    3. We will notify you of the identity and terms of any replacement GIA/ISA Product Provider in good time before any changes are made.
  9. What being a ‘retail client’ means

    1. We will provide our Investment Services on the basis that you are a Retail Client as defined in the FCA Rules. This means that you are entitled to the protections provided for Retail Clients under the FCA Rules and relevant legislation. If you would like further information on the nature of these protections, please ask us by email.
  10. Selecting investments

    1. Through WithPlum you are able to select and invest in a selection of investment funds (the "Funds") that we have arranged to make available to you. For more information about the Funds please see our FAQ.
    2. We do not provide financial advice to our clients and we will never make recommendations based on your personal circumstances. If you are not sure whether our Investment Services, the GIA/ISA Platform Products, or the Funds are suitable for you then we recommend that you seek advice from a qualified financial adviser.
    3. Prior to making any decision to invest, you must read the "Key Investor Information Document" or "KIID" relating to the relevant Fund. The KIIDs contain important information of which you should be aware. You can access the KIIDs via WithPlum.
    4. We will not provide you, or be responsible for providing you, with any financial, legal or tax advice. Please note that certain provisions contained in these Terms and within the Plum product(s) set out information relating to tax treatment. You should note that tax treatment depends on individual circumstances and our current understanding of law and HMRC practice, which may be subject to change in the future.
  11. Fees for the Plum Investment Services

    1. We reserve a right to charge a fee for the Products and Services we provide to you. All fees you may have to pay to us are listed on the Plum Website.
    2. If the available funds are insufficient we may sell assets held as part of your Investment Account to cover such charges.
    3. For full details on fees, please see Plum’s website, https://withplum.com/investments/ and the related section of the FAQ.
  12. Opening your Plum Investment Account and making Contributions

    1. Before we can open your Plum Investment Account and provide the Investment Services to you, we are required to verify your identity in accordance with UK anti-money laundering legislation. We will use various third-party services to do this and you acknowledge that this will involve us transmitting your personal information to such third parties as set out in our Privacy Notice.
    2. You warrant and represent to us on an ongoing basis that:
      1. You are aged 18 or over;
      2. You are UK resident for tax purposes; and
      3. You are not a US Person for the purposes of residency, citizenship or tax.
    3. You agree to notify us immediately if any of the above warranties cease to be correct.
    4. Contributions to your GIA/ISA Platform Product may be single or regular and can only be paid from your Plum Account, or such other methods as we may otherwise specify. Contributions may be subject to certain minimums and maximums. We may change the minimum or maximum contributions from time to time and will notify you.
    5. Contributions will be debited from your Plum Account and transferred to us and held in accordance with Section 2 (GIA/ISA Product Provider Terms), Part A (“GIA and ISA Product Provider Terms”), paragraph 4 (Cash and Investments) below.
  13. Communications

    1. You can give us instructions electronically through WithPlum. Where we do act on your instructions we will do so promptly. We will not act on any instruction if it would be illegal or contrary to any rule or regulation for us to do so.
    2. We may communicate with you about your Investment Account at any time through the Plum App or, where appropriate SMS and email.
    3. We may act on any instruction which we reasonably believe to be from you. We will not be liable if we carry out an instruction which is not genuine or for not investigating any instruction we reasonably believe to 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, wilful default or fraud. We are not obliged to acknowledge receipt of your instructions.
    4. We will send all notices, information and other correspondence to you by email and/or at the email address you have provided for your Plum Account or such other email address as you may designate from time to time. In the event any notice, information or other correspondence is sent to you by letter, the letter will be sent to the current postal address you have recorded in your account and will be deemed to be delivered on the second Business Day after posting.
    5. We may record and monitor our communications with you. We will store relevant communications for at least the period required by law.
    6. We cannot guarantee that electronic communications between us will be successfully delivered. We will not be liable for any loss, damage, expense, harm or inconvenience caused as a result of an email being lost, not delivered, delayed, intercepted, corrupted or otherwise altered.
    7. All communications between us will be in the English language.
  14. Instructions given via WithPlum

    1. When you use and interact with WithPlum to select and/or make changes to your Plum Investment Account, the GIA/ISA Platform Product(s), and/or indicate your intention to undertake an investment transaction, such use and interaction will constitute your instructions to us.
    2. Section 2 of these Terms sets out our obligations and duties with respect to instructions in relation to your GIA/SIA Platform Products. You acknowledge and agree that all instructions and authorisations given by you in relation to the GIA/ISA Platform Products and the investments made in respect of your Plum Investment Account must be sent by you personally and by no other person.
    3. You acknowledge and agree that all instructions are effective when they are received by us. When we receive an instruction from you we will use all reasonable endeavours to ensure that the instruction is executed as accurately and as soon as possible.
    4. When relaying instructions from you to buy and/or sell your investments, we shall apply our Order Transmission Policy which is set out in Section 4 of these Terms. By entering into the Plum Terms, you agree and consent to our Order Transmission Policy.
    5. Where a delay occurs in transmitting an instruction due to factors outside of our reasonable control (including, without limitation, where WithPlum is unavailable) we will ensure that your instruction is executed as soon as reasonably possible. However, we will not otherwise be responsible for any delay. In such circumstances please contact help@withplum.com.
  15. Withdrawals of Investments

    1. If you wish to make a Permitted Withdrawal you must provide instructions to us.Subject to the terms of your GIA/ISA Platform Product (if applicable), to meet withdrawal requests, we will realise the investments to provide you with the cash sum required and will pay the net sale proceeds into your Plum Account. We will credit your Plum Account with the withdrawal proceeds as soon as practicable, but you should note that the process of selling investments may take some time, depending on the settlement dates of those investments.
  16. Reports and Contract Notes

    1. We are responsible for providing to you all contract notes in respect of all investment transactions carried out by you via the Plum Account and all reports that are required to be provided to you in accordance with the FCA Rules - including valuation reports ("KIID"). These Reports will include details of all transactions during the relevant period, details of the contents of your Plum Account, the current market value and the basis of valuation, income and fees charged. In accordance with the FCA Rules and applicable legislation, you will be provided with Reports quarterly.
    2. We will make daily valuations of your GIA/ISA Platform Products available to you.
    3. By entering into this Investment Terms and the GIA/ISA Product Provider Agreement you agree and consent to the electronic delivery of contract notes and Reports and all other information required to be provided to you under those Agreements. We will send all such contract notes and Reports to the most recent email address you have provided to us.
  17. Conflicts of interest

    1. We or anyone connected with us, may carry out certain transactions for you where we 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 adequately manage a conflict.
    2. Our Conflicts of Interest Policy is set out in Section 3 which describes some of the actual or potential conflicts of interest which may arise and provides our policy about how these are managed. We will from time to time update our policy and you may obtain the latest policy from us at any time upon request.
  18. Liability

    1. Subject to the FCA Rules, we shall not be liable for any losses suffered by you unless such loss arises from our negligence, breach of the Plum Terms, wilful default, fraud, or from our failure to comply with applicable laws or the FCA Rules.
    2. We will not be held liable for any loss incurred by you which arises, either wholly or in part, as a result of an event which is beyond our reasonable control to prevent and the effect of which is beyond our reasonable power to avoid in relation to your Plum Account and which may arise from delays or changes in market conditions, market fluctuation, currency fluctuation, computer failure, labour dispute, inability to communicate with you and/or the GIA/ISA Product Provider, or for any other reason and whereby we are either unable to take or refrain from taking or shall not be obliged to take or refrain from taking any action as a consequence thereof.
    3. We will take reasonable care and exercise reasonable due skill, care and diligence in the assessment, selection and appointment, custodians, bankers, counterparties, agents and other third parties. We accept responsibility for any losses, damages or costs suffered or incurred by you to the extent these are caused by our negligence, wilful default or fraud in the assessment, selection or appointment, and ongoing monitoring of such persons. We will not be responsible in any other circumstance for the acts or omissions of any such third parties.
    4. We do not accept responsibility for any loss, damages or costs you may incur as a result of:
      1. any cause beyond our reasonable control to prevent (as described in paragraph 18.2 above); and/or
      2. our taking any action, or omitting to take any action, to the extent we are required to do so under applicable laws and regulations, the FCA Rules and/or at the direction of a competent regulator such as the FCA.
    5. No provision of the Plum Terms will restrict, qualify or exclude any duty owed to you under applicable laws relating to the provision of services or under the FCA Rules. For further information about your rights under these applicable laws contact your local Citizens’ Advice Bureau.
  19. Delegation

    1. We may appoint another person or entity ("Delegate") to perform all or part of the Investment Services, provided that we take all reasonable steps to ensure that such Delegate is (and remains) suitably competent and qualified to do so. Where we appoint a Delegate:
      1. this will not affect our liability to you for the Investment Services we have delegated; and
      2. this will be undertaken in accordance with these Investment Terms and all applicable laws and the FCA’s Rules.
  20. Referrals

    1. Where appropriate, we may offer to refer you to third parties to provide certain additional services. We will not make any such referral without your agreement.
    2. We may pay (or receive from third parties), fees in relation to referrals of business. In making or receiving any such referral and making or receiving such payments, we will act in accordance with the FCA Rules and all applicable laws.
  21. Termination

    1. Without affecting your use of other services provided by affiliates of Saveable Limited, you may terminate this Investment Contract at any time and for any reason by providing us with notice, subject to the settlement of all outstanding transactions. Transactions already in progress will be completed in the normal course of business. In order to be able to close your Investment Account, all investments will need to be transferred out. Once that is done, we will proceed to close your Investment Account as soon as practicable after receiving your notice to terminate the Investment Contract.
    2. If you decide to close your account with Plum, we will treat that as notice to terminate this Investment Contract, realise any assets and cash held in your GIA/ISA Platform Products and close your Investment Account.
    3. Our fees shall continue to apply until the later of the date of the termination of the Investment Contract or the settlement of all outstanding transactions in respect of your Plum Investment Account.
    4. We may also terminate the Investment Contract immediately if:
      1. we reasonably believe that providing you with a service exposes us to action or censure from any law enforcement, government or regulatory body (including, without limitation, the FCA);
      2. either you or we close your GIA/ISA Platform Product(s).
    5. Where we terminate the Investment Contract immediately, we will inform you in writing immediately of our decision and our reasons for making that decision.
    6. On termination of the Plum Agreement, as may be applicable, we will re-register your assets and transfer your cash as you reasonably request. If you make no reasonable request, we may, at our discretion, take steps to re-register your assets into your own name and to transfer your cash to you, or take advice from HMRC as to the appropriate steps in the circumstances.
    7. Please also see the ISA Terms set out in Section 2, Part B ("Additional ISA Terms") of this document for additional termination provisions with respect to your ISA.


Section 2 – GIA/ISA Product Provider Terms


Part A – GIA and ISA Product Provider Terms

Please note that this is an important document that sets out how the GIA/ISA Platform Products are operated. It sets out the terms and conditions for the GIA/ISA Platform Products. It should be read as part of the overall Investment Terms.

In these GIA and ISA Product Provider Terms, references to "Plum", "us", "our", "we" and/or "GIA/ISA Product Provider" and/or means Saveable Limited. Saveable Limited is a company registered in England and Wales under company number 09777255 and registered at 2-7 Clerkenwell Green, EC1R 0DE London. Saveable Limited is authorised and regulated by the Financial Conduct Authority ("FCA") (registration number 739214). It provides the dealing and custody service and acts as the ISA manager for the Plum ISA.

