• General Terms & Conditions

• Plum Cash ISA Terms

• Interest Pockets Terms

• Plum Card Terms

• Plum ISA/GIA Terms & Conditions

• Plum SIPP Terms & Conditions

• Stock Investing Terms & Conditions

• Money Market Fund ("Plum Interest") Terms and Condition

• Order Handling And Best Interest Policy

• Risk Warning Notice

• Recurring Investment Terms

Plum General Terms and Conditions

This document (together with our Privacy Policy) ("Terms") details the general terms and conditions governing this relationship and sets out the rights and responsibilities we each have in this context. These Terms include important information about who we are and prescribe the way in which we will provide products or services ("Products and Services") to you.

Our Products and Services are made available to you on a non-advised basis. This means that Plum will not provide you with any advice or make any recommendations about whether and how you should use our Products and Services. You are solely responsible for any decisions you take in this context. You must note that certain of our Products and Services involve capital at risk and the value of your investments may go down, as well as up, and you may lose all of the capital that you have invested.

You will not be able to use any of our Products and Services unless you accept these Terms. Please read them carefully and make sure that you understand them before deciding to sign up with us. We may amend these Terms from time to time. Please refer to clause 13.7 for more information. You can find the latest version of these Terms on our website https://withplum.com/legal/terms.html or you may ask for a copy at any time.

Note that these Terms are general terms and not specific to any of our Products and Services. Each of our Products and Services may be subject to additional specific terms, which you will need to agree to and which may take precedence over these Terms. Please refer to clause 1.1 of these Terms for more information.

These Terms, along with our Terms of Website Use, any applicable Premium Service Terms and any other specific terms and conditions that apply to our Products and Services, constitute a legal agreement between you and Plum Fintech Limited and Saveable Limited, as the case may be depending on the Products and Services you receive (the latter two referred to in these Terms together or separately as "Plum", "we", "us", etc.).

A glossary of defined terms used in these Terms is set out in Annex 1.

1. Information about us

2. 1. Depending on the products and/or services you may choose to use, your provider will be one of Plum Fintech Limited or Saveable Limited. Plum Fintech Limited or Saveable may provide the product and/or service using Third Party Providers. This will be clearly stated in each of the specific product terms and conditions, but also reflected in the following table.

      Product / Service	Provider	Relevant terms
      Aggregation Partner	TrueLayer Limited	TrueLayer Limited Terms
      E-Money Provider	Modulr FS Limited	Modulr FS Limited Terms
      Card Services Provider for Card	PayrNet Limited and PayrNet Limited Consumer Cardholder Terms (VISA)	PayrNet Limited TermsVISA Card Terms
      Plum Cash ISA	Saveable Limited	Plum Cash ISA Terms
      Interest Accounts (Interest Pocket Terms)	Investec Bank Plc	Interest Pockets Terms
      ISA / GIA Terms and Conditions	Saveable Limited	Plum Investment Terms
      SIPP Terms and Conditions	Quai Investment Services Limited	SIPP Investment Terms
      Stock Investing	Alpaca Securities LLC	Stock Investing Terms
      Money Market Fund ("Plum Interest") Terms and Conditions	Saveable Limited	Money Market Fund ("Plum Interest") Terms

   2. Plum Fintech Limited, trading name Plum, is a company registered in England and Wales under company number 09952199 with registered office at Floor 2, 2-7 Clerkenwell Green, EC1R 0DE, London. Plum Fintech Limited is registered with the Financial Conduct Authority (“FCA”) in the UK (reference number 836158 and 902844) to provide account information services, under the Payment Services Regulations 2017.
   3. Plum Fintech Limited is a distributor of Modulr FS Limited, a company registered in England and Wales with company number 09897919, which is authorised and regulated by the Financial Conduct Authority (‘FCA’) as an Electronic Money Institution (Firm Reference Number (‘FRN’): 900573) for the issuance of electronic money and payment services. Your account and related payment services are provided by Modulr FS Limited. Modulr FS Limited (a company registered in England and Wales under company number 09897919), registered office is at Scale Space, 58 Wood Lane, London, W12 7RZ, United Kingdom.
   4. Plum Fintech Limited is also registered with the FCA in the UK (FRN: 902844) as an e-money agent of PayrNet Limited, which is an e-money institution also authorised by the FCA in the UK (FRN: 900594). This registration is maintained pursuant to Plum Card that is issued by PayrNet Limited with a licence from Visa. PayrNet Limited (a company registered in England and Wales under company number 09883437), registered office is at Kemp House, 152 City Road, London, EC1V 2NX, United Kingdom and is regulated by the FCA for issuance of electronic money under FRN 900594.
   5. Saveable Limited, trading name Plum and Plum Money, is a company registered in England and Wales under company number 09777255 with registered office at Floor 2, 2-7 Clerkenwell Green, EC1R 0DE, London, United Kingdom Saveable Limited is authorised to carry out a wide range of regulated activities in the UK, including certain investment, insurance and consumer credit activities, and it is regulated by the FCA in the UK (FRN: 739214).
   6. We are not a financial adviser, and we do not provide financial, legal, tax or any other advice. We are not responsible for ensuring your Plum Wallet or your Plum Account has sufficient funds for your needs, purposes, or transactions. We do not make any representations, warranties, or guarantees of any kind that any or all of the Products and Services are suitable or appropriate for you. If you are not sure whether any of the Products or Services are suitable or appropriate for you, you should seek advice from a qualified financial, legal, tax or other adviser.

2. Plum Website and App

3. 1. You can find a lot of information about us and our Products and Services on our website https://withplum.com ("Plum Website").
   2. We also operate a mobile application ("Plum App") which you can download on your mobile phone. All Products and Services are delivered via the Plum App, and as such, you will not be able to access the Products and Services without having first installed the Plum App.
   3. The use of the Plum Website and Plum App is governed by our Terms of Website Use which can be found on the Plum Website. Please take the time to read these carefully.

3. Our Products and Services

4. 1. Plum will act with all due skill, diligence, and care when making the Products and Services available to you.
   2. Access to the Products and Services is provided at Plum’s sole discretion. Plum may reasonably, and as permitted under applicable law, add, modify or discontinue any feature, functionality or any other tool within the Products and Services at its own discretion and without further notice to you. Where a material adverse change is made to the core functionality of the Products and Services, Plum will provide you with reasonable prior notice of such change in accordance with the relevant provisions.
   3. You may use our Products and Services only for lawful purposes. You may not use our Products and Services:
   4. • in any way that breaches or is intended to breach any applicable local or international law, regulation or policy or causes Plum to breach any applicable law, regulation or policy;
      • in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect;
      • for the purpose of harming or attempting to harm others, including minors and vulnerable persons (as such term is defined by the local legislation) in any way;
      • for anything that is abusive or incites hate, violence or does not comply with Plum’s policies;
      • in connection with any unsolicited or unauthorised advertising or promotional material or any other form of spam;
      • in connection with harmful programs like viruses or spyware or similar computer code designed to adversely affect the operation of any computer software or hardware;
      • in any way that would evade any applicable taxes, levies or duties illegally or facilitate any form of tax evasion;
      • in any way that facilitates money laundering and/or terrorist financing.
   4. Account Information Management Services:
   5. • This service will enable you to access, manage, and act on information regarding your individual personal account(s) held with your bank ("Personal Account(s)"). The service does not address any accounts held for business purposes.
      • We track and analyse information from your Personal Account(s) in order to help you better understand your income, expenses, and spending patterns. Making use of our analytics, Plum will be able to identify funds in your Personal Account(s) that may be put aside and transferred automatically to your Plum Wallet.
      • Note that Plum is not endorsed or sponsored by the providers of your Personal Account(s).
   5. Plum Wallet:
   6. • The Plum Wallet is an e-money wallet.
      • Benefiting from the data made available to you through the Account Information Management Services, and based on specific parameters (amount of funds, frequency of transfers, etc.) as set by you via the Plum App, we can assist you effect transfers of funds from your Personal Account(s) to your Plum Wallet.
      • For these purposes, and as applicable, we will set up a direct debit mandate for you with an appropriately authorised Third Party Services Provider. The direct debit will continue until you notify us that you wish to cancel it by contacting us. We may not be able to stop payments which are already in progress or scheduled to take place when you give notice to cancel because, for example, the notice to cancel is too close to the payment date and the relevant instructions to make those payments have already been acted on. You can also cancel a direct debit by contacting the provider of your Personal Account(s) directly.
      • We are not liable for any overdraft charges you may incur as a result of any direct debits related to your use of our Products and Services, including the Plum Wallet, unless we are negligent in cancelling your direct debit when asked to do so.
      • Note that only funds from your Personal Account(s) may be transferred to your Plum Wallet.
      • Your funds will remain in your Plum Wallet until you instruct us to transfer any or all of your funds from your Plum Wallet to your Personal Account(s) by using the "withdraw" functionality in-app. We will generally transfer the requested funds from your Plum Wallet to your Personal Account(s) within one Business Day of when we receive your request. If you do not have sufficient funds in your Plum Wallet to cover the amount of the requested transfer, your request for the transfer will be declined.
      • We may also transfer funds from your Plum Wallet to your Personal Account(s) without notice to you upon the closure of your Plum Account, and at any time if required under applicable law, or if we, in our sole discretion, reasonably suspect that the Products and Services, including the Plum Wallet, are being used for illicit purposes or otherwise in violation of these Terms.
      • Your Plum Wallet is operated and maintained by the E-Money Provider for whom we distribute and redeem electronic money. The E-Money Provider is obliged to safeguard your money, which they will do by placing funds into a segregated account. If we cease to trade, or become insolvent, the E-Money Provider will arrange for the redemption of any funds in your Plum Wallet. If the E-Money Provider ceases to trade, or becomes insolvent, we will make claims for the redemption of your funds on your behalf. Even though your funds are segregated, you should know that your money is pooled with money belonging to other Plum users and other customers of the E-Money Provider. If the E-Money Provider is unable to redeem the funds in your Plum Wallet, your claim will not be against a specific account but against the pool in general.
      • For the purpose of clarity, your provider for the Plum Card is your Card Services Provider.
   6. The Premium Services:
   7. • The Premium Services are subject to specific additional terms and conditions (the “Premium Service Terms”) and may incur additional fees or subscription charges found in Appendix 1. The Premium Services Terms include:
      • 1. The Interest Pocket Terms set out here;
        2. the Investment Services (Stocks & Shares ISA, SIPP) Terms set out here;
        3. the Cash ISA Terms set out here;
        4. the Card Terms set out here;
        5. the Stock Investing Terms set out here;
        6. the Money Market Fund ("Plum Interest") Terms and Conditions here; and
        7. any other service terms that we describe as “Premium Service Terms” from time to time.
      • Note that Premium Services may be provided by third parties. In these cases, provided we have exercised due skill, diligence, and care in selecting the relevant Third Party Providers, Plum is not responsible or liable for their supply (or failure to be supplied) and does not endorse or recommend any Premium Services offered by Third Party Providers. If you choose to proceed with a Premium Service offered by a third party, we will act as your agent in arranging it. When receiving a Premium Service from a Third Party Provider, in addition to the Premium Service Terms, you will also be subject to the terms and conditions of the relevant third party, over which we have no control or discretion. You should decide whether to use any Premium Services from a Third Party Provider only at your own discretion and risk. If you have any doubt about whether a certain Premium Service is provided by us or by a Third Party Provider, please ask us.
      • Premium Services may involve the transfer of funds from your Plum Wallet to facilitate move of funds in connection with the use of Premium Services or a Third Party Provider, and your ability to access your money will depend upon the relevant Premium Service Terms.
      • Funds released from closing, redeeming or withdrawing from a Premium Service will be paid back to your Plum Wallet, unless otherwise specified.
      • From time to time, we, or third parties on our behalf, may offer trials of Premium Services for a specified period (Trial Period) without payment or with payment at a reduced rate for a specified period (Discount Period). The selection of customers along with the specified period may vary based on various factors, including but not limited to, their usage history, subscription plans, engagement, or other criteria determined by us. Plum may determine at its sole discretion your eligibility for a Trial or Discount Period, and withdraw or modify a trial or discount at any time without prior notice and with no liability and obligation to provide any explanation or reasoning for the selection or discontinuation process, to the extent permitted under applicable law.
      • Trial and/or Discount Period may be communicated to you through various channels such as email, in-app notifications, or other means of communication and social media as deemed appropriate by us. To avail yourself of the Trial and/or Discount Period, you must follow any instructions provided in the communication received from us or in the Plum app. Failure to follow the specified instructions may result in the discontinuation of the Trial and/or Discount Period.
      • We may require you to provide your payment details to start the Trial and/or Discount Period. By providing such details you acknowledge and agree that we may automatically begin charging you for the Premium Services on the first day following the end of the Trial and/or Discount Period on a recurring monthly basis or another interval that we disclose to you in advance. If you do not agree with these clauses on the Trial and Discount Period, you should refrain from accessing or using it.
      • If you do not wish to continue receiving the Premium Service(s) you must cancel these, and the respective trial, via the App before the Trial Period lapses. Plum bears no responsibility for providing you with advanced notice of the expiry of a Trial Period and you bear sole responsibility for giving notice that you do not wish to continue to receive the Premium Services prior to the expiry of the Trial Period.
   7. Plum Referral Programme
   8. • From time to time, you may be enrolled into a Referral Campaign under which you may be able to invite eligible persons to use our Products and Services. Provided the successful completion of the necessary steps described in each Referral Campaign, you may be eligible for a Referral Bonus.
      • An eligible person can be anyone over the age of 18, who is not an existing Plum user at the time they are invited.
      • We may suspend a Referral Campaign at any time, if we have reason to believe that it is being abused or not made in good faith. We may do this on an individual or campaign-wide basis.
      • In cases of suspected fraud and/or material abuse of the Plum Referral Programme, further action may result in the suspension of your Plum account. If the Referral Bonus has been paid to you, we have the right to recover it in such cases. If the Referral Bonus has not yet been paid to you, we have the right to not proceed with its payment in such cases.
      • Additional terms relating to the Plum Referral Programme can be found under the Plum Frequently Asked Questions (FAQ) section, which you can visit here. You must read these terms carefully to ensure that you understand your obligations under the Plum Referral Programme.
      • You must claim any Referral Bonus(es) when it’s paid to your Plum account. If you decide to close your Plum account, we may recover any unclaimed Referral Bonus(es) unless you reach out to claim it within one (1) month after the closure of your Plum account. Plum will not be liable for any loss when you fail to claim the Referral Bonus(es) in due time.

4. Using our Products and Services

5. 1. Application
   2. • You must make an application ("Application") via our App in order to use our Products and Services. You are not able to make an Application on behalf of another person.
      • By submitting your Application, you confirm that the information you have provided is accurate and complete. You acknowledge that we may require further information from you in order to consider your Application. If any information provided in your Application is found to be incorrect or incomplete, we may reject your Application but will return to you any funds received.
      • If we have been unable to complete identity verification checks to our satisfaction following our receipt of your Application, we may reject your Application but will return to you any funds received.
      • We maintain full discretion to accept or reject your Application and reserve the right to do so without providing any reasons.
      • We will notify you once we have reached a decision (either positive or negative) regarding your Application, save where we are restricted from doing so by applicable law.
   2. Access:
   3. • You can access our Products and Services through our App.
   3. Eligibility:
   4. • You must be over 18 years old to use our Products and Services and maintain an individual bank account that is personal to you and not used for business or commercial purposes.
      • You must be a UK resident to use our Products and Services and you must be a UK resident for tax purposes to use the Premium Services that are subject to the relevant Premium Services Terms as noted above in Section 3.6.
   4. Obligations:
   5. • As a condition of receiving access to the Products and Services, you shall:
      • 1. exercise all due care, skill, and diligence in use of the Products and Services;
        2. ensure that you comply with all applicable laws and regulations in connection with its access to and use of the Products and Services;
        3. enter into and continuously comply with your obligations under all documentation required by Plum in connection with the provision of the Products and Services;
        4. provide all such documentation or information as may be reasonably required by Plum to ensure its compliance with applicable law and regulation, including, but not limited to, information to verify your identity, your financial circumstances, or other, your financial circumstances, or other, and failure to do so may result in the termination of your Account in accordance with the provisions of these Terms;
        5. not use the Products or Services to provide products or services to any third party;
        6. give us consent to access your Personal Account(s) on a read-only basis in order to use our Product and Services. You must use said Personal Account(s) only for self-use or personal use, not business purposes;
        7. confirm that the Personal Account(s) is/are owned in your name and not in the name of any other person or a legal entity;
        8. agree to submit only one Application to use our Products and Services and to have only one Plum Account. Any additional Plum Accounts identified, will result in termination of said Plum Accounts, in accordance with provision 13 of the Terms.

5. Fees

6. 1. We reserve a right to charge a fee, in the form of subscription or other, for the Products and Services we provide to you. Any subscription fees you may have to pay to us are listed on the Plum Website, whereas all other related fees are listed on the Fees section of the Plum Website. Unless we have agreed otherwise, all fees arising in connection with the provision of the Products and Services shall be due and payable by you to us immediately.
   2. If not enough money is held in your Personal Account or Plum Wallet to pay the fees or other amounts you owe us, we may recover the amount due by:
   3. • exercising our right of set-off; or
      • exercising our legal rights, such as instructing lawyers or debt collectors.
   3. If we take any (or all) of these steps, we might charge you our reasonable costs.
   4. You must pay, or reimburse, us for any taxes applicable to you, now or in the future, as a result of using the Products and Services.

6. Our Regulatory Obligations

7. 1. Conflicts of Interest
   2. • We comply with applicable law concerning conflicts of interest and we maintain a conflicts of interest policy, a copy of which you can access here. To that end, we have put in place and comply with various organisational and administrative measures to avoid any conflicts which may negatively affect your and our interests.
      • If, in providing you with our Products and Services, there is a risk of a conflict of interest arising between you and us (including Plum’s managers, employees or persons directly or indirectly related to Plum), or between you and another client, we will clearly inform you about the general nature and/or sources of such conflicts of interest and the measures taken to mitigate such risks before providing you with any of our Products and Services.
      • Note that a separate policy in respect of avoiding and managing conflicts of interests may apply to you under the Premium Service Terms or the Third Party Provider Terms.
   2. Record Keeping
   3. • We maintain records relating to the verification of your identity and for activities carried out under this agreement in accordance with applicable law and the FCA Rules.
      • We may record and monitor conversations and/or correspondence that we have with you. We will store recordings in accordance with applicable law and the FCA Rules.
   3. Appropriateness
   4. • Before providing you with certain Products and Services, we may need to ask for information about your knowledge and experience relevant to specific financial instruments to enable us to carry out an appropriateness assessment. An appropriateness assessment is designed to ensure that you are able to understand the terms and risks involved in investing in a particular financial instrument.
   4. Safeguarding your Funds
   5. • We are not responsible for safeguarding your funds when using our Products and Services. Safeguarding obligations may apply to Third Party Providers. Please refer to the Third Party Providers Terms, as these may be applicable to you.
      • We do not hold any client money or assets for you unless it is in relation to certain Products and Services where this has been specifically identified as such.

7. Third Party Providers

8. 1. We may partner with Third Party Providers, including E-Money Provider, when making our Products and Services available to you. These Terms include important information about the relationship you might have with such Third Party Providers. Note that Third Party Providers may have their own terms and policies which may be applicable to you. Please also refer to our Privacy Policy for information about the processing of your personal data in this context.
   2. When selecting Third Party Providers, we shall act in your best interests and in accordance with applicable laws.
   3. The Third Party Providers we use in each case may differ. For instance, we may, as your agent, redeem e-money held with an E-Money Provider and distribute to you e-money of the same value issued by another appropriately authorised E-Money Provider. We may do this for regulatory reasons, to implement contingency measures in the event of business interruptions or to improve our technical capabilities and operational standards.
   4. We will inform you of the identity and terms of any Third Party Providers you might use when providing you with our Products and Services. Should we decide to replace any of the Third Party Providers we have already spoken to you about, we will notify you as per the relevant provisions with the Third Party Provider, or otherwise at least ten (10) Business Days, in advance of the change being effected, unless we implement contingency plans or act to comply with applicable law, in which case we will tell you as soon as possible. If you do not consent to the replacement of a Third Party Provider, you may terminate your contract with us in accordance with provision 13.1.

8. Security Issues

9. 1. General:
   2. • You must not allow anyone to access our Products and Services on your behalf.
      • You must treat your security credentials, identification code, password, and any other piece of information linked to the applicable security procedures as confidential, and you must not disclose it to any third party.
      • You must notify us immediately if you have reason to believe that any of the aforementioned information, or any other information relevant to your app security have been disclosed to a third party.
      • You must use material, information, and content made available to you exclusively for the purposes of using the Products and Services. You may not copy, reproduce, distribute, or create derivative works from this content.
      • You may not reverse engineer or reverse compile any of the technology associated with us.
   2. Access to your Personal Account(s):
   3. • In order to ensure we can access information from your Personal Account(s) securely, we may work with and redirect you to one of our trusted Aggregation Partner(s). You will be asked to provide your explicit consent to enable us and our Aggregation Partner(s) to access specified information about your Personal Account(s) and your transactions on a read-only basis. To keep you safe, we will periodically ask you to renew your consent, including in circumstances where access is in relation to transactions executed more than 90 calendar days ago.
      • You may withdraw your consent to access your Personal Account(s) at any point. If you do withdraw (or fail to renew) your consent, we may be unable to provide you with some or all of our Products and Services.
      • If you have cancelled any of your Personal Account(s) or transferred a Personal Account to another bank, or where your Personal Account(s) has been restricted, disabled, suspended, or terminated by the provider of your Personal Account(s), you must inform us as soon as reasonably possible. You should be mindful that such an event may impact your ability to receive our Products and Services, but that such event will not impact your obligations under Clause 5.2.
   3. Your Information:
   4. • For our compliance purposes, and in order to provide our Products and Services to you, you hereby authorise us to, directly or through a third-party, obtain, verify, record and, where appropriate, share information and documentation that helps us verify your identity and Personal Account(s) information. When you register to Plum, and from time to time thereafter, we may require you to provide and/or confirm information and documentation that will allow us to identify you. You agree to provide us from time to time with all such information and documentation about you as we may reasonably require in order to fulfil (i) our obligations under applicable laws; and/or (ii) our obligations to you under these Terms.
      • Where we request information about your identity, including information relevant to third parties provided by you, we maintain such information under our record keeping requirements throughout which period these Terms are in effect in accordance with applicable law and the FCA Rules.
      • By agreeing to these Terms, you grant us and our Aggregation Partner(s) a non-exclusive, royalty-free licence to use the information from your Personal Account(s) in connection to the Products and Services you have chosen to use or as otherwise required under these Terms. We will only have the right to use, modify, display, distribute, and create new material using or incorporating information from your Personal Account(s) to provide Products and Services to you. When retrieving information from your Personal Account(s), we are doing so only as your representative and on your behalf and not on behalf of or in the name of any third party.
      • Our Aggregation Partner(s) and we may also use, sell, licence, reproduce, distribute and disclose aggregate, non-personally identifiable information that is derived through your use of the Products and Services.
      • We may disclose your identity and information relating to your Personal Account(s) to third parties and authorities if we are required to do so under any applicable law or court order.
      • We do not check the accuracy of the information in your Personal Account(s) or any other personal information you provide to us. We rely on you to ensure that any such information is up to date, complete, and accurate.
      • By agreeing to these Terms, you represent that you are the legal owner of the data in your Personal Account(s) and that you have the authority to appoint, and do expressly appoint, our Aggregation Partner(s) as your agent and grant a limited power of attorney to access and retrieve such data on your behalf.
   4. Security Incidents:
   5. • If we become aware or suspect that you are affected by fraud and/or an operational security incident, your access and use of our Products and Services may be restricted until such time that the suspected incident is resolved.
      • If we believe that there is any suspected or actual fraud, or we suspect that there has been a security breach, we will contact you by email or any other secure means.
      • If you believe that your account has been compromised or you do not recognise activity on your account, please contact us at help@withplum.com.
      • Neither we nor our Aggregation Partner(s) can initiate any transaction on your Personal Account(s). However, if you are concerned about any activity on your Personal Account(s) please contact us.
   5. Lost or Stolen Device:
   6. • If your mobile device is lost or stolen, or if you suspect someone has gained unauthorised access to your username, security credentials (e.g. PIN) or password, you must contact us immediately at help@withplum.com. In order to take any action, you will need to provide certain account information so we can verify your identity.
      • If you have lost or had stolen any payment card provided to you by Plum, you must follow the relevant instructions in the terms and conditions for such payment card, which can be found here.
      • You must ensure that you are the only person who accesses and uses the Products and Services via the app.
      • You shall use reasonable endeavours such as using password protection on your device to prevent any unauthorised access to and use of the app and the Products and Services and, in the event that you suspect any such unauthorised access, promptly notify Plum.
      • You shall be solely responsible for maintaining and keeping secure all security credentials (e.g. PIN) or passwords required to access the Products and Services. If you become aware that you have lost or misplaced your security credentials, or that the security credentials have become or may become compromised, you shall inform Plum immediately and Plum reserves the right to suspend your access to and use of the Products and Services until such time as changes are made to its security credentials.
      • Until such time as you notify Plum that the security credentials have been lost or misplaced, Plum shall be entitled to rely on any instructions made via the Plum App or via email and you shall remain solely liable for any transactions entered into as a result.