  1. General

    1. In accordance with your instructions and your selections, we shall provide the GIA/ISA Platform Products and shall provide dealing, safe custody, settlement and post-execution services in respect of your investments (together, the “GIA/ISA Platform Services”). Where you have selected a ISA, then the additional terms set out in the section headed "Part B: Additional ISA Terms" also apply.
    2. We will at all times provide the GIA/ISA Platform Services to you in accordance with the terms of the GIA/ISA Product Provider Agreement, all applicable laws and all applicable FCA Rules.
    3. If you materially breach these Terms then we reserve the right, without further notice, to close your GIA/ISA Platform Products, withdraw access to the GIA/ISA Platform Service, require you to transfer out your GIA/ISA Platform Products to an alternate provider, or any combination of these.
    4. We do not provide advice about GIA/ISA Platform Products or allowable investments. The GIA/ISA Platform Products are only available to direct investors. If for any reason you are unsure about or do not understand these Terms or any other aspect of the products or services, then you should seek appropriate financial advice BEFORE making any commitment.
    5. We will act on all instructions transmitted to us through WithPlum.
    6. The value of each GIA/ISA Platform Product must be maintained above the minimum value of £1. Plum may change the minimum value from time to time and will notify you of any such change. In the event that the value of a Platform Product remains below this value for more than a 12-month period, then the GIA/ISA Product Provider may close your relevant GIA/SIA Platform Product by giving notice to you.
    7. The GIA/ISA Platform Products are only available through Plum and all reports and documentation will only be provided to you for access through Plum. By applying to take out a GIA/ISA Platform Product, you agree that you do not require us to provide reports, statements, contract notes or other documentation associated with your GIA/ISA Platform Product other than in electronic form via these means. You must also keep contact details up to date so that we can notify you of any important information or documents.
    8. You accept that where we are required to provide you with written notice then this will be given to you by means of electronic correspondence as set out above.
    9. There may be circumstances that require us to review these Terms and the charges being made. In this event, we will notify you advising you of any amendments to these Terms at least 30 days prior to the change taking effect. However,we reserve the right in extreme circumstances to vary these Terms with shorter notice e.g. a change to an existing, or implementation of a new regulatory requirement where we have to take action immediately.
    10. Value Added Tax will be levied on all appropriate expenses and fees and charged at the prevailing rate.
    11. You authorise us to provide HMRC, the FCA and any other relevant authority with all the information about your GIA/ISA Platform Product(s) and its investments, as required to do so by them.
    12. We reserve the right to sell investments if there is insufficient cash to meet the amount of any ongoing costs or charges.
  2. Opening GIA ISA Platform Product(s)

    1. Your GIA/ISA Platform Product will be set up when we receive all necessary information from you or when all of our requirements have been met if this is later. We reserve the right to refuse your application for a GIA/ISA Platform Product without providing any reason for our decision.
    2. You may not open a GIA/ISA Platform Product if you are a US Person (as defined by the US Internal Revenue Service). If at any point you become a US Person, then you must immediately inform us and we will require you to close your GIA/ISA Platform Product(s).
    3. You may only open a GIA/ISA Platform Product if you are a UK resident over the age of 18. If you cease to be a UK resident, then you must inform us immediately.
    4. You have the right to cancel your GIA/ISA Platform Product. We will send you a cancellation notice and you have 30 calendar days from its applicable implementation date to inform us that you wish to cancel. We will follow any investment instructions that you have given to us during this cancellation period. If you choose to cancel during the cancellation period, any investments held in your GIA/ISA Platform Product(s) will be sold and we will return any contributions. The amount to be returned may be less than the amount paid to us if the value of the investments has fallen at the time they are sold. We will also deduct any fees and charges due.
  3. Contributions to your GIA/ISA Platform Product(s)

    1. Contributions to your Platform Product are made in accordance with Section 1 (General Terms), paragraph 12 (Opening your Plum Account and making Contributions).
    2. We support “Transfers In” to your GIA/ISA Platform Product(s).
    3. We may decline any Contribution entirely at our discretion.
    4. All Contributions we receive will be applied to your relevant GIA/ISA Platform Product.
  4. Cash and Investments

    1. All monies received by us in respect of your GIA/ISA Platform Products will be held by us in a Client Money Bank Account. Client Money Bank Accounts are designated as trust accounts and are segregated from our own funds in accordance with the FCA Rules on Client Money. Client Money Bank accounts are pooled accounts with one or more banks. In the event of a bank’s failure, your claim will be for a share of the cash held in all pooled accounts at the bank.
    2. When considering where a Client Money Bank Account should be held, we will exercise all due skill, care and diligence and will periodically review the adequacy and appropriateness of any bank or credit institution where Client Money is deposited and of the arrangements for holding Client Money. It is important to note that we are not responsible for any acts, omissions or default of a credit institution or bank chosen by us, only for taking care in our choice and monitoring of such bank of credit institutions.
    3. Interest may be paid to us by banks with which it holds deposit accounts on your behalf. Currently no interest will be paid to your GIA/ISA Platform Product(s). If interest becomes payable on any of your GIA/ISA Platform Products, the rates of interest will be disclosed to you and the we will (and you authorise the us to) deduct such charges as HMRC imposes from time to time on interest payments. We will retain any differences between the interest received from the banks and the amounts paid to your GIA/ISA Platform Product.
    4. Dividends or other income received will be credited to your GIA/ISA Platform Product on the day of receipt wherever practicable but no later than 10 Business Days after receipt. Any income received in the form of cash will be credited to your GIA/ISA Platform Product.
    5. All investments other than cash are held by the us in a pooled investment (omnibus) account in the name of our nominee or by an approved third-party custodian. This means that individual client entitlements may not be identified by individual entries in the records of the nominee. If there is a shortfall following default by the nominee, all client accounts will share proportionally in that shortfall. We do not accept responsibility for the default or failure of a custodian or nominee. However, this does not limit our liability to you for our own respective fraud, wilful default, or negligence.
    6. Investments held within your GIA/ISA Platform Products must not be used as a security for a loan, except as provided for in the ISA Regulations.
    7. We will not be responsible for any loss (including loss of profit) in relation to, or diminution in value of, any investment:
      1. acquired by us at your request; or
      2. not acquired by us or not disposed of by us in accordance with our rights under these Terms; or
      3. disposed of by us in accordance with these Terms unless such loss or diminution in value results from our fraud, wilful misconduct, negligence or breach of regulatory duty or the fraud, wilful misconduct, negligence or breach of regulatory duty of any of our employees or agents.
    8. We will be entitled to dispose of any investment if in our reasonable opinion continued retention of such investment would or may be unlawful, contrary to the Regulations, impose tax or other costs on us or expose us to liabilities.
    9. We will be entitled to dispose of any investment if required to do so by the terms of any agreement to which we are a party. We will make all reasonable endeavours to inform you of such an event in advance, where feasible.
    10. We will use reasonable endeavours to promptly notify you of a Corporate Action notified to us by a company or third-party custodian where relevant. There may be instances when we are not notified of a Corporate Action (or are not provided with sufficient information in time) and as a result are unable to pass on the details to you. In such circumstances, we will not be liable to you for any loss suffered.
    11. When a mandatory Corporate Action (an event initiated by a public company that will bring an actual change to the securities—equity or debt—issued by the company) is announced where no option is available to shareholders and no firm payment date is known in advance, we will notify you only after the new securities or cash have been received and credited to your GIA/ISA Platform Product.
    12. We may, at our sole discretion, not make available to you all the choices that are offered by the company relating to the Corporate Action.
    13. If you wish to benefit from a Corporate Action that entails the payment of cash from your GIA/ISA Platform Product(s), e.g. a rights issue, it is your responsibility to ensure that there is sufficient Available Cash to to satisfy the payment when it falls due.
    14. We will not credit to you and we will be entitled to retain fractions of shares arising from Corporate Actions where we cannot reasonably allocate these to your GIA/ISA Platform Product.
    15. We do not pass on shareholder perks and will not become involved in any shareholder interest groups.
    16. We will place an electronic copy of your quarterly and annual statements detailing the investments and transactions on your GIA/ISA Platform Product(s).
    17. You specifically agree that the GIA/SIA Product Provider may transfer client money to another provider in connection with a transfer of part or all of its business. Any such client money transferred will be held by that third-party in accordance with the FCA Rules on Client Money, or if such monies will not be held in accordance with the FCA Rules on Client Money, the GIA/SIA Product Provider will exercise all due skill, care and diligence in assessing whether adequate measures will be applied by the third party to protect such monies.
  5. Fees, Charges, and Expenses

    1. The fees and charges payable to us and the timing of these fees in respect of the GIA and ISA Platform Products are set out in Plum’s website, Plum Investments, and the related section of the FAQ
    2. We will also be entitled to charge the following costs to your GIA/ISA Platform Product: all taxes, duties, or levies to us becomes liable as a result of acquiring, holding, or disposing of any investment or other asset allocated to your GIA/ISA Platform Product(s) and from making any payments from your GIA/ISA Platform Product(s).
    3. Provided, in doing so we act at all times in accordance with all applicable laws and the FCA Rules, we may reasonably reimburse ourselves in respect of the liability, charges or costs by way of making a charge to your GIA/ISA Platform Product(s) as we may reasonably determine that we have incurred as a result of one of the following events occurring:
      1. we become liable to pay any levies in relation to the Financial Services Compensation Scheme; or
      2. we become liable to pay any tax or levies imposed on your GIA/ISA Platform Product(s) or on any contribution paid by you; or
      3. we become liable to make any other payment to the UK Government or any governmental agency or self-regulatory organisation of which we are (or become) a member, to the extent directly or indirectly attributable to your GIA/ISA Platform Product(s).
    4. These clauses 5.2 and 5.3 will not apply to the extent that the relevant event is attributable, directly or indirectly, to any fraud, negligence, wilful default, or regulatory breach by us. 5.5. If we omit to deduct all or part of any charges from your GIA/ISA Platform Product on the due date, we shall not subsequently be prevented from deducting such amounts or exercising any available remedy because of that omission.
    5. We may also deduct cash from and/or sell any of the investments in your GIA/ISA Platform Product to realise cash if your GIA/ISA Platform Product has been credited in error.
    6. Charges, costs, and liabilities which we are entitled to charge you will be paid from your Available Cash. If at any time the Available Cash is not enough to cover all such charges, costs, and liabilities in full, we may:
      1. dispose of investments at our discretion and without liability, to pay the amounts due; or
      2. require you to pay it the amounts due.
    7. If we disposes of your investments in accordance with paragraph 5.7 of this Section 2, Part A then we will, ordinarily, sell your investments to meet the amount due in the following order:

        your Funds, starting with the largest holding by value; and then

        any other investment.

    8. We may sell slightly more of your investments than is needed due to:
      1. The fact that we cannot know the exact price at which the investments will be traded, and any excess will be held as Available Cash; or
      2. The requirement to maintain a minimum holding value for each investment.
    9. If for any reason the value of your investments is insufficient to meet any such fees, charges, expenses, or tax payable, you agree to pay us on demand the amount of any such shortfall.
    10. We will continue to be entitled to our charges and to recover all costs and liabilities as referred to in the above terms until all the assets of your GIA/ISA Platform Product(s) have been Transferred Out of or fully Withdrawn from your GIA/ISA Platform Product(s)in accordance with these Terms.
  6. Dealing

    1. We are responsible for executing any Order it receives from you through WithPlum. You may only place Orders for Funds as part of a GIA/ISA Platform Product.
    2. You may only place Orders through WithPlum. If this is unavailable for any reason, please contact help@withplum.com.
    3. You are responsible for the accuracy of your Orders. You may not be able to cancel or change an Order after you have submitted it.
    4. You must have sufficient Available Cash or Available Investments to settle any Order that you place together with any related charges.
    5. We reserve the right for any reason to refuse to execute an Order, but we will act reasonably in so doing. There may be circumstances, including (without limitation) suspension of dealing in extreme market conditions in which we may not be able to execute an Order. Wewill, if possible, notify you of the reason. Provided we have acted reasonably, then we will not be liable for any loss or profit forgone between the time an Order was received and when it was executed, if ever.
    6. We may combine your Order with other clients’ Orders if it reasonably believes that this will not be to your disadvantage. We may have to execute your Order in tranches and provide an average price per Order.
    7. If we receive an Order via WithPlum, then:
      1. In the case of an Order to buy a Fund, arrange to pass that Order on the next Dealing Day to the relevant Fund Manager for execution; and
      2. In the case of an Order to sell a Fund, arrange to pass that Order no later than the next Business Day to the relevant Fund Manager.
    8. Our records of the time of receipt and execution of an Order will be conclusive unless it is obvious that it is wrong.
    9. You must notify us if you receive confirmation of an Order which you did not place, or which has not been completed in accordance with your instructions.
    10. We will send to you contract notes confirming the details of your transaction by the end of the Business Day on which we receive confirmation from the market of the terms under which your Order has been executed, or in relation to Funds, by the end of the Business Day after we received it from the relevant Fund Manager.
  7. Transfers Out and Withdrawals

    1. You can request the transfer of your Platform Product(s) to another provider at any time by providing written notice, subject to the applicable legislation and HMRC regulations. You may instruct us to Transfer Out in specie and/or as cash, and this will be executed as soon as reasonably practicable. For ISA transfers, the following timelines apply:
        • Transfers between cash ISAs should take no longer than 15 working days.
        • Other types of transfers should be completed within 30 calendar days.
      A Transfer Out in specie will be subject to the prevailing Transfer Out charges outlined in the relevant GIA/ISA fees schedule.
    2. If you request a Permitted Withdrawal from your GIA/ISA Platform Product, then you must sell sufficient of your Available Investments so that you have enough Available Cash for the payment plus any applicable charges. You may only make one Permitted Withdrawal at a time.
    3. All Permitted Withdrawals must be paid to an account in your name, or as otherwise prescribed in the specific terms relevant for each GIA/ISA Platform Product. You must supply to us all information and documentation we require to complete all necessary anti-money laundering checks. These checks must be concluded to our satisfaction before any payment can be made to your designated account.
    4. If you instruct us to Transfer Out or Withdraw all the investments and cash from your GIA/ISA Platform Product then we will continue to act upon other Orders that you provide to us (through WithPlum), including the collection of Direct Debits and dealing.
    5. Once all the Available Cash has been Withdrawn from your GIA/ISA Platform Product, we will regard that GIA/ISA Platform Product as being closed unless you continue to make Contributions.
    6. If your GIA/ISA Platform Product is closed for any reason other than a breach by you of these Terms, then we will continue to provide you with information relating to your GIA/SIA Platform Product for at least 18 months after the date upon which the relevant GIA/ISA Platform Product was closed so that you can obtain, inspect and download all necessary information.
  8. Personal Information