9. Representations and Warranties

10. 1. You expressly represent and warrant on a continuous basis that:
    2. • you are over 18 years old and have full legal capacity to enter into an agreement to use our Products and Services;
       • you are the legal and beneficial owner of any monies that are used by you in relation to any of our Products and Services;
       • any monies used by you in relation to any of our Products and Services do not constitute the proceeds of crime;
       • you are acting solely on your own behalf and not as agent for another;
       • you understand that you bear sole responsibility for all decisions made in connection with your access to and use of the Products and Services;
       • you will not use our Products and Services to engage in any activity that is fraudulent, deceptive, misleading, manipulative, abusive, or otherwise brings or causes to bring Plum into disrepute;
       • factual information heretofore or contemporaneously furnished by you to Plum, for purposes of or in connection with the Products and Services is true and accurate in all material respects;
       • you have not relied on any oral or written representation or warranty made by Plum or any other person on Plum’s behalf, other than those explicitly out in these Terms;
       • if you choose to download or otherwise obtain any information, material and other content made available by or through us or a Third Party Provider, you will do so at your own discretion and risk and you are solely responsible for any damage to your operating system or loss of data following the download of any such material;
       • if you choose to use any of our Product and Services, you will do so for domestic and private purposes only and you will not use any of the Products and Services for any commercial, business or resale purposes; and
       • you understand that we make our Products and Services available on an "as is" and "as available" basis.
    2. Except as otherwise stated in these Terms, we and our Third Party Provider(s) expressly disclaim any other duties or warranties in relation to our Products and Services, as well as in relation to information, material, and other content made available by or through us or a Third Party Provider, whether express or implied, including, but not limited to the implied warranties of merchantability, fitness for a particular purpose, and non-infringement.
    3. We will act reasonably to ensure that our Products and Services operate as intended. However, neither we nor our Third Party Provider(s) make any warranty that:
    4. • we will meet your requirements;
       • we will be uninterrupted, timely, secure, or error-free;
       • the results and data that may be obtained from the use of our Products and Services will be accurate or reliable;
       • the quality of Products and Services, or information, material and other content made available by or through us or a Third Party Provider will meet your expectations;
       • any errors in the technology will be corrected.
    4. No advice or information, whether oral or written, obtained by you from or through us or our Third Party Provider(s) will create any warranty not expressly stated in these Terms.

10. Our Liability

11. 1. We will compensate you for any loss or damage you may suffer that is a foreseeable and direct result of our negligent breach of these Terms. A loss or damage is foreseeable in this context if it was contemplated by you and us at the time you agreed to these Terms.
    2. Subject to applicable laws, we or any Third Party Provider(s) (provided that we have exercised due skill, diligence, and care in the appointment of such Third Party Provider(s)) are not liable or responsible to compensate you for:
    3. • any loss or damage you may suffer that was caused by events outside our control, including, but not limited to changes in applicable law, a major suspension or interruption of public services or electrical power and delays or other malfunctions in our communications systems (including phone and email), IT systems, or the internet;
       • any loss or damage you may suffer that was not foreseeable at the time you agreed to these Terms;
       • any loss or damage arising from a failure of Plum to perform its obligations under these Terms due to a Force Majeure Event;
       • any damage to a device or digital content belonging to you which resulted from the use of our Products and Services [and which could been have avoided if you had followed our advice and recommended technological updates in respect of the use of Products and Services];
       • any loss of profit, loss of business or goodwill, damage to reputation, business interruption, or loss of business opportunity resulting from the use of our Products or Services;
       • any loss of data which is caused by factors other than negligence or breach of statutory duty of us or our Aggregation Partner(s);
       • the acts or omissions of the providers of your Personal Account(s);
       • any statement or conduct on or via Plum Website or Plum App by any third party;
       • the cost to you of obtaining goods or services as substitutes for the Products and Services we provide;
       • any other loss or damage suffered by you in connection with the Services and Products or these Terms; or
       • any loss, damages, or lost opportunity that arises in connection with the Plum App being unavailable to you or which arises in connection with your failure to ensure that you have downloaded the latest version of the Plum App.
    3. We do not in any way exclude or limit our liability for:
    4. • death or personal injury caused by our negligence; or
       • fraud or fraudulent misrepresentation.

11. Compensation

12. 1. You may be entitled to compensation from the Financial Services Compensation Scheme in respect of certain Products and Services. This depends on the type of business and the circumstances of the claim. Further information about compensation arrangements is available here and from the Financial Services Compensation Scheme website (www.fscs.org.uk).

12. Indemnification

13. 1. You agree to protect and fully compensate us, our affiliates, and our Aggregation Partner(s) from any and all third party claims, liability, damages, expenses, and costs (including, but not limited to, reasonable solicitors’ fees) caused by or arising from your use of the Products and Services, your violation of these Terms or your infringement, or infringement by any other user of your Plum Account, of any intellectual property or other right of anyone.

13. Information about These Terms

14. 1. Termination: These Terms will remain in force until either you or us seek their cancellation in accordance with this clause.
    2. 1. Subject to these Terms, you can cancel your use of the Products and Services at any time by giving notice to us via email or via the Plum App.
       2. Subject to the Premium Services Terms, we can immediately cancel our provision of any of the Products and Services to you by giving notice to you via email or via the Plum App if:
       3. • your use of the Plum Account has been inactive for an extended period of time;
          • you commit a material breach of these Terms;
          • you commit a breach of the Terms of Website Use;
          • a Default Event occurs in relation to you.
    2. Suspension: where we become aware of any circumstances, or the possibility of such circumstances, under Clause 13.1.2 arising in connection with you, we may suspend your account with immediate effect and without prior notice to you whilst we conduct an investigation in relation to such circumstances. Where we suspend your Plum Account, we will notify you of that, save where we are restricted from doing so under applicable law.
    3. Death: once we have received a notification that you have died, we will suspend your Plum Account as soon as reasonably practicable. The value of any funds held in your Plum Wallet or otherwise connected to your Plum Account, including any assets, may form part of your estate and, provided we receive appropriate evidence that an appropriate representative is responsible for the management of your estate, we will act on the instructions that are given by those representatives. These Terms will continue in full force and effect until such time as your Plum Account is closed, at which point these Terms will terminate. You acknowledge and agree that Plum shall not be responsible for any losses incurred on your Plum Account whilst we await instructions from your representative(s).
    4. If your account is cancelled, we will subject to the completed cancellation process aim to complete transfer any funds in your Plum Account to your Personal Account as soon as reasonably possible. within two (2) Business Days. In the event you hold investments, these will be sold prior to your account being closed, as applicable your consent will be sought.
    5. Interpretation: In the event of any conflict or inconsistency between these Terms, the Terms of Website Use, any applicable Premium Service Terms, and any other terms and conditions that apply to our Products and Services, the Premium Service Terms will prevail and take precedence over these Terms, which in turn shall prevail over the Terms of Website Use.
    6. Language: These Terms and all information, notifications, and communication in relation to the Products and Services will be in the English language. Any communication, information or documents provided by you to us must be in English, and as applicable translated and certified by a professional and accredited translator, unless otherwise agreed between you and us.
    7. Updates and Amendments: We may from time to time update or amend these Terms, including, for the avoidance of doubt, the definitions, appendices and any arrangements made under or in connection with these Terms.
    8. • We can make changes to these Terms without your specific agreement. Unless required otherwise under the provisions of a Third Party Provider or applicable laws, we will make a reasonable effort to give you at least ten (10) Business Days’ notice of any changes and inform you of when these changes will become effective. If you do not agree to the changes, you can notify us and we will terminate these Terms in accordance with clause 13.1 and arrange for your account to be closed subject to any relevant Premium Service Terms. By continuing to use the Products and Services, or by failing to notify us of your objection within ten (10) Business Days after the changes to these Terms have been communicated to you, you agree to be bound by the revised Terms.
       • You can find the latest version of these Terms on the Plum Website. Any changes effected to the version of the Terms you originally agreed to, will be reflected in the latest version of the Terms available on the Plum Website.
    8. Third Party Rights: To the extent we rely on third-party providers for the provision of our Products and Services, such third-party providers are to be treated as beneficiaries of the relevant provisions of these Terms with all rights to enforce such provisions as if they were a party to these Terms. Save as otherwise expressly provided for in these Terms, no other person will have any rights to enforce any of its terms.
    9. Transfer of Rights: We may transfer our rights and obligations under these Terms to another legal entity. Your rights and obligations under these Terms will remain unchanged if this happens. Your consent is not required for such transfer, but we will notify you at least two (2) months before any changes are effected. You are not permitted to transfer or assign any of your rights and obligations under these Terms to any other person.

14. Data Protection

15. 1. How we process your data: By accepting these Terms you agree that we may use your personal information, including sensitive personal information, and store it on our systems and may otherwise process it for the purposes of providing our Products and Services.
    2. By accepting these Terms you agree that we may provide you with marketing materials, promotions and other information regarding any of our other Products and Services that we think may be of interest to you. If you do not wish to receive such materials, please contact us at help@withplum.com.
    3. We may pass personal information relating to you to third parties appointed by us for the purpose of administration and verifying your identity, as well as for the provision of our Products and Services.
    4. We may disclose your personal information if we are required to do so by law or we are requested to do so by the FCA, HMRC, or any other relevant regulatory authority in any country.
    5. Where it is necessary for the provision of our services, your personal data may be transferred to third parties outside the UK and the EEA as well as within it. You should be aware that in territories outside the EEA, laws and practises relating to the protection of personal data are likely to be different and, in some cases, may be weaker than those within the UK and the EEA. Where data is transferred outside of the UK and the EEA, Plum will take all reasonable steps to ensure that your data is protected to the most stringent degree possible and in line with industry guidance. By agreeing to these terms, you consent to such processing of your data.
    6. Our full terms outlining the protection, processing and treatment of your data can be found in our Privacy Policy.
    7. Questions, comments, and requests regarding our data protection policies are welcome and should be addressed to dpo@withplum.com.

15. Complaints

16. 1. Should you have any complaint(s) in relation to the Plum app, the Products and Services, or any other aspect in regards to your experience with us, please notify us in accordance with the Complaints section. 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. 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.
    4. Complaints must be submitted to us either via email or via our help widget in our in-app. You may find more information and instructions on how to submit a complaint, visiting the Complaints section on the Plum Website.
    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) written response to you. The address of the FOS is Exchange Tower, London E14 9SR. You can also telephone the FOS at: 0800 023 4567, or email the FOS at: complaint.info@financial-ombudsman.org.uk. You can find out further information about the FOS on its website: www.financial-ombudsman.org.uk.

16. Communication

17. 1. You may contact us and we may contact you as described in this clause.
    2. When we refer, in these Terms, to "in writing", this will include email and instant messaging.
    3. You can contact us in any of the following ways:
    4. • email us at help@withplum.com;
       • in-app via our help widget.;
    4. If we have to contact you or give you notice in writing, we will do so via email or through the App.
    5. It is your responsibility to ensure the contact information we have for you is up to date.
    6. You are required to notify us promptly if there is a change to: your legal name; your residential address; your Personal Account(s); your email address; your mobile number [if applicable]; and/or your status as a UK resident. Following any of these changes, it might be necessary for us to ask you for, and for you to provide, more information as part of this process in order for you to continue accessing and using any Products and Services, if applicable.

17. Authorised Representatives

18. 1. As a Plum account holder, you have the option to appoint a maximum of one authorised representative to act on your behalf in matters governed by this agreement. This includes making communications, requests, instructions, transactions, or other actions related to the subject matter and services covered by this Agreement.
    2. To appoint an authorised representative, you must submit a power of attorney in a format determined by Plum, along with the necessary supporting documentation. Plum reserves the right to request the original or a certified copy of the power of attorney before acting upon it. Additionally, anti-money laundering verification checks may be conducted on the appointed representative before accepting instructions from them.
    3. Plum retains the right to restrict the access or actions of an authorised representative concerning certain services. Furthermore, Plum may, at its discretion, request a written signature from you for any communication, request, instruction, or transaction made by an authorised representative.
    4. It is essential to note that you remain responsible for any communication, request, instruction, transaction, or other actions taken by your authorised representative. Plum will consider all activities on your account, including those carried out by the authorised representative, as if they were conducted by you.
    5. Plum will continue to accept and act upon any communication, request, instruction, transaction, or other action taken by an authorised representative until evidence of the termination of the power of attorney is provided. You must deliver such evidence in the format reasonably required by Plum, along with supporting documentation. Plum may require the original or a certified copy of the evidence of termination before taking any action based on it.

18. Other Important Terms

19. 1. Each of the paragraphs of these Terms, as applicable from time to time, operates separately. If any court or relevant authority decides that any of them are invalid, unlawful or unenforceable, the remaining paragraphs will remain in full force and effect.
    2. If we fail to insist that you perform any of your obligations under these Terms, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations. If we waive a default by you, we will only do so in writing, and that will not mean that we will automatically waive any later default by you.
    3. These Terms are governed by English law. This means any dispute or claim arising out of or in connection with these Terms will be governed by English law. The courts of England and Wales will have non-exclusive jurisdiction. However, if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are a resident of Scotland, you may also bring proceedings in Scotland.

Annex 1 - Glossary

The following terms shall have the following meanings:

"Aggregation Partner" means our third party provider supplying the technology allowing us to aggregate your bank account information, this is currently Truelayer Limited (FCA Registration number 901096), 3rd Floor 1 Hardwick Street, London, United Kingdom, EC1R 4RB.

"Business Day(s)" means 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.

"Card Services Provider" PayrNet Limited (a company registered in England and Wales under company number 09883437, registered office is at Kemp House, 152 City Road, London, EC1V 2NX, United Kingdom. This registration is Plum relationship maintained pursuant to operating and maintaining the Plum Card that is issued by PayrNet Limited with a licence from Visa.

"Default Event" means any one or more of the following events in respect to you:

1. you are the subject of, or are found guilty, or at fault in any criminal proceedings or investigation carried out by a governmental or regulatory authority in any jurisdiction;
2. you fail to pay any sum due and payable to Plum in accordance with the relevant time period for payment as prescribed within these Terms;
3. any representation or warranty made by you is or becomes untrue;
4. you are subject to a petition of bankruptcy, you make a general assignment for the benefit of, or enter into any reorganisation, arrangement or composition, with your creditors, or you state in writing that you are unable to pay your debts as they become due; or
5. any other circumstance occur or exist in respect of, in relation to or otherwise affecting it as a result of which Plum reasonably believes that it is necessary or desirable to take action under Clause 13.1.2

"E-Money Provider(s)" means our provider of E-Money who operate and maintain your Plum Wallet on our behalf Modulr FS Limited (a company registered in England and Wales under company number 09897919), registered office is at Scale Space, 58 Wood Lane, London, W12 7RZ, United Kingdom.
Modulr FS Limited (a company registered in England and Wales under company number 09897919), registered office is at Scale Space, 58 Wood Lane, London, W12 7RZ, United Kingdom.

"Force Majeure Event" means acts of God, fire, flood, drought, earthquake or other natural disaster, epidemic or pandemic; terrorist attack, civil war, civil commotion or riots, war, threat of or preparation for war, armed conflict, imposition of sanctions, embargo, or breaking off of diplomatic relations; nuclear, chemical or biological contamination or sonic boom; any law or any action taken by a regulatory or governmental authority, including without limitation imposing an export or import restriction, quota or prohibition; collapse of buildings, fire, explosion or accident; any labour or trade dispute, strikes, industrial action or lockouts (other than in each case by the party seeking to rely on this clause, or companies in the same group as that party); non-performance by suppliers or subcontractors (other than by companies in the same group as the party seeking to rely on this clause); and interruption or failure of utility service.

"Payment Services Provider" means the party which facilitates payments (including direct debits) to be made from your bank account into your Plum Wallet. This may be one of several Third Party Providers according to the type of payment. More information can be found in our Privacy Policy.

"Personal Account" means the personal banking account(s), only used for self-use or personal use, that Plum accesses on a read-only basis after your consent. Plum does not accept banking accounts which are held by legal entities.

"Plum Account" means the notional account which will encompass the totality of the products and services we will provide to you, and through which you will manage money.

"Plum Card" means the card issued by PayrNet Limited pursuant to licence from Visa

"Plum Wallet" means an e-money wallet, the primary pocket in your Plum Account where funds originating from your Personal Account(s) are deposited to and withdrawn from.

"Products and Services" means the products and services made available to you by or through Plum, or through Third Party Provider(s).

"Third Party Provider" means any third party entity that we partner with and rely on for the provision of our Products and Services, including our Aggregation Partner(s), Payment Services Provider(s), E-Money Provider, and Premium Services Provider(s).

"Third Party Provider Terms" means terms, conditions and/or policies applicable in respect of and governing your relationship with a Third Party Provider.

"Trial Period" means the length of time that the trial will be in place for, before you are deemed to have taken up the Premium Service. If not otherwise agreed, this will be thirty (30) days and, unless cancelled, you will be charged on the first day following the end of said trial.

"UK" means England, Wales, Scotland, and Northern Ireland.

Terms of Website Use

These Terms of Website Use (together with any documents referred to in it) detail the terms of use under which you may make use of our website https://withplum.com and the chatbot available through our App, whether as a guest or a registered user. Website Use includes accessing, browsing, or registering to use Plum.

Please read these terms of use carefully before you start using Our Site, as these will apply to your use of Our Site.

By using Plum, you confirm that you accept these terms of use and that you agree to comply with them.

If you do not agree to these terms of use, you must not use Plum.

Other applicable terms

These terms of website use refer to the following additional terms, which also apply to your use of Our Site:

• Our Privacy Policy sets out the terms on which we process any personal data we collect from you, or that you provide to us. By using Our Site, you consent to such processing and you warrant that all data provided by you is accurate.
• Our General Terms & Conditions apply to users who sign up to use our services ("Terms").
• The Premium Service Terms apply to users who sign up to use our premium services.
• Our Cookie Policy sets out information about the cookies on Our Site.

Information about Us

https://withplum.com is a Site operated by Plum Fintech Limited.

Plum Fintech Limited, trading name Plum, is a company registered in England and Wales under company number 09952199 with registered office at Floor 2, 2-7 Clerkenwell Green, EC1R 0DE, London. Plum Fintech Limited is registered with the Financial Conduct Authority (“FCA”) in the UK (reference number 836158 and 902844) to provide account information services, under the Payment Services Regulations 2017.

Plum Fintech Limited is a distributor of Modulr FS Limited, a company registered in England and Wales with company number 09897919, which is authorised and regulated by the FCA as an Electronic Money Institution (Firm Reference Number (“FRN): 900573) for the issuance of electronic money and payment services. Your account and related payment services are provided by Modulr FS Limited. Modulr FS Limited (a company registered in England and Wales under company number 09897919), registered office is at Scale Space, 58 Wood Lane, London, W12 7RZ, United Kingdom.

Plum Fintech Limited is also registered with the FCA in the UK (FRN: 902844) as an e-money agent of PayrNet Limited, which is an e-money institution also authorised by the FCA in the UK (FRN: 900594). This registration is maintained pursuant to Plum Card that is issued by PayrNet Limited with a licence from Visa. PayrNet Limited (a company registered in England and Wales under company number 09883437), registered office is at Kemp House, 152 City Road, London, EC1V 2NX, United Kingdom and is regulated by the FCA for issuance of electronic money under FRN 900594.

Saveable Limited, trading name Plum Money, is a company registered in England and Wales under company number 09777255 with registered office at Floor 2, 2-7 Clerkenwell Green, EC1R 0DE, London. Saveable Limited is authorised to carry out a wide range of regulated activities in the UK, including certain investment, insurance and consumer credit activities, and it is regulated by the FCA in the UK (FRN: 739214).

Changes to these Terms

We may revise these terms of use at any time by amending this page.

Please check this page from time to time to take notice of any changes we made, as they are binding on you.

Changes to our site

We may update Our Site from time to time, and may change the content at any time. However, please note that any of the content on Our Site may be out of date at any given time, and we are under no obligation to update it.

If we change these terms of use, we will post the revised document here with an updated effective date. If we make significant changes to these terms of use, we may also notify you by other means such as sending an email or posting a notice on our home page.

We do not guarantee that Our Site, or any content on it, will be free from errors or omissions.

Accessing Plum

Our Site is made available free of charge.

We do not guarantee that Our Site, or any content on it, will always be available or be uninterrupted. Access to Our Site is permitted on a temporary basis. We may suspend, withdraw, discontinue, or change all or any part of Plum without notice. We will not be liable to you if for any reason Our Site is unavailable at any time or for any period. We reserve the right to restrict or deny you access to all or some parts of Plum if, in our opinion, you have failed to comply with these terms of use.

You are responsible for making all arrangements necessary for you to have access to Plum.

You are also responsible for ensuring that all persons who access Our Site through your internet connection are aware of these terms of use, and other applicable terms and conditions, and that they comply with them.

Plum is directed to people residing in the United Kingdom. We do not represent that content available on or through Plum is appropriate or available in other locations. We may limit the availability of Our Site or any service or product described on Plum to any person or geographic area at any time. If you choose to access Plum from outside the United Kingdom, you do so at your own risk.