    1. We may use your personal information, including your sensitive personal information, and store it on our systems and may otherwise process it for the administration of your GIA/ISA Platform Product(s). We need to know your personal information in order to provide you with the services you have engaged us to provide and to ensure that your account is administered as efficiently as possible. This includes such information as is required to comply with all legal and regulatory requirements. You can here find our full Privacy Policy.
    2. We will not collect personal information from you that we do not need in order to provide the services we have agreed to provide to you.
    3. We may pass personal information relating to you to associates, banks or the firm for administering your GIA/ISA Platform Product in order to verify your identity and by dealing with us you confirm that you accept and consent to this. We may also need to seek additional information from you to verify your identity, in which case we may:
      1. ddelay your application; or
      2. return and cancel your application; or
      3. withhold from you the ability to trade or withdraw any Funds until we successfully verified your identity.
    4. We may disclose personal information if it is required to do so by law or are requested to do so by HMRC, the FCA, or any other relevant authority with the powers to request such information.
    5. You can ask questions about how we have handled your personal information or raise a complaint about how we have handled your personal information, by emailing our Data Protection Officer at dpo@withplum.com. If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). For further information about the ICO and their complaints procedure visit https://ico.org.uk/concerns/.
  9. Availability of the Service

    1. We cannot guarantee that access to, or trading in, your GIA/ISA Platform Product(s) via WithPlum will be available at all times or without delay. You acknowledge that the service may be interrupted and the services available may be variable in certain circumstances.
    2. We may suspend the operation of our service where we consider it necessary, including (but not limited to) where we have to suspend operations for technical problems, emergencies, maintenance, regulatory reasons, where we decide it is sensible for our clients’ protection, in periods of exceptional trading activity or to ensure the continued availability of other services.
    3. We will not be liable to you if our systems or services are unavailable to you for trading or information purposes due to Events Beyond their Control.
  10. Market Abuse

    1. By placing Orders with us, you agree that you will not take part in activity which may be considered market abuse. You agree that you will not in any way engage in market abuse or require or encourage others to do so. If you are uncertain as to whether your dealings or proposed dealings are lawful, you should take legal advice. If we have reason to suspect that your GIA/ISA Platform Product is being used to engage in market abuse, we reserve the right to take any action deemed to be appropriate. This action will include but is not limited to, refusing to act on your instruction and in such circumstances.
  11. Assignment and Delegation

    1. We may appoint any person (whether connected to us or not) to advise on or perform any of its functions or responsibilities under these Terms.
  12. Events Beyond our Control

    1. An "Event Beyond Our Control" mmeans any act or event beyond our reasonable control, including without limitation strikes, lock-outs, or other industrial action by third parties, civil commotion, riot, invasion, terrorist attack or threat of terrorist attack, war (whether declared or not) or threat or preparation for war, fire, explosion, storm, flood, earthquake, subsidence, epidemic or other natural disaster, or failure of public or private telecommunications networks.
    2. We will not be liable or responsible for any failure to perform, or delay in performance of, any of our obligations under these Terms that is caused by an Event Beyond Our Control. If an Event Beyond Our Control takes place that affects the performance of our obligations under these Terms we will implement our business continuity procedures and notify you as soon as reasonably practicable and our obligations under these Terms will be suspended and the time for performance of our obligations will be extended for the duration of the Event Beyond Our Control.
    3. You may terminate the contract if an Event Beyond Our Control takes place and you no longer wish us to provide the GIA/ISA Platform Product(s).
  13. Termination

    1. These Investment Terms, as amended, will continue to apply until the provision of your GIA/ISA Platform Product(s) is terminated. All charges or fees due up to the date of termination must be paid. Termination shall be without prejudice to the completion of transactions already initiated by, or with, us on your behalf.
    2. If we terminate or suspend the provision of your GIA/ISA Platform Product(s), then we reserve the right to encash all investments and hold the proceeds in cash pending receipt of instructions from you.


Part B: Additional ISA Product Provider Terms


  1. ISA Terms

    1. Our ISA is a Stocks and Shares ISA and will be managed in accordance with these Terms and the applicable ISA Regulations. If there is a conflict between these Terms and the ISA Regulations then the ISA Regulations will prevail.
    2. You must be a UK resident to subscribe to an ISA. If you hold an ISA and you cease to be a UK resident, you must inform us immediately. Subscriptions to your ISA are not permitted whilst you are not a UK resident, but we will keep your ISA open.
    3. You may only subscribe to an ISA from your own funds. You may also transfer other Cash ISAs or Stocks and Shares ISAs you may have to this ISA.
    4. You must not subscribe to a Stocks & Shares ISA if you have already subscribed to any other Stocks and Shares ISA in the same tax year, unless you are transferring that ISA to us.
    5. You are responsible for ensuring that subscriptions to your ISA are within allowable limits set out in the ISA Regulations. If instructed by HMRC we will return any oversubscription without your further authority.
    6. This is not a Flexible ISA. Therefore, you cannot withdraw and replace the money in the same tax year without the replacement money counting towards your annual ISA allowance i.e. all subscriptions to your WithPlum ISA will count towards your annual ISA subscription limit.
    7. Additional ISA subscriptions (i.e. subscriptions to this ISA in excess of the annual ISA subscription limit as a result of the death of a spouse or partner) are not supported by this product.
    8. If you cancel your ISA in accordance with paragraph 2.4 of Section 2, Part A: GIA/ISA Product Provider Terms, the following applies:
      1. Any subscriptions received will be returned to your Bank Account
      2. If you cancel a transfer from another ISA, we will seek to return the transfer to the original ISA manager. Where they refuse to accept the return of the transfer or only accept it on revised terms that are not acceptable to you, then you are required to provide, within 30 days, one of the following alternative instructions:
        1. transfer to an alternative ISA manager of your choice,
        2. disapply the cancellation request and retain the transfer within this ISA,
        3. disinvest and retain the money within your Plum Account as a Cash Balance to await further instruction from you, or
        4. disinvest and pay the money into your Bank Account.
      3. In the absence of any instruction from you under 8.2 then clause 8.2.4 will be actioned.
      4. The amount to be repaid may be less than the amount paid to us if the value of the investments has fallen at the time they are sold. We will also deduct any fees and charges due.
    9. If any investment in your ISA ceases to be permitted by the ISA Regulations, then we shall inform you of the options available. If we do not receive an appropriate response within 30 days, then it reserves the right to sell that investment.
    10. In the event of your death the tax advantages of your ISA will continue but no new subscription or transfers-in are allowed. Your account will be designated a continuing account of a deceased investor and it will remain open until the earlier of:
      • The completion of the administration of your estate;
      • The closure of the account by your executors;
      • The third anniversary of your death.
      After the third anniversary of your death, if the account still remains open, the tax advantages will be removed. It will no longer be deemed an ISA and will become subject to all Terms and Conditions as a GIA.
    11. You can request us to transfer all of your Current Tax year’s ISA, and all or part of your previous tax years’ ISAs, held with us to another ISA plan manager. Transfers out in specie are subject to administration fees.
    12. You will need to contact your new ISA plan manager and make arrangements in accordance with their requirements. Your new ISA plan manager will need to contact us to arrange for the transfer.
    13. Where investment income is received net into your ISA, we will reclaim tax where permitted by, and in accordance with, current HMRC regulations. We will reclaim UK tax paid on income, where appropriate, for the previous tax year ending on the 5th April. We will reclaim it by the 5th October. Any tax reclaim received will be credited to your ISA.


Section 3 – Plum’s Conflicts Management Policy


  1. Introduction

    1. We are committed to taking measures to recognise, supervise, examine and resolve conflicts of interest. We recognise that it is not possible to eliminate all sources of conflict of interest; however, treating our customers fairly and in accordance with FCA Rules and principles remains our primary objective. This policy encompasses the relationships with customers and third-party contacts.
  2. What is a conflict of interest?

    1. A conflict of interest is a situation in which Plum (or any of its personnel) finds itself in a position where its own interests conflict with the duties and obligations owed to its clients or, a situation in which Plum’s duty to one client conflicts with its duty to another.
  3. Identifying conflicts of interest

    1. For the purposes of identifying the types of conflict and potential conflicts that arise which may entail a material risk of damage to the interests of a client, we must consider whether Plum or its directors, employees, or contractors ("Plum Personnel") or any other person linked by control to Plum:
      1. is likely to make a financial gain, or avoid a financial loss, at the expense of a client;
      2. has an interest in the outcome of a service provided to a client or transaction carried out on behalf of a client, which is distinct from the client’s interest in that outcome;
      3. has an incentive to favour the interest of another client or group of clients over the interests of the client;
      4. carries on the same business as a client, or
      5. receives or will receive from a person other than a client an inducement in relation to a service provided to the client, in the form of remuneration, goods or services.
  4. Conflict Situations

    1. We have identified a number of situations which may give rise to a potential conflict of interest. These situations include, but are not limited to, the following:
      1. we receive gifts, entertainment or other monetary and non-monetary benefits from our service providers or business partners (for example, the fund managers of the Funds we make available to clients through Plum), which could give rise to a conflict with respect to the duties that we owe to our clients;
      2. Plum Personnel who have outside commitments (e.g. directorships or other outside business interests) may be influenced to act in a manner that conflicts with the interests of Plum or its clients; and
      3. where Plum Personnel invest for their own account in certain investments which are retained as investments for client accounts.
  5. Conflict Management

    1. We have developed protocols to manage conflicts of interest set out in this document to enable us to act without bias or damage to your interests. Our employees are provided with training about the protocols and the standards of conduct to which they must adhere. Our management is responsible for ensuring the protocols are adhered to and to deal with any conflict that may arise.
    2. We maintain a log of conflicts that arise, and we note on it each conflict was monitored and any solution which was developed and applied to resolve the problem and to prevent the customer's interests from being disadvantaged. The effectiveness of our protocols is assessed by internal audit staff members who execute their duties in a wholly independent capacity.
      1. We have in place procedures to prevent unauthorised access to information and to prevent the dissemination of information.
      2. We ensure that all Plum Personnel are subject to appropriate restrictions and monetary limits for any gifts or entertainment received.
      3. We ensure that all Plum Personnel pre-clear and report any personal trading activity which may conflict with the interests of our clients.
      4. We ensure that our personnel’s external commitments do not conflict with the interests of Plum or its clients;
      5. Where our functions could create an internal conflict, we separate the duties appropriately. The operations functions are maintained and conducted separately from the front office functions and an appropriate level of qualification, expertise and supervision is applied.
      6. Staff remuneration is by means of a basic salary which is not linked to the underlying performance of your Account or any underlying investment. A remuneration committee agrees and monitors awards, including for example, any performance related pay, to achieve consistency and equitability and to ensure they do not lead to conditions which may foster conflict.
  6. Conflicts Disclosure

    1. If we are not reasonably confident that we are able to manage a particular conflict to adequately protect the interest of a client, the general nature and/or source of conflicts of interest will be clearly disclosed before we undertake any business.
    2. We wish to disclose that we may aggregate anonymised data with that of other clients and license or sell it to third parties.
  7. Conflicts Disclosure

    1. A summary of Plum’s Conflicts of Interest Policy can be found here.


Section 4 - Order Handling and Best Interest Policy


  1. Plum’s commitment

    1. We are committed to treating you fairly when we manage your Investment Account. As part of this commitment, we have prepared this Order Handling and Best Interest ("Policy") to provide you with information on how we will receive and transmit your Orders to the Execution Broker.
    2. Under the FCA’s Rules, when transmitting Orders to other entities for execution, we are required to act in your best interests and to take all reasonable steps to obtain the best possible result (the "Best Interest Obligation"). This Policy therefore sets out the most important aspects of the arrangements that we have put in place to comply with our Best Interest Obligation.
    3. Unless otherwise defined in this Policy, defined terms shall have the same meaning as in the Investment Terms.
  2. Your consent

    1. By opening a Plum Investment Account, you agree to this Policy. You understand that we must keep this Policy under review. We therefore review it at least once a year. If we update this Policy, we will let you know by sending you a message.
  3. Order Execution Methods

    1. We do not execute your Orders. Instead, we receive your Orders through WithPlum and transmit these to an appropriate broker for execution.
    2. In selecting an appropriate broker for execution we have taken into account our Best Interest Obligation. We have reviewed the Execution Broker’s dealing arrangements and are satisfied that it considers all the Execution Factors (and places relative importance on these Execution Factors) in a manner that corresponds with our own Policy.
    3. The Execution Broker is authorised and regulated by the FCA, and therefore owes a duty of best execution in respect of Orders received for execution. Under the FCA Rules, the Execution Broker is obliged to have in place a written order execution policy that it will follow when carrying out Orders. Details of the Execution Broker’s and custodian’s best execution policy are available here.
  4. Execution Factors

    1. The factors (the "Execution Factors"that we have to take into account when placing Orders on your behalf will include:
      1. the price of the investment;
      2. the costs associated with the transaction;
      3. the likely speed of getting the transaction done;
      4. the likelihood of execution and settlement;
      5. the size and nature of the order; and
      6. While price and costs will generally be the key factors in any decision to deal, the overall benefit to you of a particular transaction may be affected by the other Execution Factors.

        This means that our obligation to try to obtain the best possible result when carrying-out our Orders may not necessarily always equate to the best headline price in every case.