Intellectual property rights

We are the owner or the licensee of all intellectual property rights in relation to Plum, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You may print off one copy, and may download extracts, of any page(s) from Our Site for your personal use and you may draw the attention of others within your organisation to content posted on Our Site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of content on Our Site must always be acknowledged.

You must not use any part of the content on Our Site for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy or download any part of Plum in breach of these terms of use, your right to use Plum will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

No Reliance on Information

The content on Plum is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on Plum.

Although we make reasonable efforts to update the information on Our Site, we make no representations, warranties or guarantees, whether expressed or implied, that the content on Our Site is accurate, complete, or up-to-date.

Limitation of our Liability

Nothing in these terms of use excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by English law.

To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to Our Site or any content on it, whether express or implied.

We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

• use of, or inability to use, Plum; or
• use of or reliance on any content displayed on Our Site.

As a consumer using Plum, please note that we only provide Plum for domestic and private use. You agree not to use Plum for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programmes, data or other proprietary material due to your use of Our Site or to your downloading of any content on it, or on any website linked to it.

We assume no responsibility for the content of websites linked to from Plum. Such links should not be interpreted as endorsement by us of those linked websites. We will not be liable for any loss or damage that may arise from your use of them.

Different limitations and exclusions of liability will apply to liability arising as a result of the supply of any services to you, which will be set out in the Plum Terms and Conditions.

Acceptable Communication

When using our App or Our Site, you may on occasion require assistance from members of Plum staff in connection with an issue, finding more information or any other query. In any and all communications with Plum staff, the customer must refrain from any language or actions which may be considered abusive, aggressive, or harassment. Continued or repeating behaviour of this nature may result in the customer being banned from using the Plum App and cancellation of our agreement with the customer in accordance with clause 13 of the Terms and Conditions.

Viruses

We do not guarantee that Plum will be secure or free from bugs or viruses.

You are responsible for configuring your information technology, computer programmes and platform in order to access Our Site. You should use your own virus protection software.

You must not misuse Our Site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to Our Site, the server on which Our Site is stored or any server, computer or database connected to Our Site. You must not attack Our Site via a denial-of-service attack or a distributed denial-of-service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will cooperate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use Plum will cease immediately.

Linking to Plum

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.

You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

You must not establish a link to Plum in any website that is not owned by you.

Plum must not be framed on any other site, nor may you create a link to any part of Our Site other than the home page.

We reserve the right to withdraw linking permission without notice.

If you wish to make any use of content on Plum other than that set out above, please contact help@withplum.com

Validity

If any part or provision of these terms of use are found to be unlawful or unenforceable, this shall not affect the validity of any other part or provision.

Third Party Links and Resources in Our Site

Where Plum contains links to other sites and resources provided by third parties, these links are provided for your information only.

We have no control over the contents of those sites or resources.

Applicable Law

As a consumer, please note that these terms of use, its subject matter, and its formation, are governed by English law. You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction. However, if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

Contact us

To contact us, please email help@withplum.com.

Thank you for visiting Plum.

Appendix 1: Fees

Plum access fees (excluding Investment Funds, Stocks and Pensions)

See: https://withplum.com/

Investment Funds

See: Fee Schedule

Stock Investing Fees

See: Fee Schedule

Money Market Fund ("Plum Interest") Fees

See: Fee Schedule

Pension Fees

See: Fee Schedule

Plum Cash ISA Terms and Conditions

Introduction

This agreement (the “Cash ISA Terms”) is between you, the client (Client, you, your) and Saveable Limited, a company registered in England and Wales under company number 09777255 and registered at Floor 2, 2-7 Clerkenwell Green, EC1R 0DE, London (“Plum”, “we”, “us”, “our”). These Cash ISA Terms relate to the provision of certain services by Plum to you in relation to your Plum Cash ISA (“Cash ISA” or “Plum Cash ISA”) and the Cash ISA Services.

These Cash ISA Terms act as an addendum to the Plum General Terms and Conditions that are in place between you and us. You are entering into this agreement because you wish to receive the Cash ISA Services and any rights or obligations which you may have or be subject to under these Cash ISA Terms are in addition to the rights and obligations arising under the Plum General Terms and Conditions to which you are a party. The Plum General Terms and Conditions will continue to apply to you when accessing and using the Cash ISA Services. To the extent that any conflicts arise between the provisions of these Cash ISA Terms and the Plum General Terms and Conditions in relation to the Cash ISA Service, these Cash ISA Terms will prevail.

Throughout this agreement, we use certain capitalised terms. A full list of these capitalised terms can be found in the Glossary to these Cash ISA Terms. For any capitalised term not defined in the Glossary of these Cash ISA Terms, the definition is the one given in the Plum General Terms & Conditions.

These Cash ISA Terms contain important information that you need to read carefully. If you have any questions or doubts about any of the content in these Cash ISA Terms, you should seek appropriate professional advice before opening your Cash ISA.

There may be circumstances that require us to review these Cash ISA Terms and the charges being made. If a change we are proposing will be detrimental to you, we will provide you with at least 30 calendar days’ prior notice of that change, unless we need to make the change sooner because of legal or regulatory issues in which case we will make the information available within one business day of making the change. If we make a change that is not detrimental to you, we can make such a change immediately.

We may update these Cash ISA Terms in accordance with any amendment provisions in force from time to time between you and us under the Plum General Terms and Conditions.

About us

Plum Money is a trading name of Saveable Limited, an entity authorised and regulated by the Financial Conduct Authority “FCA” with firm reference number 739214. The FCA’s registered address is 12 Endeavour Square, London, E20 1JN. We can be contacted at help@withplum.com or via the Plum App.

1. Plum Cash ISA

2. 1. The Plum General Terms and Conditions relating to account opening shall apply to any application made by you. Open a Cash ISA and shall be supplemented by these Cash ISA Terms.
   2. In order to receive the Cash ISA Services you must ensure that you have the Plum App and that you have opened a Cash ISA with us. Further information relating to how to open accounts with us is provided in the Plum General Terms and Conditions and via our Website. When you open a Cash ISA, you will be deemed to confirm that the representations and warranties contained in the Plum General Terms and Conditions are true and accurate, and each time you deposit or withdraw cash you will be deemed to confirm that such representations and warranties remain true and accurate. It is a condition of opening a Cash ISA that you agree to these Cash ISA Terms and that you agree to comply with your obligations under these Cash ISA Terms.
   3. When opening your Cash ISA, we may utilise the services of third-party service providers to verify your identity and you agree that we may share your personal data with such providers for this specific purpose.
   4. You acknowledge and agree that Plum retains sole discretion as to whether to accept any request made by you to open a Cash ISA and just because you currently receive other services from Plum does not guarantee that you will be able to open a Cash ISA with us.
   5. Unless you have notified us of a lost or stolen device in accordance with the provisions in the Plum General Terms and Conditions, we are entitled to treat any deposits or withdrawals made via the Plum App as legitimate and rely on those deposits or withdrawals and you shall remain solely liable for any deposits or withdrawals that arise as a result.

2. The Cash ISA Terms

3. 1. Plum will provide the Cash ISA Services subject at all times to the provisions of these Cash ISA Terms. These Cash ISA Terms will govern all Transactions entered into by you under the Cash ISA Service.
   2. Access to the Cash ISA Service is provided to you at Plum’s sole discretion. Plum may add, modify or discontinue any feature, functionality or any other tool within the Cash ISA Service at its own discretion and without further notice to you.
   3. Plum will exercise all due skill, care and diligence in the performance of the Cash ISA Service and it shall owe no other duties to you other than those duties to perform the Cash ISA Service in accordance with this clause Plum shall be responsible for the performance of the Cash ISA Service as expressly set forth in these Cash ISA Terms and shall have no implied duties or obligations whatsoever.
   4. You must be a UK tax resident, and pursuant to our General Terms and Conditions, over the age of 18 to subscribe to our Cash ISA. If you hold a Cash ISA and you cease to be a UK tax resident, you must inform us immediately.
   5. You acknowledge and agree that you will be the sole beneficial owner of the Cash ISA. You may only subscribe to an ISA from your own funds. You may also transfer other providers’ Cash ISAs you may have to this Cash ISA.
   6. You can open a Cash ISA with us, and with other providers, within in the same tax year, without losing your allowance as long as you do not exceed your total annual allowance in any given tax year.
   7. 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.
   8. 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 Cash ISA will count towards your annual ISA subscription limit.
   9. 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.
   10. For details around closing your Plum Cash ISA, please refer to clause 6 below.
   11. 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:
   12. 1. the completion of the administration of your estate;
       2. the closure of the account by your executors;
       3. the third anniversary of your death.
   12. You can request us to transfer all of your Current Tax year’s ISA, and all of your previous tax years’ ISAs, held with us to another ISA plan manager.
   13. You can transfer in another Cash ISA to Plum at any time. We aim to complete transfers of Cash ISAs within 15 working days, or within 30 calendar days if you’re transferring another type of ISA. Transfer Ins are not eligible for the relevant bonus offering. Only full transfers-in for the current tax year, and previous years, are accepted.
   14. You can make a request to transfer out your ISA with Plum through Plum’s customer support, help@withplum.com. If you close your Cash ISA with Plum and Transfer Out within the 12 month period after opening your Cash ISA account with Plum you will lose your bonus and forfeit any interest earned that month. Only full transfers-out for the current tax year are accepted. Partial transfers-out are accepted for previous tax years.
   15. You will need to contact your new ISA plan manager to transfer out and make arrangements in accordance with their requirements. Your new ISA plan manager will need to contact us to arrange for the transfer.
   16. The Cash ISA Service will be provided on a non-advised basis, meaning that we will not provide you with any advice as to the merits of any particular Cash ISA or Transaction or whether a particular Cash ISA or Transaction is suitable for you. We will not provide you with any investment, legal, tax or other form of advice, nor can you request any such advice from us. You are solely responsible for any decisions taken in respect of any and all Transactions that you choose to enter or not enter into.
   17. For the purpose of the FCA Rules, which require us to categorise our customers, we will categorise you as a ‘retail client’ in accordance with the FCA’s client categorisation criteria. 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.
   18. We may be required to obtain certain information from you such that we can comply with our obligations under applicable law and regulation and you agree to provide any such information that we may reasonably request in the format within which we request it. You may be denied access to the Cash ISA Service until such time as we can obtain sufficient information from you to satisfy our obligations under applicable law and regulation. This information includes, but is not limited to, any information we need to verify your identity, any information we require for purposes of reporting and any information as to your knowledge and experience in relation to investments.
   19. As the Cash ISA is not a “complex” investment product, we may not carry out an “appropriateness assessment” to determine that you have the necessary knowledge and experience to understand the risks involved. Therefore, as we do not assess the appropriateness of the investment, your interests may be less protected.
   20. The Cash ISA product and the related tax benefits are covered by the ISA Regulations, and are subject to all of the rights and restrictions in those regulations. If any difference arises between these terms and conditions and the ISA Regulations (e.g. due to a change in regulation), the ISA Regulations will take precedence.

3. Subscriptions and Withdrawals

4. 1. Adding funds to your Cash ISA is done using funds held in your Plum Wallet, or direct from your bank account. Please consult the Plum App for more information.
   2. Withdrawals from the Cash ISA are received into your Plum Wallet.

4. Cash ISA Product Features

5. 1. Interest/return is accrued daily on the cleared balance held and paid monthly. The rate interest/return earned will be displayed in the Plum App with further details in the Key Features Document (“KFD” of the Cash ISA that is available here.)
   2. You can only withdraw interest that has been paid into your account (i.e. interest earned up to the last day of the previous month). If you wish to withdraw mid-month, you will forego any interest earned that month.
   3. The interest rate/return is subject to change at the discretion of the Interest Account/QMMF Provider, over which we have no control. Should a change occur, you will be informed at the earliest opportunity.
   4. Interest/return will not be earned on any transfer in until the transfer itself is fully completed - this means we have received both the funds and the transfer confirmation from the former provider.
   5. There may, on occasion, be additional money paid to your Cash ISA, including any bonus offering. The structure of these offerings will be clearly explained to you when they are introduced, and information on them will be available in the most recent KFD of the Cash ISA. More details regarding bonus offerings available in the KFD, here.
   6. Any cash held for the Cash ISA, including any cash gained from a bonus offering, will be held in accordance with the FCA Client Money Rules, i.e. in a Client Money bank account.
   7. Plum reserves the right to segregate client money in a qualifying money market fund (“QMMF”). In these cases, units in a QMMF will be held in accordance with the FCA Safe Custody Rules.
   8. For the avoidance of doubt, Plum will retain the difference (if any) between any interest received/return gained from the bank account/Q(MMF) deposits and the amounts paid to your Cash ISA.
   9. Pursuant to clause 4.6, and for the avoidance of doubt, the conditions of the interest/returns as provided by the (Q)MMF Provider referred to above do not apply to any bonus offering from Plum.
   10. Any cash held for the Cash ISA will be held in accordance with the FCA Client Money Rules - i.e. in a Client Money bank account.
   11. By agreeing to these Cash ISA Terms, you give your consent for Plum to segregate your money in a QMMF as they see fit.

5. Fees and Taxes

6. 1. We reserve the right to deduct any monies from your Plum Cash ISA or your Plum Wallet to satisfy your obligation to pay us any amount under these Cash ISA Terms. All fees you may have to pay to us are listed on the Plum Website, Fees.
   2. Plum may, at any time and without prior notice to you, set off any liability of yours to us under these Cash ISA Terms against any liability of ours to you under these Cash ISA Terms, whether either liability is present or future, liquidated or unliquidated. If the liabilities to be set off are expressed in different currencies, we may convert either liability at a market rate of exchange for the purpose of set off.

6. Closing your Plum Cash ISA

7. 1. Subject to paragraph 6.6 below, you may end this agreement and close your Plum Cash ISA at any time.
   2. You agree that you will continue to be responsible for all obligations related to your Cash ISA even after it is closed.
   3. We may end this agreement and close your Cash ISA or any service associated with it by giving you reasonable prior notice, unless we are required by law or other event to act sooner. You may be offered to transfer to an alternative ISA manager of your choice or on the closure date, all remaining cash you hold through Plum will be deposited in your Plum Wallet, unless we are required by law to freeze your Plum Account.
   4. We may suspend, freeze, or close your Plum Cash ISA without notice in certain circumstances. We will lift the suspension and/or restriction as soon as practicable after the reasons for the suspension and/or restriction have ceased to exist.
   5. We may at any time suspend or close your Cash ISA and/or end this agreement without notice if:
   6. 1. notifying you would be unlawful or compromise our reasonable security measures;
      2. you breach any provision of this agreement or documents referred to in this agreement;
      3. we are requested or directed to do so by any competent court of law, government authority, public agency, law enforcement agency or the FCA;
      4. we have reason to believe you are in breach of any applicable law or regulation; or
      5. we have reason to believe you are involved in any fraudulent activity, money laundering, terrorism financing or other criminal or illegal activity;
      6. allowing you to contribute or transfer in would breach legislation or HMRC and/or FCA rules; or
      7. the details you provided, including the declarations you accepted in opening your Plum Account or Cash ISA are incorrect and, had your application been correct, we would not have accepted your application for a Cash ISA.
   6. We may without prior notice or delay terminate this Cash ISA agreement immediately, if we are exposed to action or censure from any law enforcement actions by governments or regulatory bodies by providing you with the Cash ISA or Cash ISA Service
   7. If you are not happy with your choice of account within 14 days of making your first deposit, you can close your account and you will not lose your right to invest in another Cash ISA for that tax year. If you would like to take advantage of this 14 day rule, you must contact Plum Customer Service. When you close your account, we will make sure our reports to HM Revenue & Customs reflect the correct position. If you do cancel your account, the full amount of your investment, excluding any interest earned, will be returned to you.

7. Complaints

8. 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

8. Protections

9. 1. Any cash that may be held within the Cash ISA with our banking partner(s) is protected by the Financial Services Compensation Scheme (FSCS) up to a total of £85,000. This total includes all cash deposits you may have with our banking partner(s), not just the balance through Plum. If anything happens to Plum, your cash deposit within the Cash ISA is still safely held with our banking partner(s) up to the £85,000 limit.
   2. Pursuant to clause 4.7, Plum reserves the right to segregate client money in QMMF. A QMMF is a low-risk financial asset, aiming to invest in short-term investments, such as government bonds. Any QMMF we choose is subject to strict regulatory requirements to enable it to be considered a cash equivalent. Your cash, if invested in a QMMF, will be protected under the FCA’s client asset custody rules, meaning if Plum or the (Q)MMF Provider or the custodian were to become insolvent, all your funds would be returned to you. For the avoidance of doubt, FSCS does not cover changes in the overall value of your Cash ISA due to market conditions, such as changes in the interest rate.

9. Communications

10. 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 Cash ISA 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.

10. Instructions given via WithPlum

11. 1. When you use and interact with WithPlum to select and/or make changes to your Cash ISA and the Cash ISA Services such use and interaction will constitute your instructions to us.
    2. These Cash ISA Terms set out our obligations and duties with respect to instructions in relation to our Cash ISA and the Cash ISA Services. You acknowledge and agree that all instructions and authorisations given by you in relation to our Cash ISA and the Cash ISA Services 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. 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.

SCHEDULE 1

GLOSSARY

Interest Pockets Terms

These Interest Pockets Terms

1. These Interest Pockets Terms impose additional obligations that will apply to you where you receive one or more Interest Pockets (as defined below).
2. By accepting these terms and conditions, you allow us to act as your trustee and send your money to the Interest Account provider, in accordance with (a) these Interest Pockets Terms; (b) our General Terms & Conditions; and (c) any other terms or deeds that apply to you including the terms set by the Interest Account provider.
3. Where there is any conflict or inconsistency between: (a) these Interest Pockets Terms; (b) our General Terms & Conditions; and (c) any other terms or deeds that apply to you, these Interest Pockets Terms shall prevail.

4. The Interest Pockets

5. We may, at our discretion, offer the following services to you:
6. 1. A deposit account ("Easy Access Account") service where you can place and withdraw your funds within one working day (the "Easy Access Interest Pockets");
   2. A 32-day notice deposit account ("32-day Account") service (the "32-Day Interest Pockets"); and
   3. A 95-day notice deposit account ("95-day Account") service (the "95-Day Interest Pockets"), (each a Interest Pocket and together the Interest Pockets).
6. The Interest Pocket is provided by our Interest Account provider, but offered via the Plum App. The Interest Pocket is provided by the Interest Account provider subject to and in accordance with the Interest Account provider terms, over which we have no control.
7. You may only receive the Interest Pockets if you are UK domiciled. If you cease to be a UK resident at any point, then you must inform us immediately.
8. If you are unsure whether the interest you accrue could be subject to tax, you should contact His Majesty’s Revenue and Customs (HMRC) or seek professional tax advice. Any interest accrued from your Interest Pocket(s) may be subject to these or other taxes.
9. The maximum value that may be funded across the Interest Pockets is £85,000.

10. Account Opening and Closing

11. In order to open or close an Interest Pocket you must follow the instructions and meet the criteria set out on the Plum App. We are required by law to carry out steps prior to the opening of an account. In the majority of cases this will be done almost instantly, but in some cases this may take a short time. We will notify you when your Application to open or close an Interest Pocket has been successful.
12. When you open an Interest Pocket you may use the Plum App to direct the E-Money Provider to transfer funds from your Plum Wallet into the Interest Pocket.
13. When you withdraw money from an Interest Pocket (including when you close an Interest Pocket) your funds will be transferred into your Plum Wallet.

14. Notice

15. Where you wish to withdraw funds from your Interest Pocket, you are required to give notice to withdraw. You must request this via the instructions available in the Plum App. The applicable Notice Period will correspond to the name of the account and will be outlined in the Terms provided at the time of signing up to the service.
16. During the Notice Period you will not be able to instruct any action on your Interest pocket until the Notice Period has elapsed, at which time the funds will be allocated to your Plum Wallet in accordance with clause 11.
17. It may take up to 24 hours or longer for a withdrawal to be processed following the completion of the Notice Period, subject to the operational processes of the Interest Account provider. This is out of our control.

18. Cancellation

19. You have 14 calendar days within which to cancel a Interest Pockets, beginning on the date on which we notify you that the relevant Interest Pocket(s) is opened. After this time, the full notice must be served on any funds deposited in accordance with clause 12 of these Interest Pocket Terms.

20. Interest

21. Interest or profit is paid by the Interest Account provider, and is only accrued during the term of the Interest Pocket. For new Interest Pockets, interest or profit is accrued from the time the Interest Account provider receives your funds, not during the transfer process. Similarly, once funds are matured or Interest Pockets have been closed they stop being interest or profit bearing. During the transfer of funds to and from your Plum Wallet, no interest or profit is accrued. We do not have access to the funds in your Interest Pocket at any time. We do not profit from the time it takes for your funds to transfer to or from the Interest Account provider to your Plum Wallet.
22. The Interest is calculated daily on the cleared balance in the account using the interest rate applicable on that day and is paid into the Interest Pocket monthly.
23. The interest rate is a managed rate and will be agreed prior to account opening. The interest rate is subject to change at the discretion of the Interest Account provider, over which we have no control. Should a change occur, you will be informed at the earliest opportunity.

24. Pooled Trust Account

25. Each Interest Pocket is a ledger that records your beneficial interest in a Pooled Trust Account. A Pooled Trust Account is an account held at the Interest Account provider in our name that contains money beneficially owned by you and a number of our other customers. We will hold each Pooled Trust Account for you and our other customers in proportion to your interests as recorded in the ledger. We do not exercise any discretion in relation to your Interest Pocket or the Pooled Trust Account.

26. Compensation

27. The Interest Account provider is covered by the Financial Services Compensation Scheme ("FSCS"). This means that the FSCS may pay compensation to you, up to the current FSCS compensation limit (£85,000), if the Interest Account provider is unable to meet its financial obligations.
28. The current FSCS limit relates to the combined amount in all of your accounts with the Interest Account provider, which may include both your Interest Pockets and any other account that you hold with the Interest Account provider either directly or indirectly, including your share of any joint account held at the Interest Account provider.
29. For further information about the compensation provided by the FSCS (including the amounts covered and eligibility to claim) please contact us in accordance with clause 16.3 of the General Terms & Conditions, or refer to the FSCS website www.FSCS.org.uk. Please note only compensation related queries should be directed to the FSCS.

30. Queries and Complaints

31. If you have any questions or complaints regarding the Interest Pocket, please direct these to us in accordance with our normal complaints process (which is set out in clause 15 of the General Terms & Conditions) or through the Plum App messenger. Do not send questions or complaints directly to the Interest Account provider. We may share details of any query or complaint that you send to us with the Interest Account provider if we, in our absolute discretion, consider it necessary or desirable in order to respond to your question or complaint.