    2. When determining the relative importance of each of the Execution Factors, we will take into account the following criteria:
      1. the fact that we have classified you as a “Retail Client”;
      2. the characteristics of the particular order, and the characteristics of the investment that is subject to that Order; and
      3. the characteristics of the execution venues on or with which the Order can be placed.
  5. Transmitting orders to the usand choice of venue

    1. We receive Orders from you through WithPlum and relay these to the Execution Broker for execution. When we receive an Order from you we will promptly transmit this Order for execution.
    2. Orders for Funds can only be executed through the operator of the Fund and, therefore, there is only one venue on which we are able to execute your order.
  6. Order Aggregation

    1. We may aggregate (combine) Orders placed via WithPlum with Orders of other clients for execution. However, the effect of order aggregation may, on some occasions, work to a particular client’s disadvantage.
  7. Specific instructions from you

    1. If you wish to withdraw funds from your Plum Investment Account or close it, we may have to liquidate investments to meet your instruction. If you have given us specific instructions (for example, if you have asked us to satisfy the withdrawal request by a specific deadline), this may limit the extent to which we are able to abide by this Policy.
    2. We will not advise you on the purchase or disposal of your investments.
  8. The Best Execution Policy

    1. By agreeing to these Terms, you will be giving your consent to our best execution arrangements. Details of the custodian’s best execution policy is available here.


Section 5 - Customer investments and risks


This is not intended to be 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. We have set out the main risks to which investors will be exposed, as we understand them, but warn that investing is always exposed to new risks and that some risks once thought to be very low can rapidly develop into high and serious risks.

  1. Key Risks

    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
    4. You may make a loss
    5. You may lose your entire investment
    6. The price or value of investments may fluctuate significantly
    7. Any income distributions may also fluctuate significantly
  2. Risks relating to Funds

    1. The investments held for the benefit of your Plum Investment Account will be made in Funds.
    2. The performance of a Fund is dependent on its investment policy and strategy, the skills and expertise of those responsible for managing its investments, and the market(s) in which it invests.
    3. A Fund may be subject to suspensions in valuation, during which time dealing in a Fund will not be possible. Such suspensions generally occur in exceptional conditions, for instance where the investments of the Fund cannot be accurately valued or during periods of significant market turmoil.
    4. The value of the Fund is dependent upon the underlying investments held by them and the prices of those investments may vary according to the markets on which they are listed or traded.
    5. A Fund may close, and the liquidated value of the underlying investments may result in a loss.
    6. If there is little liquidity in the market for a Fund, there may be substantial differences between the buying price and the selling price.
    7. Funds exposed to overseas markets may involve different risks from UK focussed Funds.
    8. Investments in overseas Funds depend not only on the performance of the Fund but also upon foreign exchange rates which may change adversely affecting the value of the Fund.
    9. This is not intended to be 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. We have set out the main risks to which investors will be exposed, as we understand them, but warn that investing is always exposed to new risks and that some risks once thought to be very low can rapidly develop into high and serious risks.


    Section 6 - Glossary


    Available Cash

    Cleared monies held for your Platform Product adjusted for any unsettled buy and sell Orders or cash allocated for pending buy Orders.

    Available Investment

    Any investment shown as being currently held in your Platform Product adjusted for any unsettled transactions as confirmed by the GIA/ISA Product Provider.

    Business Day(s)

    Any day(s) except for Saturdays, Sundays and public holidays in the UK; where the London Stock Exchange or the major clearing banks in the City of London are open for business.Any day(s) except for Saturdays, Sundays and public holidays in the UK; where the London Stock Exchange or the major clearing banks in the City of London are open for business.

    Client Money

    Money a firm receives or holds on behalf of a client which it must treat in accordance with FCA rules on client money.

    Client Money Bank Account

    A client bank account which is used to hold Client Money in accordance with the FCA Rules.

    Client Money Rules

    The FCA’s Rules on Client Money.

    Contribution

    Payments made to your GIA/ISA Platform Product.

    Corporate Actions

    Any event initiated by a fund (or its manager), company or corporation which impacts shareholders (e.g. changes to investment objectives/strategies, mergers, takeovers, rights issues, open offers and consolidations).

    Current Tax Year

    The current period between 6th April and 5th April of the following year.

    Dealing Day

    Any day unless it is not a Business Day, in which case it shall mean the next available Business Day.

    Delegate

    A person or entity to whom we may delegate to in order that they perform the provision of certain services to you instead of us.

    Event Beyond Our Control

    Shall have the meaning in paragraph 12.1.

    Execution Broker

    Winterflood Business Services (WBS)

    FCA Rules

    The rules contained in the FCA’s handbook of rules and guidance (as may be amended and updated from time to time).

    Financial Ombudsman Service or "FOS"

    TThe office to whom you may refer a complaint you have about the services provided to you if we cannot resolve or settle your complaint (to your satisfaction) within 8 weeks of the date you first make the complaint.

    Financial Services Compensation Scheme or "FSCS"

    AA statutory compensation fund from which you may be able to make a claim in the event that a regulated firm is unable (or is likely to be unable) to pay a claim against it.

    Funds

    The investment funds that are made available to you from time to time for investment via the Service as described in paragraph 10.1 of Section 1.

    GIA/ISA Platform Products

    General Investment Account (or “GIA”) and the “Individual Savings Account” (or “ISA”) that are made available to you through WithPlum.

    GIA

    General Investment Account, which is an account which allows you to hold investments outside of tax wrappers, such as ISAs or pensions.

    HMRC

    His Majesty’s Revenue & Customs.

    Investment Services

    The services that WithPlum will provide to you as further defined in paragraph 3 of Section 1.

    ISA

    Individual Savings Account, which is a tax-exempt savings scheme for individuals established under the ISA Regulations.

    ISA Regulations

    The Individual Savings Account Regulation 1998 (as amended from time to time) which governs the establishment and operation of an ISA.

    ISA Terms

    The additional terms contained at Section 2, Part B of these Terms which will apply to you should you choose to hold your investments through an ISA.

    Key Features Document

    One or more of the GIA key features andthe ISA key features documents. These documents are designed to provide you with key information about the product and how it works to help you decide whether the product is right for you.

    Key Investor Information Document or KIID

    A short document which a fund manager of a fund categorised as a “UCITS” is required to produce and make available to you in accordance with applicable laws prior to you making a decision to invest and which contains key investor information about the relevant fund and which you should read carefully.

    Order

    An instruction received by the GIA/ISA Product Provider from WithPlum to buy or sell investments within your GIA/ISA Platform Product.

    Order Transmission Policy

    The policy set out in Section 4 which Plum has adopted to ensure that when it receives instructions from you to undertake an investment (through WithPlum) and transmits those instructions to the Execution Broker to execute, it does so with a view to achieving the best possible result for you in accordance with the FCA Rules.

    Outstanding Fees

    Fees and charges that are payable by you to us, but which are outstanding from time to time.

    Permitted Withdrawal

    A withdrawal of the cash and/or investments held through your WithPlum Account if permitted by the ISA Regulations and the terms of the particular Platform Product.

    Plum Terms / Terms

    Refers to the Plum General Terms and Conditions, the Investment Terms and the GIA/ISA Product Provider Terms.

    Previous Tax Year

    Any previous period between 6 April and the following 5th April.

    Previous Tax Year

    Any previous period between 6 April and the following 5th April.

    Transfer In

    A transfer in of cash or investments from another ISA as applicable.

    Transfer Out

    In relation to your SIPP, a transfer of cash or investments to another pension.

    UCITS

    In relation to your ISA, a transfer of Platform Product ISA together with cash and/or investments to another ISA.

    In relation to your GIA, a transfer of your Platform Product GIA together with cash and/or investments to another dealing account.

    UCITS

    An Undertaking for Collective Investment in Transferable Securities (UCITS) is an investment fund that invests in liquid assets and can be distributed publicly to retail investors across the EU.

    UK

    Includes England, Scotland, Wales and Northern Ireland.

    U.S. Person

    Any United States citizen or other person who is defined as such by the United States Internal Revenue Services the detail of which is accessible via irs.gov

    Withdrawal

    Your instruction to transfer cash and/or investments from your GIA/ISA Platform Product through your Plum Account and “Withdrawn”, “Withdraw” shall be interpreted accordingly.

    WithPlum

    Means the interface we provide to access the Investment Services and any other product or service offered by us from time to time.


Plum SIPP: Investment Terms and Conditions

users opening a Plum Investment Account for SIPP

Contents

Section 1 – General Terms of the Plum Investment Account

Section 2 – SIPP Product Provider Terms

Section 3 – Plum’s Conflicts Management Policy

Section 4 - Order Transmission Policy

Section 5 - Customer investments and risks

Section 6 - Glossary

Appendix 1. SIPP Product Provider Privacy Statement

Section 1 - General Terms of the Plum Investment Account

This page tells you about the legal terms and conditions ("Investment Terms") on which we provide Plum users with access to a Plum Investment Account.

These Investment Terms, together with the Plum General Terms and Conditions aand any terms to which these documents refer, will apply to any contract between us relating to our Investment Services ("Investment Contract"). Please read these Investment Terms carefully and make sure that you understand them, before applying for a Plum Investment Account. Please note that before you can open a Plum Investment Account you will be asked to agree to these Investment Terms. If you refuse to accept these Investment Terms, you will not be able to open a Plum Investment Account.

If there is anything contained in these Investment Terms that you do not understand, please do not hesitate to get in touch with us. You can email us at help@withplum.com.

We may amend these Investment Terms from time to time as set out in clause 13.7 of the Plum General Terms and Conditions.

These Investment Terms, and any Investment Contract between us, are only in the English language.

  1. General

    1. In these Investment Terms, references to "Plum", "us", "our", and/or "we" means Saveable Limited.
    2. In these Investment Terms, where the context requires, references to SIPP Product Provider means Quai Investment Services Limited (QISL).
    3. References to "client", "you" and/or "your" mean any person who opens a Plum Investment Account with us.
    4. In these Investment Terms "WithPlum" means the interface we provide to access the Investment Services and any other product or service offered by us from time to time.
    5. In these Terms, capitalised terms and expressions shall have the meanings given to them in the Glossary below or the Plum General Terms and Conditions, unless the context requires otherwise.
  2. Our regulated status

    1. In respect of our Investment Services, these are provided by Quai Investment Services Limited.
  3. Our Investment Services

    1. We will provide services (the "Investment Services") that integrate with your Plum Account including the following:
      1. opening SIPP Platform Products and making available to you the tools to manage your SIPP Platform Products;
      2. relaying your instructions you have made through WithPlum to transact in investments to the SIPP Product Provider for it to execute in accordance with the investment selections;
      3. providing information (including the value of your portfolio) about your Platform Product(s) and investments held by the SIPP Product Provider (including the value of your portfolio) based on information provided to us by the SIPP Product Provider;
      4. the provision of the features and services that help you to make decisions and place instructions with or through WithPlum in relation to your Plum Account and your Investment Account; and
      5. making arrangements for you to be provided with dealing, safe-custody, settlement and post-execution transaction services by us and from the SIPP Product Provider.
  4. Complaints

    1. Should you have any complaint(s) in relation to the Products and Services, please notify us in accordance with this clause. Your complaint will be acknowledged within one (1) Business Day after receipt and arrange for the matter to be investigated in accordance with the applicable laws and rules of the FCA.
    2. In the first instance please contact Plum at help@withplum.com. If your complaint relates to a service provided by Plum and not by a Third Party Provider of Plum, we will immediately carry out an investigation of your complaint in line with our complaints policy and will provide a written response, communicating the outcome of the investigation with you.
    3. If your complaint relates to a service provided by any of our Third Party Providers, we will notify them of your complaint, they will investigate the complaint and we will then respond to you with a final response no later than by the end of eight weeks after receipt of the complaint.
    4. Complaints must be submitted to us either via email or via our help widget in our in-app.
    5. If your complaint is unresolved or not settled to your satisfaction within the applicable timeframe, you may refer it directly to the Pensions Ombudsman Service (POS) within six months of the date of the sent (or should have been sent) final response to you. Details POS are as follows:


      Pensions Ombudsman Service

      10 South Colonnade, Canary Wharf, E14 4PU

      Email: enquiries@pensions-ombudsman.org.uk

      Telephone Numbers: Local:  0800 917 4487  Overseas:  +44 (0) 207 630 2200 

      Website: www.pensions-ombudsman.org.uk

  5. Compensation

    1. You may be entitled to compensation from the Financial Services Compensation Scheme ("FSCS") in respect of certain Investment Services ch The FSCS pays compensation for financial loss only to eligible claimants when an authorised firm is in default and will carry out an investigation to establish whether or not this is the case. The scheme provides protection if an authorised investment firm is unable to pay claims against it. The amount of compensation depends on the basis of your claim. The current maximum levels of compensation for investments are £85,000 per person per firm. Compensation levels are subject to change and for up to date details please refer to www.fscs.org.uk.
    2. If your investment underperforms or loses value because of market movements, this is not covered by the FSCS. Your capital is at risk when investing in a Fund through Plum Money.
    3. The FSCS will only be relevant to ‘protected claims’ which may arise from our Investment Services.
    4. Further information about compensation arrangements is available here and from the Financial Services Compensation Scheme website (www.fscs.org.uk).
  6. The SIPP Product Provider and the SIPP Product Provider Agreement

    1. References to “SIPP Product Provider” means Quai Investment Services Limited, a company incorporated in England and Wales under company number 9919243 and having its registered office at 16 Tesla Court, Innovation Way, Peterborough, PE26FL. Quai Investment Services Limited is authorised and regulated by the FCA (registration number 992590).
    2. We have selected the SIPP Product Provider to provide the "SIPP Platform Products", being the Self Invested Personal Pension (or "SIPP") that are made available to our users through WithPlum.
    3. This Investment Contract (as it applies to the SIPP Product Provider) and in particular Section 2, Part B – SIPP Product Provider Terms, together with
      1. the information we have provided to you via Plum about the SIPP Product Provider’s services and costs and charges; and
      2. the information you have provided to us via Plum and/or any other permitted means under these Plum Investment Terms in respect of the SIPP Platform Products (including declarations given by you which we transmit to the SIPP Product Provider); and
      3. any applicable Key Features Document constitute the agreement (the "SIPP Product Provider Agreement") between you and the SIPP Product Provider.
  7. Commencement and status of the SIPP Product Provider Agreement