32. Liability

33. The Interest Pocket is provided by the Interest Account provider subject to and in accordance with the Interest Account provider Terms. The Interest Account provider is an independent third party over which we have no control. We do not endorse or recommend the Interest Account provider or any of the Interest Pockets. Your use of the Interest Pocket is at your own risk.
34. The Interest Pocket provided on an "as is" and "as available" basis. We expressly disclaim all warranties of any kind as to the Interest Pocket and all information, products and other content (including that of the Interest Account provider and other third parties) included in or accessible from the Interest Pocket, whether express or implied, including, but not limited to the implied warranties of merchantability, fitness for a particular purpose and non-infringement.
35. You agree that neither us nor any of our affiliates will be responsible or liable for any loss resulting from: (i) the use or the inability to use the Interest Pocket; (ii) the cost of getting substitute services, (iii) any products, data, or services obtained through or from the Interest Pocket; (iv) unauthorised access to the Interest Pocket; (v) conduct of the Interest Account provider or any other third party; or (vi) any other matter relating to the Interest Pocket.
36. You agree to indemnify us from any and all third party claims, liability, damages, expenses and costs (including, but not limited to, reasonable legal fees) caused by or arising from your use of the Interest Pocket, your breach of these Interest Pocket Terms (insofar as they relate to the Interest Pockets) or your infringement, or infringement by any other user of your Interest Pocket, of any intellectual property or other right of anyone. You agree that the Interest Account provider is a third-party beneficiary of the above provisions, with all rights to enforce such provisions as if the Interest Account provider were a party to these Interest Pockets Terms.

37. Termination

38. Each Interest Pocket may be terminated subject to and in accordance with the Interest Account provider Terms. Withdrawals are subject to the Notice terms at clauses 11 and 12 of these Saving Terms.

39. Definitions and Interpretation

40. The following terms used in these Interest Pockets Terms shall have the following meanings:
    "Interest Account provider" means Investec Bank plc of 30 Gresham Street, EC2V 7QP, United Kingdom.
    "Pooled Trust Account" has the meaning set out in clause 19 of these Interest Pocket Terms.
    "Notice Period" means the time that must elapse before funds may be withdrawn from a Interest Pocket. This period will be set out prior to account opening, and will be either 32 days (32-day Account) or 95 Days (95-day Account). An Easy Access account does not have a Notice Period, but is still subject to clauses 12-14 of these Interest Pocket Terms.
    "Interest Pocket" means an Easy Access Account, a 32-day Account or a 95-day Account provided by the Interest Account provider and offered via the Plum site or Plum App.
    "Interest Pocket" has the meaning set out in clause 4 of these Interest Pocket Terms.
41. Capitalised terms used herein and not otherwise defined shall have the meanings ascribed to them in the General Terms & Conditions.

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

• Part A – GIA and ISA Product Provider Terms

• Part B – Additional ISA 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

2. 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

3. 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

4. 1. We will provide services (the "Investment Services") that integrate with your Plum Account including the following:
   2. 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

5. 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

6. 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

7. 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
   4. 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

8. 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

9. 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").
   2. 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

10. 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

11. 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

12. 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

13. 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:
    3. 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

14. 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

15. 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

16. 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

17. 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

18. 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

19. 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:
    5. 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

20. 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:
    2. 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

21. 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

22. 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:
    5. 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

2. 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)

3. 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)

4. 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

5. 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:
   8. 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

6. 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:
   4. 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:
   7. 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:
   8. 1. your Funds, starting with the largest holding by value; and then
      2. any other investment.
   8. We may sell slightly more of your investments than is needed due to:
   9. 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

7. 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:
   8. 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

8. 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:
      A Transfer Out in specie will be subject to the prevailing Transfer Out charges outlined in the relevant GIA/ISA fees schedule.
   2. • • Transfers between cash ISAs should take no longer than 15 working days.
   2. • • Other types of transfers should be completed within 30 calendar days.
   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

9. 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:
   4. 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

10. 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

11. 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

12. 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

13. 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

14. 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

2. 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:
   9. 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:
      3. 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:
       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. • The completion of the administration of your estate;
       • The closure of the account by your executors;
       • The third anniversary of your death.
   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

2. 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?

3. 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

4. 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:
   2. 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

5. 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:
   2. 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

6. 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.
   3. 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

7. 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

8. 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

2. 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

3. 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

4. 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

5. 1. The factors (the "Execution Factors"that we have to take into account when placing Orders on your behalf will include:
   2. 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:
   3. 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

6. 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

7. 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

8. 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

9. 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

2. 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

   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.
3. 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.

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

• Part B – 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

2. 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

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

3. Our Investment Services

4. 1. We will provide services (the "Investment Services") that integrate with your Plum Account including the following:
   2. 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

5. 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

6. 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

7. 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
   4. 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

8. 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

9. 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").
   2. 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

10. 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

11. 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

12. 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

13. 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:
    3. 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

14. 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

15. 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

16. 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

17. 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

18. 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

19. 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:
    5. 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

20. 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:
    2. 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

21. 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

22. 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:
    5. 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

2. 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

3. 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

4. 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;
   4. 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

5. 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:
   7. 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

6. 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:
   4. 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:
   9. 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:
   10. 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:
   11. 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

7. 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:
   8. 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

8. 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

9. 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:
   2. 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

10. 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:
    4. 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

11. 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

12. 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

13. 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

14. 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

15. 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

2. 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?

3. 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

4. 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:
   2. 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

5. 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:
   2. 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

6. 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.
   3. 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:

• The price of the investment;
• The costs associated with the transaction;
• The likely speed of getting the transaction done;
• The likelihood of execution and settlement;
• The size and nature of the order; and
• Any other consideration relevant to the execution of an order.

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

• The fact that Quai have classified you as a “Retail Client”;
• The characteristics of the particular order, and the characteristics of the investment that is subject to that order; and
• The characteristics of the execution venues on or with which the order can be placed.

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:

• Ensure that orders executed on your behalf are promptly and accurately recorded and allocated;
• Carry out otherwise comparable client orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable, or the interest of the client requires otherwise.
• Inform you about any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty.

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

2. 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

   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.
3. 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.

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:

• To provide you with any services and/or information you request from us. This also includes carrying out any obligations specified in any contract(s) between us
• To comply with our legal and regulatory obligations, co-operate with the court service, our regulators and law enforcement agencies and to prevent and detect crime.
• If we learn of your insolvency or bankruptcy (or any insolvency proceedings), we’ll transfer your details to the Official Receiver or appointed insolvency practitioner(s).
• To check instructions you’ve given us or to resolve disputes including to establish, exercise or defend our legal rights.
• To confirm your identity and address, this includes using automated decisions when we carry out financial crime checks.

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:

• Your right of access – you have the right to ask us for copies of your personal information.
• Your right to rectification – you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – you have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing – you have the right to as us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – you have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability – you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

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

Stock Investing Terms & Conditions

Introduction

This agreement (the Order Handling Services Terms) is between you, the client (Client, you, your) and Saveable Limited, a company registered in England and Wales under company number 09777255 and registered at Floor 2, 2-7 Clerkenwell Green, EC1R 0DE, London (Plum, we, us, our). These Order Handling Services Terms relate to the provision of certain order handling Services by Plum to you in the Securities (the Order Handling Services) via the Plum mobile application (the Plum App).

These Order Handling Services Terms act as an addendum to the Plum General Terms and Conditions that are in place between you and us. You are entering into this agreement because you wish to receive the Order Handling Services and any rights or obligation which you may have or be subject to under these Order Handling Services Terms are in addition to the rights and obligations arising under the Plum General Terms and Conditions to which you are a party. The Plum General Terms and Conditions will continue to apply to you when accessing and using the Order Handling Services. To the extent that any conflicts arise between the provisions of these Order Handling Services Terms and the Plum General Terms and Conditions in relation to the Order Handling Services, these Order Handling Services Terms will prevail.

Throughout this agreement, we use certain capitalised terms. A full list of these capitalised terms can be found in the Schedule to these Order Handling Services Terms.

These Order Handling Services Terms contain important information that you need to read carefully. Before confirming your agreement to these Order Handling Services Terms and opening a Stock Investing Account, you should carefully read our Risk Warning Notice (which can be found here) and our Order Execution Policy (which can be found here), each of which shall apply to Orders and Transactions made under these Order Handling Services. If you have any questions or doubts about any of the content in these Order Handling Services Terms, you should seek appropriate professional advice before opening your Stock Investing Account.

We may update these Order Handling Services Terms in accordance with any amendment provisions in force from time to time between you and us under the Plum General Terms and Conditions.

About us

Plum Money is a trading name of Saveable Limited, an entity authorised and regulated by the Financial Conduct Authority (FCA) with firm reference number 739214. The FCA’s registered address is 12 Endeavour Square, London, E20 1JN. We can be contacted at help@withplum.com.

Where you wish to trade Securities as part of the Order Handling Services, your Orders will be executed by the Third Party Broker, meaning you will need to open a separate account directly with the Third Party Broker which will be governed by terms and conditions of the Third Party Broker (the TPB Terms). Information on the Third Party Brokers’ regulatory status is detailed in the TPB Terms. If you do not agree to the TPB Terms, then you may not be able to submit Orders in relation to Securities. The TPB Terms are a matter between you and the Third Party Broker and we do not have any rights or obligations under such TPB Terms.