    1. The SIPP Product Provider Agreement will be legally binding when you accept these Investment Terms. However, the SIPP Product Provider will only start to provide the Platform Services to you if, and when, you open a Platform Product and, accordingly, those terms relating to the Platform Product will only be applicable after that time. The SIPP Product Provider Agreement has no minimum duration period.
    2. The SIPP Product Provider Agreement is governed by the laws of England and Wales. If any provision of the SIPP Product Provider Agreement is or becomes invalid or unenforceable, the relevant provision will be treated as if it were not in the SIPP Product Provider Agreement, and the remaining provisions will still be valid and enforceable.
  8. Selecting and appointing the SIPP Product Provider on your behalf

    1. We have entered into an agreement with the SIPP Product Provider for each of our clients (including you) for the provision of the SIPP Platform Products and dealing, safe custody, settlement and post-execution services. The additional terms that apply to the services provided to you by the SIPP Product Provider and the SIPP Platform Products are set out in Section 2, Part B (the "SIPP Terms").
      1. we are authorised to appoint the SIPP Product Provider and to agree and enter into the SIPP Product Provider Agreement on your behalf as your agent (in accordance with your instructions);
      2. the SIPP Product Provider Agreement forms a legally binding agreement between you and the SIPP Product Provider. Accordingly, the SIPP Product Provider (and not WithPlum) will be responsible for providing you the SIPP Platform Products and with safe custody, settlement and post-execution services;
      3. we are authorised to give instructions to the SIPP Product Provider (as provided in these Plum Investment Terms) and provide information concerning you to the SIPP Product Provider, and the SIPP Product Provider is entitled to rely on such instructions and information without contacting you directly;
      4. the SIPP Product Provider is authorised to hold cash and investments on your behalf and is authorised to transfer cash and/or investments from your SIPP Platform Products to meet your settlement and other obligations under these Terms; and
      5. we are authorised as your agent to terminate the appointment of the SIPP Product Provider and to instruct the SIPP Product Provider to transfer the SIPP Platform Products and the assets and cash in relation to your SIPP Platform Products to an alternative provider selected and appointed by us, provided in doing so we act in your best interests and in accordance with the FCA Rules and all applicable laws.
    2. This arrangement with the SIPP Product Provider means that you will remain a client of ours, and we will continue to be responsible to you for the Investment Services. However, you will also be a client of the SIPP Product Provider, and it will be directly responsible to you for the provision of the SIPP Platform Products and the related dealing, safe-custody, settlement and post-execution services. We shall not be responsible to you for the actions or failures of the SIPP Product Provider and the SIPP Product Provider shall not be responsible to you for our actions or failures.
    3. We will notify you of the identity and terms of any replacement SIPP Product Provider in good time before any changes are made.
  9. What being a ‘retail client’ means

    1. Both we and the SIPP Product Provider will provide our Investment Services on the basis that you are a Retail Client as defined in the FCA Rules. This means that you are entitled to the protections provided for Retail Clients under the FCA Rules and relevant legislation. If you would like further information on the nature of these protections, please ask us by email.
  10. Selecting investments

    1. Through Plum, you are able to select and invest in a selection of investment funds (the "Funds") that we have arranged for the SIPP Product Provider to make available to Plum users. For more information about the Funds please see our FAQ.
    2. We or the SIPP Product Provider do not provide financial advice to our clients and we or the SIPP Product Provider will never make recommendations based on your personal circumstances. If you are not sure whether our Investment Services, the SIPP Platform Products, or the Funds are suitable for you then we recommend that you seek advice from a qualified financial adviser.
    3. Prior to making any decision to invest, you must read the "Key Investor Information Document" or "KIID" relating to the relevant Fund. The KIIDs contain important information of which you should be aware. You can access the KIIDs via Plum.
    4. Neither we nor the SIPP Product Provider will provide you, or be responsible for providing you, with any financial, legal or tax advice. Please note that certain provisions contained in the Terms, the SIPP Product Provider Agreement, and within the Plum product(s) set out information relating to tax treatment. You should note that tax treatment depends on individual circumstances and our current understanding of law and HMRC practice, which may be subject to change in the future.
  11. Fees for the Plum Investment Services

    1. We reserve a right to charge a fee for the Products and Services we provide to you. All fees you may have to pay to us are listed on the Plum Website.
    2. The SIPP Product Provider shall facilitate the payment to us of the fees (plus VAT, if any) payable by you. If the available funds are insufficient, the SIPP Product Provider may sell assets held as part of your Investment Account to cover such charges.
    3. For full details on fees, please see Plum’s website, Plum Pension and the related section of the FAQ.
  12. Opening your Plum Investment Account and making Contributions

    1. Before we can open your Plum Investment Account and provide the Investment Services to you, we are required to verify your identity in accordance with UK anti-money laundering legislation. We will use various third-party services to do this and you acknowledge that this will involve us transmitting your personal information to such third parties as set out in our Privacy Notice.
    2. You warrant and represent to us and to the SIPP Product Provider on an ongoing basis that:
      1. You are aged 18 or over;
      2. You are UK resident for tax purposes; and
      3. You are not a US Person for the purposes of residency, citizenship or tax.
    3. You agree to notify us immediately if any of the above warranties cease to be correct.
    4. Contributions to your SIPP Platform Product may be single or regular and can only be paid from your Plum Account, or such other methods as we may otherwise specify. Contributions may be subject to certain minimums and maximums. We may change the minimum or maximum contributions from time to time and will notify you.
    5. Contributions will be debited from your Plum Account and transferred to the SIPP Product Provider’s Client Money Bank Account and held in accordance with Section 2, Part A (SIPP Product Provider Terms), paragraph 4 (Cash and Investments) below.
  13. Communications

    1. You can give us instructions electronically through WithPlum. Where we do act on your instructions we will do so promptly. We will not act on any instruction if it would be illegal or contrary to any rule or regulation for us to do so.
    2. We may communicate with you about your Investment Account at any time through the Plum App or, where appropriate SMS and email.
    3. We may act on any instruction which we reasonably believe to be from you. We will not be liable if we carry out an instruction which is not genuine or for not investigating any instruction we reasonably believe to 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, wilful default or fraud. We are not obliged to acknowledge receipt of your instructions.
    4. We will send all notices, information and other correspondence to you by email and/or at the email address you have provided for your Plum Account or such other email address as you may designate from time to time. In the event any notice, information or other correspondence is sent to you by letter, the letter will be sent to the current postal address you have recorded in your account and will be deemed to be delivered on the second Business Day after posting.
    5. We may record and monitor our communications with you. We will store relevant communications for at least the period required by law.
    6. We cannot guarantee that electronic communications between us will be successfully delivered. We will not be liable for any loss, damage, expense, harm or inconvenience caused as a result of an email being lost, not delivered, delayed, intercepted, corrupted or otherwise altered.
    7. All communications between us will be in the English language.
  14. Instructions given via WithPlum

    1. When you use and interact with Plum to select and/or make changes to your Plum Investment Account, the SIPP Platform Product(s), and/or indicate your intention to undertake an investment transaction, such use and interaction will constitute your instructions to us, which we will then transmit (as appropriate) to the SIPP Product Provider.
    2. Section 2 of these Terms sets out the SIPP Product Provider’s obligations and duties with respect to instructions that are sent to them from us in relation to your SIPP Platform Products. You acknowledge and agree that all instructions and authorisations given by you in relation to the SIPP Platform Products and the investments made in respect of your Plum Investment Account must be sent by you personally and by no other person.
    3. You acknowledge and agree that all instructions are effective when they are received by the SIPP Product Provider. When we receive an instruction from you we will use all reasonable endeavours to ensure that the instruction is transmitted to the SIPP Product Provider as accurately and as soon as possible.
    4. When relaying instructions from you to buy and/or sell your investments, we shall apply our Order Transmission Policy which is set out in Section 4 of these Terms. By entering into the Terms, you agree and consent to our Order Transmission Policy.
    5. Where a delay occurs in transmitting an instruction due to factors outside of our reasonable control (including, without limitation, where Plum is unavailable) we will ensure that your instruction is transmitted to the SIPP Product Provider as soon as reasonably possible. However, we will not otherwise be responsible for any delay. In such circumstances please contact help@withplum.com.
  15. Withdrawals of Investments

    1. If you wish to make a Permitted Withdrawal you must provide instructions, which we will pass on to the SIPP Product Provider. Subject to the terms of your SIPP Platform Product (if applicable), to meet withdrawal requests, the SIPP Product Provider will realise the investments to provide you with the cash sum required and will pay the net sale proceeds into your Plum Account. The SIPP Product Provider will credit your Plum Account with the withdrawal proceeds as soon as practicable, but you should note that the process of selling investments may take some time, depending on the settlement dates of those investments.
  16. Reports and Contract Notes

    1. The SIPP Product Provider is responsible for providing to you all contract notes in respect of all investment transactions carried out by you via the Plum Account and all reports that are required to be provided to you in accordance with the FCA Rules - including valuation reports ("Reports"). These Reports will include details of all transactions during the relevant period, details of the contents of your Plum Account, the current market value and the basis of valuation, income and fees charged. In accordance with the FCA Rules and applicable legislation, you will be provided with Reports quarterly.
    2. We will make daily valuations of your SIPP Platform Products available to you via Plum.
    3. You agree that the SIPP Product Provider shall provide the Reports to us, so that we may make these available to you via the Service. Whilst we shall be responsible for making available to you any Reports provided to us by the SIPP Product Provider, you acknowledge and agree that we shall not be responsible for any inaccuracies or omissions in the Reports we provide to you. For further information with respect to the responsibilities owed by the SIPP Product Provider to you in preparing the Reports and other information, please see Section 2 of these Terms.
    4. By entering into this Investment Terms and the SIPP Product Provider Agreement you agree and consent to the electronic delivery of contract notes and Reports and all other information required to be provided to you under those Agreements. We will send all such contract notes and Reports to the most recent email address you have provided to us.
  17. Conflicts of interest

    1. We or anyone connected with us, may carry out certain transactions for you where we 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 adequately manage a conflict.
    2. Our Conflicts of Interest Policy is set out in Section 3 which describes some of the actual or potential conflicts of interest which may arise and provides our policy about how these are managed. We will from time to time update our policy and you may obtain the latest policy from us at any time upon request.
  18. Liability

    1. Subject to the FCA Rules, we shall not be liable for any losses suffered by you unless such loss arises from our negligence, breach of the Terms, wilful default, fraud, or from our failure to comply with applicable laws or the FCA Rules.
    2. We will not be held liable for any loss incurred by you which arises, either wholly or in part, as a result of an event which is beyond our reasonable control to prevent and the effect of which is beyond our reasonable power to avoid in relation to your Plum Account and which may arise from delays or changes in market conditions, market fluctuation, currency fluctuation, computer failure, labour dispute, inability to communicate with you and/or the SIPP Product Provider, or for any other reason and whereby we are either unable to take or refrain from taking or shall not be obliged to take or refrain from taking any action as a consequence thereof.
    3. We will take reasonable care and exercise reasonable due skill, care and diligence in the assessment, selection and appointment of the SIPP Product Provider(s), custodians, bankers, counterparties, agents and other third parties. We accept responsibility for any losses, damages or costs suffered or incurred by you to the extent these are caused by our negligence, wilful default or fraud in the assessment, selection or appointment, and ongoing monitoring of such persons. We will not be responsible in any other circumstance for the acts or omissions of any such third parties.
    4. We do not accept responsibility for any loss, damages or costs you may incur as a result of:
      1. any cause beyond our reasonable control to prevent (as described in paragraph 18.2 above);
      2. the acts or omissions of the SIPP Product Provider; and/or
      3. our taking any action, or omitting to take any action, to the extent we are required to do so under applicable laws and regulations, the FCA Rules and/or at the direction of a competent regulator such as the FCA.
    5. No provision of the Plum Terms will restrict, qualify or exclude any duty owed to you under applicable laws relating to the provision of services or under the FCA Rules. For further information about your rights under these applicable laws contact your local Citizens’ Advice Bureau.
  19. Delegation

    1. We may appoint another person or entity ("Delegate") to perform all or part of the Investment Services, provided that we take all reasonable steps to ensure that such Delegate is (and remains) suitably competent and qualified to do so. Where we appoint a Delegate:
      1. this will not affect our liability to you for the Investment Services we have delegated; and
      2. this will be undertaken in accordance with these Investment Terms and all applicable laws and the FCA’s Rules.
  20. Referrals

    1. Where appropriate, we may offer to refer you to third parties to provide certain additional services. We will not make any such referral without your agreement.
    2. We may pay (or receive from third parties), fees in relation to referrals of business. In making or receiving any such referral and making or receiving such payments, we will act in accordance with the FCA Rules and all applicable laws.
  21. Termination

    1. Without affecting your use of other services provided by affiliates of Saveable Limited you may terminate this Investment Contract at any time and for any reason by providing us with notice, subject to the settlement of all outstanding transactions. Transactions already in progress will be completed in the normal course of business. In order to be able to close your Investment Account, all investments will need to be transferred out. Once that is done, we will proceed to close your Investment Account as soon as practicable after receiving your notice to terminate the Investment Contract.
    2. If you decide to close your account with Plum, we will treat that as notice to terminate this Investment Contract, realise any assets and cash held in your SIPP Platform Products and close your Investment Account.
    3. Our fees shall continue to apply until the later of the date of the termination of the Investment Contract or the settlement of all outstanding transactions in respect of your Plum Investment Account.
    4. We may also terminate the Investment Contract immediately if:
      1. we reasonably believe that providing you with a service exposes us to action or censure from any law enforcement, government or regulatory body (including, without limitation, the FCA);
      2. either you or we the SIPP Product Provider closes your SIPP Platform Product(s).
    5. Where we terminate the Investment Contract immediately, we will inform you in writing immediately of our decision and our reasons for making that decision.
    6. On termination of the Plum Agreement, as may be applicable, your SIPP assets must be either transferred to another suitable pension arrangement or sold and paid out as permitted retirement benefits.
    7. Please also see the SIPP Terms set out in Section 2, Part B ("SIPP Terms") of this document for additional termination provisions with respect to your SIPP.


Section 2 – SIPP Product Provider Terms


Part B: SIPP Product Provider Terms

Please note that this is an important document that sets out how your Plum SIPP is operated. It sets out the terms and conditions for the Plum SIPP. It should be read as part of the overall Terms.

References in these terms to the "Pension Provider" refer to Quai Investment Services Limited.

  1. General

    1. In accordance with your instructions and your selections, the Pension Provider shall provide the Plum SIPP and shall provide dealing, safe custody, settlement and post-execution services in respect of your investments (together, the "Pension Services").
    2. The Pension Provider will at all times provide the Pension Services to you in accordance with the terms of the Pension Provider Agreement, all applicable laws and all applicable FCA Rules.
    3. If you materially breach these Terms then the Pension Provider reserves the right, without further notice, to close your Plum SIPP, withdraw access to the Pension Service, require you to transfer out your Plum SIPP to an alternate provider, or any combination of these.
    4. The Pension Provider does not provide advice about their products or allowable investments. The Plum SIPP is only available to investors on an execution only basis. If for any reason you are unsure about the suitability of the Plum SIPP for your financial circumstances you should seek financial advice from an FCA authorised and appropriately qualified financial adviser prior to investing in a Plum SIPP.
    5. The Pension Provider will act on all instructions transmitted to it from Plum on your behalf and the Pension Provider shall not be liable to you for any error that Plum may make in the detail or provision of such instructions.
    6. The value of your Plum SIPP must be maintained above the minimum value of £1. The Pension Provider may change the minimum value from time to time and will notify you of any such change. In the event that the value of your Plum SIPP remains below this value for more than a 12-month period, then the Pension Provider may require us to close your Plum SIPP by giving notice to you.
    7. The Plum SIPP is only available through the Plum App; accordingly, all reports and documentation will be provided to you for access via the Plum App. By applying for a Plum SIPP, you agree that you do not require the Pension Provider to provide reports, statements, contract notes or other documentation associated with your Plum SIPP other than in electronic form via these means. You must also keep contact details up to date so that we can notify you when any important documents are sent via the Plum App.
    8. You accept that where the Pension Provider is required to provide you with written notice then this will be given to you by means of electronic correspondence as set out above.
    9. There may be circumstances that require the Pension Provider to review these Terms and the charges being made. In this event, the Pension Provider will notify you advising you of any amendments to these Terms required by the Pension Provider at least 30 days prior to the change taking effect. However, the Pension Provider does reserve the right in extreme circumstances to vary these Terms with shorter notice e.g. a change to an existing, or implementation of a new regulatory requirement which the Pension Provider has to action immediately.
    10. Value Added Tax will be levied on all appropriate expenses and fees at the prevailing rate.
    11. You authorise the Pension Provider to provide HMRC, the FCA and any other relevant authority with all the relevant information about your Plum SIPP and its investments, as required to do so by them.
    12. The Pension Provider reserves the right to sell investments if there is insufficient cash to meet the amount of any ongoing costs or charges.
    13. The Pension Provider has categorised you as a Retail Customer for all purposes of the FCA Rules. As a Retail Customer you will benefit from the greatest level of protection available under the regulatory system.
  2. Opening a Plum SIPP

    1. Your Plum SIPP will be established when the Pension Provider receives all necessary information from you or when all of their requirements have been met if this is later. The Pension Provider reserves the right at their absolute discretion to refuse your application for a Plum SIPP without providing any reason for their decision.
    2. You may not open a Plum SIPP if you are a US Person (as defined by the US Internal Revenue Service). If at any point you become a US Person as so defined, then you must immediately inform the Pension Provider and they will require you to close your Product(s).
    3. You may only open a Plum SIPP if you are a UK resident over the age of 18, or you have prior agreement to transfer in an existing UK pension fund. If you cease to be a UK resident, then you must inform the Pension Provider immediately. (UK includes England, Scotland, Wales and Northern Ireland.
    4. You have the right to cancel your Plum SIPP. The right to cancel applies to the commencement of the pension plan, and on all transfers into the pension plan. You can find the Pension Providers cancellation notice in the Pension Providers Key Features Document, which will give you the right to cancel within the 30 day cancellation period. If you decide to cancel your pension plan, any contributions will be returned to you less any tax relief claimed on your behalf, which will be returned to HMRC. If you choose to cancel in relation to a Transfer any investments held in your Plum SIPP acquired by the transferred monies will be sold and the Pension Provider will return the subsequent cash to the original pension provider. Please note that it may not always be possible to return a Transfer In to the original pension Scheme if you cancel after the transfer has been received by us. In these circumstances you will need to arrange for another pension Scheme to accept the transfer and the Pension Provider will retain the funds until such a time as a replacement provider has been notified to us. The Pension Provider will follow any investment instructions that you have given to us during this cancellation period. In the event of cancellation, the net realisable value of any assets purchased and subsequently disinvested will form the basis of the amount returned. This means that having taken into account any fees or charges paid in relation to the investment and any price movements (particularly downwards), you may get back less than you originally invested.
  3. Contributions and "Transfers In" to your Plum SIPP

    1. Contributions to your Plum SIPP are made in accordance with Section 1 (General Terms), paragraph 12 (Opening your Plum Account and making Contributions).
    2. It is your responsibility to monitor your Plum SIPP contribution limits. You are not permitted to make contributions that will not be eligible for tax relief. If you become subject to a reduced Annual Allowance (known as the Money Purchase Annual Allowance Rules) as a result of flexibly accessing pension benefits after 6th April 2015, then you are obliged to inform us of this immediately and provide the date that this occurred.
    3. Contributions cannot be refunded other than;
      1. in accordance with your instruction to cancel your SIPP under paragraph 2.4 above, or;
      2. where conditions are met to allow a ‘Refund of Excess Contribution Lump Sum’ payment to be made i.e. where your contribution exceeds your earnings in a tax year, or
      3. where explicit instruction is received from HMRC or other relevant authorities.
    4. The Pension Provider may decline any Contribution or Transfer In entirely at their discretion.
    5. Under current law, your own personal contributions will normally be treated as being paid net of basic rate tax, which the Pension Provider will reclaim from HMRC to the extent you are entitled to tax relief on that contribution. You are responsible for informing us if you are subsequently no longer entitled to tax relief on the whole or part of a contribution. Any sum reclaimed will not be available for investment until it is received from HMRC which can take several months from the date of your contribution. You are responsible for claiming any higher rate tax relief to which you are entitled.
    6. For payments received by the Pension Provider in respect of "Transfers In" your monies will only be cleared for investment after the relevant banks have cleared the monies. This typically means that cheque payments will be available for investment no later than the end of the 7th Business Day starting on the day the Pension Provider receives your cheque or any supporting documentation (whichever is the later) and for electronic payments no later than the 5th Business Day. If a payment is not honoured, then the Pension Provider will adjust the cash balance in your Plum SIPP.
    7. All Contributions and Transfer In values the Pension Provider receives will be applied to your Plum SIPP.
    8. You may "Transfer In" cash to your Plum SIPP. Alternatively, if you are transferring a pension where investments are held via an investment platform service and the pension investments that are held are also available under the Plum SIPP, then you may request for those investments to be transferred in-specie. If those investments under the Plum SIPP are available with lower fund management fees you will have the option to convert to those investments.
  4. Cash and Investments

    1. All monies received by the Pension Provider in respect of your Plum SIPP will be held by the Pension Provider in an account designated as a trust and segregated from the Pension Provider’s own funds in accordance with the FCA rules. The trustee account is a pooled account;and in the event of a bank’s failure, your claim will be for a share of the cash held in all pooled accounts at the bank. The banks used by the Pension Provider are entirely independent of them and they do not accept any liability for any default or delay in the distribution of funds in the event of the banks failure.
    2. Interest may be payable on your Plum SIPP. Any interest earned will be retained by the Pension Provider.
    3. Dividends or other income received will be credited to your Plum SIPP on the day of receipt wherever practicable but no later than 10 Business Days after receipt. Any income received in the form of cash will be credited to your Plum SIPP.
    4. All investments other than cash are held by the Pension Provider in a pooled investment (omnibus) account in the name of the nominee of an approved third-party custodian. This means that individual customer entitlements may not be identified by individual entries in the records of the nominee. If there is a shortfall following default by the nominee all customer accounts will share proportionally in that shortfall. The Pension Provider accepts no responsibility for the default or failure of a custodian or nominee. However, this does not limit the Pension Provider’s liability to you for its own respective fraud, wilful default or negligence.
    5. Investments held within your Plum SIPP must not be used as a security for a loan.
    6. The Pension Provider will not be responsible for any loss (including loss of profit) in relation to, or diminution in value of, any investment:
      1. acquired by the Pension Provider at your request; or
      2. not acquired by the Pension Provider or not disposed of by the Pension Provider in accordance with their rights under these Terms; or
      3. disposed of by the Pension Provider in accordance with these Terms unless such loss or diminution in value results from the Pension Provider’s fraud, wilful misconduct, negligence or breach of regulatory duty or the fraud, wilful misconduct, negligence or breach of regulatory duty of any of their employees or agents.
    7. The Pension Provider will be entitled to dispose of any investment if in their reasonable opinion continued retention of such investment would be unlawful, contrary to the Pension Regulations or would impose tax or other costs on the Pension Provider or expose them to liabilities which in each case they may not be able to meet from your Plum SIPP.
    8. The Pension Provider will be entitled to dispose of any investment if required to do so by the terms of any agreement to which it is a party. The Pension Provider will make all reasonable endeavours to inform you of such an event in advance, where feasible.
    9. Where investment income is received net into your Plum SIPP the Pension Provider will reclaim tax where permitted by, and in accordance with, current HMRC regulations. Such tax reclaims will be submitted to HMRC by the 31st January following the tax year in which the deduction was made. Any tax reclaim received will promptly be credited to your Plum SIPP.
    10. The Pension Provider will use reasonable endeavours to promptly notify you of a Corporate Action notified to it by a company or third-party custodian where relevant. There may be instances when the Pension Provider is not notified of a Corporate Action (or is not provided with sufficient information in time by them) and as a result are unable to pass on the details to you. In such circumstances, the Pension Provider will not be liable to you for any loss suffered.
    11. When a mandatory Corporate Action is announced where no option is available to shareholders and no firm payment date is known in advance, the Pension Provider will notify you only after the new securities or cash have been received and credited to your Plum SIPP.
    12. The Pension Provider may, at its sole discretion, not make available to you all of the choices that are offered by the company relating to the Corporate Action.
    13. We at our discretion may notify you of a Corporate Action, but are not obliged to do so.
    14. If the Corporate Action entails the payment of cash from your Plum SIPP, e.g. a rights issue, it is your responsibility to ensure that there is sufficient Available Cash in your Plum SIPP to satisfy the payment when it falls due.
    15. The Pension Provider will not credit to you and it will be entitled to retain fractions of shares arising from Corporate Actions where it cannot reasonably allocate these to your Plum SIPP.
    16. The Pension Provider does not pass on shareholder perks and will not become involved in any shareholder interest groups.
    17. The Pension Provider will place an electronic copy of your statement detailing the investments and transactions on your Plum SIPP in the relevant area of the Plum App.
    18. You specifically agree that the SIPP Product Provider may transfer client money to another provider in connection with a transfer of part or all of its business. Any such client money transferred will be held by that third-party in accordance with the FCA Rules on Client Money, or if such monies will not be held in accordance with the FCA Rules on Client Money, the SIPP Product Provider will exercise all due skill, care and diligence in assessing whether adequate measures will be applied by the third party to protect such monies.
  5. Fees, Charges and Expenses

    1. The fees and charges payable to the Pension Provider and the timing of those fees in respect of your Plum SIPP are set out in Schedule 1 of the Plum SIPP Key Features Document and form part of these SIPP Terms.
    2. The Pension Provider will also be entitled to charge the following costs to your Plum SIPP: all taxes, duties or levies to which the Pension Provider becomes liable as a result of acquiring, holding or disposing of any investment or other asset allocated to your Plum SIPP and from making any payments from your Plum Sipp.
    3. Provided, in doing so the Pension Provider acts at all times in accordance with all applicable laws and the FCA Rules, the Pension Provider may reasonably reimburse themselves in respect of the liability, charges or costs by way of making a charge to your Plum SIPP as they may reasonably determine which they have incurred as a result of one of the following events occurring:
      1. they become liable to pay any levies in relation to the Financial Services Compensation Scheme; or
      2. they become liable to pay any tax or levies imposed on your Plum SIPP or on any contribution paid by you; or
      3. they become liable to make any other payment to the UK Government or any governmental agency or self-regulatory organisation of which they are (or become) a member, to the extent directly or indirectly attributable to your Plum SIPP.
    4. These paragraphs 5.2 and 5.3 will not apply to the extent that the relevant event is attributable, directly or indirectly, to any fraud, negligence, wilful default or regulatory breach on the part of the Pension Provider.
    5. If the Pension Provider omits to deduct all or part of any charges from your Plum SIPP on the due date, the Pension Provider shall not subsequently be prevented from deducting such amounts or exercising any available remedy as a result of that omission.
    6. The Pension Provider may also deduct cash from and/or sell any of the investments in your Plum SIPP to realise cash if your Plum SIPP has been credited in error.
    7. If the Pension Provider cannot settle any instruction or Order because you do not have enough Available Cash in your Plum SIPP then the Pension Provider may promptly sell any of your investments, at their complete discretion, to cover the relevant costs.
    8. Charges, costs and liabilities which the Pension Provider and/or we are entitled to charge you will be paid from your Plum SIPP. If at any time the Available Cash on your Plum SIPP is not enough to cover all such charges, costs and liabilities in full, the Pension Provider may:
      1. dispose of investments at its discretion and without liability in order to pay the amounts due; or
      2. require you to pay the amounts due.
    9. If the Pension Provider disposes of your investments in accordance with these Terms and Conditions then it will, ordinarily, sell your investments to meet the amount due in the following order:
      1. your Funds, starting with the largest holding by value; and then
      2. any other investment.
    10. The Pension Provider may sell slightly more of your investments than is needed due to:
      1. The fact that the Pension Provider cannot know the exact price at which the investments will be traded and any excess will be held as Available Cash; or
      2. The requirement to maintain a minimum holding value for each investment.
    11. If for any reason the value of your investments is insufficient to meet any such fees, charges, expenses or tax payable, you agree to pay Pension Provider on demand the amount of any such shortfall.
    12. The Pension Provider will continue to be entitled to its charges and to recover all costs and liabilities as referred to in the above terms until all the assets of your Plum SIPP have been Transferred Out of or fully Withdrawn from your Plum SIPP in accordance with these Terms.
  6. Dealing

    1. The Pension Provider is responsible for executing any Order it receives from you through WithPlum. You may only place Orders for Permitted Investments.
    2. You may only place Orders via the Plum App. If this is unavailable for any reason, please contact help@withplum.com.
    3. You are responsible for the accuracy of your Orders. You may not be able to cancel or change an Order after you have submitted it.
    4. You must have sufficient Available Cash or Available Investments to settle any Order that you place together with any related charges.
    5. The Pension Provider reserves the right for any reason to refuse to execute an Order but we will act reasonably in so doing. There may be circumstances, including (without limitation) suspension of dealing in extreme market conditions in which the Pension Provider may not be able to execute an Order. The Pension Provider will, if possible, notify you of the reason. Provided the Pension Provider has acted reasonably, then the Pension Provider will not be liable for any loss or profit forgone between the time an Order was received and when it was executed, if ever.
    6. The Pension Provider may combine your Order with other customers’ Orders if it reasonably believe that this will not be to your disadvantage. The Pension Provider may have to execute your Order in tranches and provide an average price per Order.
    7. If the Pension Provider receives an Order via WithPlum then:
      1. In the case of an Order to buy a Fund, arrange to pass that Order on the next Dealing Day to the relevant Fund Manager for execution;
      2. In the case of an Order to sell a Fund, arrange to pass that Order no later than the next Business Day to the relevant Fund Manager;
      3. In any other case, arrange to pass that Order to an appropriate broker to execute on the relevant exchange. If this Order cannot be completed before the exchange closes at the end of the first Business Day then it will be cancelled, unless you have instructed us to continue to try to execute it on the following Business Day.
    8. The Pension Provider’s record of the time of receipt and execution of an Order will be conclusive unless it is obvious that it is wrong.
    9. You must notify us if you receive confirmation of an Order which you did not place or which has not been completed in accordance with your instructions.
    10. The Pension Provider will send to you contract notes (via the Plum App) confirming the details of your transaction by the end of the Business Day on which the Pension Provider receives confirmation from the market of the terms under which your Order has been executed, or in relation to Funds, by the end of the Business Day after the Pension Provider received it from the relevant Fund Manager.
  7. Transfers Out and Withdrawals

    1. You can require us by written notice to Transfer Out your Plum SIPP to another provider at any time, subject to the applicable legislation and HMRC regulations. You may instruct us to Transfer Out in specie and/or as cash. This will be done as soon as reasonably practicable. A Transfer Out in specie will incur the prevailing Transfer Out charges set out in the relevant SIPP fees schedule.
    2. If you instruct the Pension Provider to Transfer Out all of the investments and cash from your Plum SIPP then the Pension Provider will continue to act upon other Orders that you provide to it (through WithPlum), including the collection of Direct Debits and dealing.
    3. If your Platform Product is closed for any reason other than a breach by you of these Terms then the Pension Provider will continue to provide us with information relating to your SIPP Platform Product for at least 18 months after the date upon which the Plum SIPP was closed so that you can obtain inspect and download all necessary information.
  8. Serious Ill Health and Options on Death

    1. Serious ill health is defined by HMRC as likely having less than a year to live. If you are suffering from serious ill health, you can take all your pension benefits as a single lump sum (known as ‘serious ill health lump sum’) at any age and can be paid subject to the following conditions:
      1. A registered medical practitioner must provide us with written evidence stating that your life expectancy is less than a year before the payment is made. The completed declaration will then need to be received and accepted by us before the serious ill health lump sum can be paid
      2. You must have some lifetime allowance available at the time of payment. The SIPP Product Provider can withhold a payment until they have received any evidence that we have requested. The SIPP Product Provider will make payment to you by bank transfer, to an account held in your name that has been verified by an authorised person. The SIPP Product Provider will not make payments to third parties unless instructed to by someone with a valid power of attorney.
    2. In the event of your death the SIPP Product Provider retain their absolute discretion to pay any individual or individuals in the proportions that they see fit following deduction of all fees, taxes and charges due at the time of payment. Any nomination made by you will be considered but is not binding and may not be followed.
    3. Upon your death benefits may be paid as a lump sum as defined in the Finance Act 2004.
  9. Personal Information

    1. The SIPP Product Provider may use your personal information, including your sensitive personal information, and store it on its systems and may otherwise process it for the administration of your Platform Product(s). They need to know your personal information in order to provide you with the services you have engaged them to provide and to ensure that your account is administered as efficiently as possible. This includes such information as is required to comply with all legal and regulatory requirements. You can find the full SIPP Product Provider Privacy Statement in Appendix 1.
    2. The SIPP Product Provider will not collect personal information from you that they do not need in order to provide the services we have agreed to provide to you.
    3. The SIPP Product Provider may pass personal information relating to you to its associates or the bank for administering your Platform Product and verifying your identity and by dealing with the SIPP Product Provider you confirm that you accept and consent to this. The SIPP Product Provider may also need to seek additional information from you to verify your identity, in which case the SIPP Product Provider may:
      1. delay your application; or
      2. return and cancel your application; or
      3. withhold from you the ability to trade or withdraw any Funds until the SIPP Product Provider has successfully verified your identity.
    4. The SIPP Product Provider may disclose personal information if it is required to do so by law or are requested to do so by HMRC, the FCA, or any other relevant authority with the powers to request such information.
    5. You can ask questions about how we have handled your personal information or raise a complaint about how we have handled your personal information, by emailing the Data Protection officer of the SIPP Product Provider’s Administrator (see Appendix 1 - SIPP Product Provider Privacy Statement). If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). For further information about the ICO and their complaints procedure visit https://ico.org.uk/concerns/.
  10. Availability of the Service

    1. The Pension Provider cannot guarantee that access to, or trading in, your Plum SIPP through WithPlum or the Plum App will be available at all times or without delay. You acknowledge that the service may be interrupted and the services available may be variable in certain circumstances.
    2. The Pension Provider may suspend the operation of its service where it considers it necessary, including (but not limited to) where they have to suspend operations for technical problems, emergencies, maintenance, regulatory reasons, where they decide it is sensible for their customer’s protection, in periods of exceptional trading activity or to ensure the continued availability of other services.
    3. The Pension Provider will not be liable to you if their systems or services are unavailable to you for trading or information purposes for whatever reason.
  11. Market Abuse

    1. By placing Orders to the Pension Provider, you agree that you will not take part in activity which may be considered market abuse. You agree that you will not in any way engage in market abuse or require or encourage others to do so. If you are uncertain as to whether your dealings or proposed dealings are lawful, you should take legal advice. If the Pension Provider has reason to suspect that your Plum SIPP is being used to engage in market abuse, the Pension Provider reserves the right to take any action deemed to be appropriate. This action will include but is not limited to, refusing to act on your instruction and in such circumstances the Pension Provider is obliged to provide you with reasons for its actions.
  12. Assignment and Delegation

    1. We may appoint any person (whether connected to the Pension Provider or not) to advise on or perform any of our functions or responsibilities under these Terms. This contract may be assigned in whole or in part, but only if this does not offer you a poorer service and if your rights are not prejudiced by the assignment. Any group company of the Pension Provider shall be entitled to enforce provisions of these Terms which shall apply to it as if it were a party to the contract.
  13. Events Beyond our Control

    1. An "Event Beyond Our Control" means any act or event beyond our reasonable control, including without limitation strikes, lock-outs or other industrial action by third parties, civil commotion, riot, invasion, terrorist attack or threat of terrorist attack, war (whether declared or not) or threat or preparation for war, fire, explosion, storm, flood, earthquake, subsidence, epidemic or other natural disaster, or failure of public or private telecommunications networks.
    2. The Pension Provider will not be liable or responsible for any failure to perform, or delay in performance of, any of their obligations under these Terms that is caused by an Event Beyond Our Control. If an Event Beyond Our Control takes place that affects the performance of the Pension Provider’s obligations under these Terms they will notify you as soon as reasonably practicable and their obligations under these Terms will be suspended and the time for performance of their obligations will be extended for the duration of the Event Beyond Our Control.
    3. You may terminate the contract if an Event Beyond Our Control takes place and you no longer wish the Pension Provider to provide the Plum SIPP.
  14. Termination

    1. These Terms, as amended, will continue to apply until the provision of your Plum SIPP is terminated. All charges or fees due up to the date of termination must be paid. Termination shall be without prejudice to the completion of transactions already initiated by, or with, the Pension Provider on your behalf.
    2. If the Pension Provider terminates or suspends the provision of your Plum SIPP then they reserve the right to encash all investments and hold the proceeds in cash pending receipt of instructions from you.


Section 3 – Plum’s Conflicts Management Policy


  1. Introduction

    1. We are committed to taking measures to recognise, supervise, examine and resolve conflicts of interest. We recognise that it is not possible to eliminate all sources of conflict of interest; however, treating our customers fairly and in accordance with FCA Rules and principles remains our primary objective. This policy encompasses the relationships with customers and third-party contacts.
  2. What is a conflict of interest?

    1. A conflict of interest is a situation in which Plum (or any of its personnel) finds itself in a position where its own interests conflict with the duties and obligations owed to its clients or, a situation in which Plum’s duty to one client conflicts with its duty to another.
  3. Identifying conflicts of interest

    1. For the purposes of identifying the types of conflict and potential conflicts that arise which may entail a material risk of damage to the interests of a client, we must consider whether Plum or its directors, employees, or contractors ("Plum Personnel") or any other person linked by control to Plum:
      1. is likely to make a financial gain, or avoid a financial loss, at the expense of a client;
      2. has an interest in the outcome of a service provided to a client or transaction carried out on behalf of a client, which is distinct from the client’s interest in that outcome;
      3. has an incentive to favour the interest of another client or group of clients over the interests of the client;
      4. carries on the same business as a client, or
      5. receives or will receive from a person other than a client an inducement in relation to a service provided to the client, in the form of remuneration, goods or services.
  4. Conflict Situations

    1. We have identified a number of situations which may give rise to a potential conflict of interest. These situations include, but are not limited to, the following:
      1. we receive gifts, entertainment or other monetary and non-monetary benefits from our service providers or business partners (for example, the fund managers of the Funds we make available to clients through Plum), which could give rise to a conflict with respect to the duties that we owe to our clients;
      2. Plum Personnel who have outside commitments (e.g. directorships or other outside business interests) may be influenced to act in a manner that conflicts with the interests of Plum or its clients; and
      3. where Plum Personnel invest for their own account in certain investments which are retained as investments for client accounts.
  5. Conflict Management

    1. We have developed protocols to manage conflicts of interest set out in this document to enable us to act without bias or damage to your interests. Our employees are provided with training about the protocols and the standards of conduct to which they must adhere. Our management is responsible for ensuring the protocols are adhered to and to deal with any conflict that may arise.
    2. We maintain a log of conflicts that arise, and we note on it each conflict was monitored and any solution which was developed and applied to resolve the problem and to prevent the customer's interests from being disadvantaged. The effectiveness of our protocols is assessed by internal audit staff members who execute their duties in a wholly independent capacity.
      1. We have in place procedures to prevent unauthorised access to information and to prevent the dissemination of information.
      2. We ensure that all Plum Personnel are subject to appropriate restrictions and monetary limits for any gifts or entertainment received.
      3. We ensure that all Plum Personnel pre-clear and report any personal trading activity which may conflict with the interests of our clients.
      4. We ensure that our personnel’s external commitments do not conflict with the interests of Plum or its clients;
      5. Where our functions could create an internal conflict, we separate the duties appropriately. The operations functions are maintained and conducted separately from the front office functions and an appropriate level of qualification, expertise and supervision is applied.
      6. Staff remuneration is by means of a basic salary which is not linked to the underlying performance of your Account or any underlying investment. A remuneration committee agrees and monitors awards, including for example, any performance related pay, to achieve consistency and equitability and to ensure they do not lead to conditions which may foster conflict.


Section 4 - Order Transmission Policy


INTRODUCTION

Quai are committed to treating you fairly when it manages your SIPP Platform Products.

When Quai are transmitting orders to other entities for execution, it is required, by the FCA, to act in your best interests, and to take all reasonable steps to obtain the best possible result. This policy sets out the arrangements that it has put in place to comply with its regulations.

You are classified as a “Retail Client”. This means that you benefit from the highest level of protection under the FCA rules.

YOU’RE CONSENT

By opening a SIPP Platform Products you agree to this policy. Quai will review the policy on an annual basis and if it makes any changes, it will let you know.

ORDER EXECUTION

Quai will buy and sell investments on your behalf on an execution only basis. Quai will not give you any advice on the suitability of any investment or any order you give it.

Quai has selected Platform Securities to execute the orders you give us. Their details are as follows:

Platform Securities LLP (FCA Number 214206)
Tricorn House
51-53 Hagley Road
Edgbaston
Birmingham
West Midlands
B16 8TP

Quai have selected Platform Securities taking into account its obligations to you. Quai have reviewed Platform Securities and their dealing arrangements and are satisfied that they consider all of the execution factors in a manner that matches with its own policy.

ORDER EXECUTION

The execution factors Quai take into account are:

When determining the relative importance of each of the execution factors Quai will take into account the following criteria:

TRANSMITTING ORDERS

Quai will receive orders from you via WithPlum and transmit these to Platform Securities for execution.

Quai shall satisfy the following conditions when carrying out your order:

SPECIFIC INSTRUCTIONS FROM YOU

If you wish to withdraw funds from SIPP Platform Products or close it, Quai may have to liquidate investments in order to meet your instruction. If you have asked Quai to satisfy the withdrawal request by a specific deadline, this may limit the extent to which it is able to apply this policy.

ORDER AGGREGATION

Quai may aggregate orders placed in respect of your SIPP Platform Products with orders of other customers for execution, which will be executed in line with our order allocation policy. The effect of order aggregation may, on some occasions, work to a particular customers disadvantage.

EXECUTION VENUES

The execution venue will be dependent on the investment and will be determined by Platform Securities at the time of execution.

Platform Securities maintains their own order execution policy.

BEST EXECUTION POLICY

By agreeing to these terms you will be giving your consent to Platform Securities order execution arrangements. Details of Platform Securities best execution arrangements are available upon request.


Section 5 - Customer investments and risks


This is not intended to be 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. We have set out the main risks to which investors will be exposed, as we understand them, but warn that investing is always exposed to new risks and that some risks once thought to be very low can rapidly develop into high and serious risks.

  1. Key Risks

    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
    4. You may make a loss
    5. You may lose your entire investment
    6. The price or value of investments may fluctuate significantly
    7. Any income distributions may also fluctuate significantly
  2. Risks relating to Funds

    1. The investments held for the benefit of your Plum Investment Account will be made solely in Funds.
    2. The performance of a Fund is dependent on its investment policy and strategy, the skills and expertise of those responsible for managing its investments, and the market(s) in which it invests.
    3. A Fund may be subject to suspensions in valuation, during which time dealing in a Fund will not be possible. Such suspensions generally occur in exceptional conditions, for instance where the investments of the Fund cannot be accurately valued or during periods of significant market turmoil.
    4. The value of the Fund is dependent upon the underlying investments held by them and the prices of those investments may vary according to the markets on which they are listed or traded.
    5. A Fund may close, and the liquidated value of the underlying investments may result in a loss.
    6. If there is little liquidity in the market for a Fund, there may be substantial differences between the buying price and the selling price.
    7. Funds exposed to overseas markets may involve different risks from UK focussed Funds.
    8. Investments in overseas Funds depend not only on the performance of the Fund but also upon foreign exchange rates which may change adversely affecting the value of the Fund.


    Section 6 - Glossary


    Annual Allowance

    The cap on the total amount of tax relievable contributions and benefit accruals that can be built up in an individual’s pension Schemes over an input year, as described in the Finance Act 2004.

    Available Cash

    Cleared monies held for your Platform Product adjusted for any unsettled buy and sell Orders or cash allocated for pending buy Orders.

    Available Investment

    Any investment shown as being currently held in your Platform Product adjusted for any unsettled transactions as confirmed by the SIPP Product Provider.

    Business Day(s)

    Any day(s) except for Saturdays, Sundays and public holidays in the UK; where the London Stock Exchange or the major clearing banks in the City of London are open for business.Any day(s) except for Saturdays, Sundays and public holidays in the UK; where the London Stock Exchange or the major clearing banks in the City of London are open for business.

    Client Money

    Money a firm receives or holds on behalf of a client which it must treat in accordance with FCA rules on client money.

    Client Money Bank Account

    A client bank account which is used to hold Client Money in accordance with the FCA Rules.

    Client Money Rules

    The FCA’s Rules on Client Money.

    Contribution

    Payments made to your SIPP Platform Product.

    Corporate Actions

    Any event initiated by a fund (or its manager), company or corporation which impacts shareholders (e.g. changes to investment objectives/strategies, mergers, takeovers, rights issues, open offers and consolidations).

    Data Protection Officer of the SIPP Product Provider’s Administrator

    The contact point for any questions with respect to privacy on the side of the SIPP Product Provider, reachable at dataenquiries@quaifmc.com

    Dealing Day

    Any day unless it is not a Business Day, in which case it shall mean the next available Business Day.

    Delegate

    A person or entity to whom we may delegate to in order that they perform the provision of certain services to you instead of us.

    Event Beyond Our Control

    Shall have the meaning in paragraph 12.1.

    FCA Rules

    The rules contained in the FCA’s handbook of rules and guidance (as may be amended and updated from time to time).

    Financial Services Compensation Scheme or "FSCS"

    AA statutory compensation fund from which you may be able to make a claim in the event that a regulated firm is unable (or is likely to be unable) to pay a claim against it.

    Funds

    The investment funds that are made available to you from time to time for investment via the Service as described in paragraph 10.1 of Section 1.

    HMRC

    His Majesty’s Revenue & Customs.

    Investment Services

    The services that WithPlum will provide to you as further defined in paragraph 3 of Section 1.

    Key Features Document

    SIPP key features documents. This document is designed to provide you with key information about the product and how it works to help you decide whether the product is right for you.

    Key Investor Information Document or KIID

    A short document which a fund manager of a fund categorised as a “UCITS” is required to produce and make available to you in accordance with applicable laws prior to you making a decision to invest and which contains key investor information about the relevant fund and which you should read carefully.

    Money Purchase Annual Allowance

    This applies from the point you first access any pension benefits flexibly and is the maximum amount that can be contributed annually thereafter to money purchase pension schemes and still benefit from tax relief.

    Order

    An instruction received by the SIPP Product Provider from WithPlum to buy or sell investments within your SIPP Platform Product.

    Order Transmission Policy

    The policy set out in Section 4 which WithPlum has adopted to ensure that when it receives instructions from you to undertake an investment (through WithPlum) and transmits those instructions to the SIPP Product Provider to execute, it does so with a view to achieving the best possible result for you in accordance with the FCA Rules.

    Outstanding Fees

    Fees and charges that are payable by you to us and/or the SIPP Product Provider, but which are outstanding from time to time.

    Pension Ombudsman Service or “POS”

    The office to whom you may refer a complaint you have about the administration or management of a pension if we cannot resolve or settle your complaint (to your satisfaction) in accordance with our complaints procedure. (See also Financial Ombudsman Service).

    Pension Provider

    Refers to the SIPP Product Provider.

    Plum Terms / Terms

    Refers to the Plum General Terms and Conditions, the Investment Terms and the SIPP Product Provider Terms.

    Previous Tax Year

    Any previous period between 6 April and the following 5th April.

    Scheme

    The HMRC registered pension scheme, under which the Plum SIPP operates, administered and managed by the SIPP Product Provider.

    SIPP

    The self invested personal pension arrangements established for you under the Scheme.

    SIPP Platform Products

    Self Invested Personal Pension (or “SIPP”) that are made available to our users through WithPlum.

    SIPP Product Provider

    Quai Investment Services Limited.

    SIPP Product Provider’s Administrator

    QUAI Administration Services Limited.

    SIPP Product Provider Agreement

    The agreement between you and the SIPP Product Provider, as further defined in paragraph 6.3 of Section 1.

    Transfer In

    In relation to your SIPP, a transfer in of cash from another pension.

    Transfer Out

    In relation to your SIPP, a transfer of cash or investments to another pension.

    UCITS

    An Undertaking for Collective Investment in Transferable Securities (UCITS) is an investment fund that invests in liquid assets and can be distributed publicly to retail investors across the EU.

    UK

    Includes England, Scotland, Wales and Northern Ireland.

    U.S. Person

    Any United States citizen or other person who is defined as such by the United States Internal Revenue Services the detail of which is accessible via irs.gov

    Withdrawal

    Your instruction to transfer cash and/or investments from your SIPP Platform Product through your Plum Account and “Withdrawn”, “Withdraw” shall be interpreted accordingly.

    WithPlum

    Means the interface we provide to access the Investment Services and any other product or service offered by us from time to time.


Appendix 1. SIPP Product Provider Privacy Statement


Quai Investment Services Limited (Quai) will be known as the ‘Data Controller’ of the personal information you provide to us. The company registration number for Quai is ZB125709 and the registered address is: Unit 16 Tesla Court, Innovation Way, Peterborough, PE2 6FL.

Quai is committed to protecting and respecting your privacy. Our Privacy Statement is to let you know:

• How and why we collect personal information

• What we do with it

• When and why we share it with other organisations

• How long we keep it

• The rights and choices you have with regard to your personal information

Contact Us

If you have any questions about how we have handled your personal information or wish to raise a complaint about how we have handled your personal information, you can contact our Data Protection Officer at compliance@quai-digital.co.uk

If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). For further information about the ICO and their complaints procedure visit ico.org.uk.

How we collect personal information

You, your financial adviser or your employer may give us information about by completing application forms (paper versions or online) or by contacting us by phone, email or letter.

The personal information we gather may include, but is not exclusive to:

• Your name

• Address

• Date of Birth

• National Insurance Number

• Plum Account Number

• Gender

• Email address

• Telephone Number

• Bank account details

• Emergency Contacts

• Medical information (in certain limited circumstances)

• Any further information required as part of a product application

Why we need it and what we do with it

We use your personal information in the following ways:

We need to know basic personal information in order to provide you with the services you have engaged us to provide and to ensure that your account is administered as efficiently as possible. This includes such information as is required to comply with all legal and regulatory requirements.

We will not collect personal information from you that we do not need in order to provide the services we have agreed to provide to you.

We keep the personal information we collect from you, your employer, and other third parties, where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

We hold personal information securely and limit access to those who need to see it.

The personal information we collect may be transferred to, and stored at, a destination outside the UK. This could be to another company within the Quai group of companies or to external service providers working on our behalf.

Where any such processing takes place, appropriate controls, such as adoption of agreements containing the appropriate standard clauses, will be put in place to ensure that the personal information is protected to the same standard as if it were in the UK.

How long we keep it

In most circumstances we will retain personal information for the lifetime of a plan or product or for up to seven years after the end of the relationship with us. This is to ensure we comply with our retention obligations, as set out by the Financial Conduct Authority (FCA) and other regulatory and legislative requirements.

Certain circumstances dictate that we retain some specific information for longer, i.e. pension transfer information, HMRC tax records etc.

Our retention obligations are reviewed on a regular basis to ensure that we do not keep personal information longer than we are legally obliged to.

When we have no ongoing legitimate business need to hold your personal information, we will either delete it or anonymise it. If we can’t do this we will securely store your personal information, only use it for a purpose we’ve already communicated to you, and isolate it from any further processing until archives are deleted.

What are your rights?

Under data protection legislation, you have rights including:

You are not required to pay any charge for exercising your right to access. If you make a request, we have one month to respond to you.

If you wish to make a request, please contact us at:

Data Protection Officer
Quai Investment Services Limited
Unit 16 Tesla Court
Innovation Way
Peterborough
PE2 6FL

How to Complain

If you have any concerns about our use of your personal information, you can make a complaint to us at the above address.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICOs address:

Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline Number: 0303 123 1113

ICO Website – https://www.ico.org.uk