1. The Order Handling Services and our relationship

2. 1. Plum will provide the Order Handling Services subject at all times to the provisions of these Order Handling Services Terms. These Order Handling Services Terms will govern all Orders and Transactions entered into by you under the Order Handling Services. You acknowledge that the TBP Terms may also apply to you where you wish to trade in Securities and you should read the TBP Terms carefully before agreeing to enter into such TBP Terms.
   2. Access to the Order Handling Services is provided to you at Plum’s sole discretion. Plum may add, modify or discontinue any feature, functionality or any other tool within the Order Handling Services at its own discretion and without further notice to you.
   3. Plum will exercise all due skill, care and diligence in the performance of the Order Handling Services and it shall owe no other duties to you other than those duties to perform the Order Handling Services in accordance with this Clause 1.3. Plum shall be responsible for the performance of the Order Handling Services as expressly set forth in these Order Handling Services Terms and shall have no implied duties or obligations whatsoever.
   4. The Order Handling Services are provided in relation to the Securities only. You acknowledge and agree that Plum determines which Securities are available with respect to the Order Handling Services via the Plum App in its sole discretion and that it may add or remove Securities at any time and without prior notice to you.
   5. You acknowledge and agree that you will enter into any Transactions as principal and not as agent for any undisclosed person. Unless we have agreed otherwise, you will be solely responsible for performing any obligations under these Order Handling Services Terms in connection with Transactions entered into as part of the Order Handling Services.
   6. The Order Handling Services will be provided on a non-advised basis, meaning that we will not provide you with any advice as to the merits of any particular Security or Transaction or whether a particular Security or Transaction is suitable for you. We will not provide you with any investment, legal, tax or other form of advice, nor can you request any such advice from us. You are solely responsible for any decisions taken in respect of any and all Transactions that you choose to enter or not enter into.
   7. We will treat you as a Retail Client in relation to the Order Handling Services unless we have informed you otherwise in writing, including following a request made by you in connection with other services provided by us that are not addressed by these Order Handling Services Terms. You may request a different client categorisation to the one we have given you and, if you do so, we will need to contact you to discuss what further information we may require and what additional requirements may apply in this context. Please be aware that we may reject any request made by you to change your client categorisation.
   8. We may be required to obtain certain information from you such that we can comply with our obligations under applicable law and regulation and you agree to provide any such information that we may reasonably request in the format within which we request it. This includes, but is not limited to, any information we need to verify your identity, any information we require for purposes of reporting Transactions, and any information as to your knowledge and experience in relation to Securities that we may need to gather to assess whether or not such Securities, and the Order Handling Services generally, are appropriate for you. You may be denied access to the Order Handling Services until such time as we can obtain sufficient information from you to satisfy our obligations under applicable law and regulation.
   9. Information relating to how to make a complaint in relation to the Order Handling Services and information relating to your rights to claim compensation can be found in the Plum General Terms and Conditions.
2. Stock Investing Account
3. 1. The Plum General Terms and Conditions relating to account opening shall apply to any application made by you to open a Stock Investing Account and shall be supplemented by the provisions detailed in this Clause 2.
   2. In order to receive the Fee you must ensure that you have the Plum App and that you have opened a Stock Investing Account with us. Further information relating to how to open accounts with us is provided in the Plum General Terms and Conditions and via our Website. When you open a Stock Investing Account, you will be deemed to confirm that the representations and warranties contained in the Plum General Terms and Conditions are true and accurate, and each time you submit an Order you will be deemed to confirm that such representations and warranties remain true and accurate. It is a condition of opening a Stock Investing Account that you agree to these Order Handling Services Terms and that you agree to comply with your obligations under these Order Handling Services Terms.
   3. When opening your Stock Investing Account, we may utilise the services of third-party service providers to verify your identity and you agree that we may share your personal data with such providers for this specific purpose.
   4. You acknowledge and agree that Plum retains sole discretion as to whether to accept any request made by you to open a Stock Investing Account and just because you currently receive other services from Plum does not guarantee that you will be able to open a Stock Investing Account with us.
   5. Stock Investing Account.
   6. Unless you have notified us of a lost or stolen device in accordance with the provisions in the Plum General Terms and Conditions, we are entitled to treat any Orders made via the Plum App as legitimate and rely on those Orders and you shall remain solely liable for any Orders and any Transactions that arise as a result.
3. Orders and Transactions
4. 1. In order to enter into a Transaction, you must submit an Order to us in accordance with this Clause 3 of these Order Handling Services Terms.
   2. An Order may only be made via the Plum App by completing the relevant information required to create such Order. Any Order is binding on you and you bear sole responsibility for any obligations arising out of or in connection with any Orders or Transactions. We retain sole discretion as to whether to accept or otherwise transmit any Order. Our acceptance of your Order will be evidenced through a confirmation in the Plum App. Where your Order relates to Securities, the Third Party Broker shall retain sole discretion as to whether to execute that Order. Under normal market conditions a market order would generally be fully executed. Partial order execution may occur in the event there are not enough Securities to fill your order or due to unexpected technical reasons in which case the unexecuted part of your order will be cancelled. You acknowledge and agree that we are reliant on various third-parties to facilitate the execution of your Orders and we cannot, therefore, guarantee that your Orders will be executed, nor can we guarantee that there will not be a delay in the execution of your Order. The price of any Security to which your Order relates may move between our acceptance of the Order and its ultimate execution and you acknowledge that such price movements may work in your favour or against you. Where we do not accept your Order, we will use reasonable endeavours to provide you with a reason why, save where the provision of such information to you would be prohibited by applicable law or regulation.
   3. We reserve the right to cancel an Order previously accepted where we reasonably believe that:
   4. • (a) the Order was not made in accordance with these Order Handling Services Terms;
      • (b) the Order breaches or may reasonably breach a Risk Control;
      • (c) you no longer have sufficient funds in your Plum Wallet to cover any financial obligations that may arise in connection with the Order;
      • (d) we reasonably believe that the Order has not originated from you;
      • (e) the Order is suspicious in nature and we wish to clarify it with you;
      • (f) we may be in breach of these Order Handling Services Terms or applicable law or regulation if we continue to accept the Order; or
      • (g) any other circumstances arise following acceptance of the Order but prior to it becoming a Transaction that mean it is no longer reasonable or possible for us to act on the Order, including, but not limited to:
      • • (i) the Order is suspicious in nature and we wish to clarify it with you;
        • (ii) a Force Majeure Event has occurred;
        • (iii) the relevant issuer of the Security becomes subject to an Insolvency Event;
        • (iv) trading in the relevant Security has been suspended by any relevant underlying market or exchange;
        • (v) we or the Third Party Broker no longer supports the Security to which the Order relates; or
        • (vi) we are required by any underlying market or exchange or by the Third Party Broker to cancel the Order.
   4. Save where prohibited under applicable law or regulation, we will use reasonable endeavours to provide you with a reason as to why we have cancelled any Order submitted by you.
   5. We will determine in our sole discretion what Orders are made available. At present, the only form of Order that can be made is a Market Order. We may notify you from time to time of any changes to the types of Orders that are available. Orders can only be made in relation to Securities and we will not facilitate any Orders that do not relate to Securities.
   6. We determine, in our sole discretion, what Securities are made available via the Plum App and we may change such Securities at any time without notice to you. If we no longer wish to support a Security in which you have a Position, you may be required to close that Position and, in such circumstances, we will provide you with advance notice in writing of the relevant date by which you must close that Position. If you have not closed that Position by the relevant date specified in such notice, we will close that Position at the prevailing market price of that particular Security.
   7. By default, all Orders will be treated as Manual Orders unless you have indicated that you wish for that Order to be an Automated Order.. Any Automated Orders will be executed on the predefined date selected for the transfer of relevant funds to the Stock Investing Account.
   8. As may be applicable, where you submit an Order outside Trading Hours, that Order will be held until the commencement of the next period of Trading Hours and subsequently actioned during that period. In such circumstances, you may not be notified of the relevant price of any Securities to which that Order relates until that Order becomes a Transaction. The minimum value for Automated Orders is GBP 1.00. If the value available in the Plum Wallet to facilitate an Automated Order is less than this amount, then the Automated Order will not be created.We will notify you via the Plum App in the event that any of your Automated Orders cannot be created due to insufficient funds.
   9. When your close a Position by submitting an Order to sell a Security, the Third Party Broker will credit any proceeds from that Transaction to your Stock Investing Account minus any fees or charges due and payable to us, but we will place a restriction on your ability to withdraw those funds from your Stock Investing Account until such time as the Transaction settles.
   10. When you submit an Order to buy a Security we may agree to lend you the money to fund your buy Order by using an equal amount of funds from an executed sell Order(s) pending settlement. At any time, you will not be able to borrow money that exceeds the funds from executed but not yet settled sell Order(s). The availability payment of the arrangements set out in this Clause 3.10 is determined in ouris at our sole discretion and we may choose to refuse to offer this payment model at any time and for any reason (which we will not have to explain to you), but we will notify you if this payment model is not available to you. You acknowledge and agree that if you borrow funds from us under this Clause 3.10 you will owe us a debt equal to the value of the funds borrowed and you will repay this amount to us as soon as any executed sell Order(s) settles and you agree that we may deduct the value of any borrowed funds from the proceeds of your settled sell Order(s) when we credit such proceeds to your Plum Wallet.
   11. We will not aggregate your Orders will those received from our other clients However, the Third Party Broker may, when it considers it necessary and in their customers’ best interests, aggregate (i.e. combine together) multiple orders. In certain circumstances, the aggregation of Orders may result in you obtaining a less favourable price on resulting Transactions. Because your investment may be bought or sold alongside the shares of other customers, the price obtained may not be the same as if it had been an individual order. You acknowledge and agree that we shall not have any liability to you as a result of you obtaining a less favourable price because of the aggregation of Orders by the Third Party Broker.
   12. We will take all sufficient steps to provide you with best execution in relation to Orders and such Orders will be handled and executed in accordance with our Order Execution Policy. For Orders relating to Securities, you acknowledge that the Third Party Broker may not be subject to best execution requirements in the same manner as we are and it shall execute Orders in Securities in accordance with its obligations of the applicable law and regulation of the jurisdiction in which it is established.
   13. By agreeing to these Order Handling Services Terms, you expressly agree that we may execute your Orders outside a regulated market or multilateral trading facility.
   14. We shall have no liability to you for the actions or omissions of the Third Party Broker in relation to any Orders, Transactions or Positions relating to Securities.
4. Risk Controls and Limits
5. 1. You acknowledge and agree that any Orders or Transactions submitted under or created by the use of the Order Handling Service may be subject to risk limits, risk tolerances and credit limits imposed by Plum from time to time (the Risk Controls). The Risk Controls may be general or specific to you, may apply to all Securities or only certain Securities, and at all times are imposed, amended, maintained or removed at the sole discretion of Plum without prior notice to you.
   2. Plum may reject, cancel or amend any Order that, in its sole discretion, breaches or may breach a Risk Control. Plum shall have no liability to you for any losses or damages incurred by you in connection with any Orders which are rejected, cancelled or amended by us in circumstances where such Orders breach or are reasonably likely to breach a Risk Control.
   3. You acknowledge that the Third Party Broker may impose its own risk limits and controls with respect to Orders and Transactions in relation to Securities and that Plum has no control or influence over any such limits and controls.
5. Your Obligations
6. 1. As a condition of receiving the Order Handling Services, you shall:
   2. • (a) exercise all due care, skill and diligence in your use of the Order Handling Services;
      • (b) ensure that your comply with all applicable law and regulation in connection with your access to and use of the Order Handling Services and in particular, but without limitation, not: (i) engage in any practice that is considered to be market abuse, (ii) use your Stock Investing Account or act with any attempt to launder money or avoid applicable sanctions against any person, company or country, or (iii) provide any false or otherwise misleading information in relation to your identity or personal circumstances that we request in order to provide you with a Stock Investing Account;
      • (c) not use any automated trading arrangements, algorithms or other software in connection with your access to and use of the Order Handling Services;
      • (d) provide all such documentation or information as may be reasonably required by Plum to ensure its compliance with applicable law and regulation;
      • (e) ensure that you regularly access the Plum App to monitor your Positions;
      • (f) inform Plum immediately if you become subject to any investigation, proceedings or actions undertaken by any regulatory or governmental authority;
      • (f) inform Plum immediately if you become a Sanctioned Person or if you are or become located, organised or resident in, or begin to conduct business in or with, any country or territory with which Order Handling Services are broadly restricted or prohibited by Sanctions; and
      • (f) not use the Order Handling Services to provide services or activities to your own clients, counterparties or customers.
6. Your Money
7. 1. Plum will not hold any money from or for you. Any money received in connection with our provision of the Order Handling Services is held by Modulr FS Limited (Modulr FS). Modulr FS will be responsible for safeguarding your money in accordance with applicable law of the jurisdiction in which Modulr FS is established and the relevant terms and conditions agreed between you and Modulr FS.
   2. We will not be liable to you for the acts, omissions or insolvency of Modulr FS or any third party banking institution which holds your money in accordance with this Clause 6, provided that we have exercised due skill, care and diligence in the selection of Modulr FS.
7. Your Positions
8. 1. Plum does not hold any Securities in connection to the Order Handling Services on your behalf. Securities are held by the Third Party Broker in accordance with applicable law of the jurisdiction in which the Third Party Broker is established and the TPB Terms agreed between and Third Party Broker. We will not be liable to you for the acts, omissions or insolvency of the Third Party Broker or any sub-custodian appointed in accordance with this Clause 7, provided that we have exercised due skill, care and diligence in the selection of such Third Party Broker.
8. Fees and Taxes
9. 1. You have sole responsibility for making any payments that are due and payable under these Order Handling Services Terms. When you submit an Order to buy a Security, the amount you are required to pay in connection with that Order will become due and payable once that Order becomes a Transaction. It is your responsibility to ensure that there are sufficient funds on your Stock Investing Account to cover the value of your Transactions, including the payment of any fees due and payable to us in connection with those Transactions. The amount of fees that are due and payable to us in connection with Transactions are detailed on the Plum App and the Plum Website. You should familiarise yourself with such information before submitting any Orders.
   2. You acknowledge and agree that the Third Party Broker may charge you additional fees in relation to Transactions in Securities and that Plum has no control or influence over such fees or the terms governing the payment of such fees. You have a direct obligation to the Third Party Broker to pay such fees in accordance with the requirements imposed by the Third Party Broker under the TPB Terms.
   3. All amounts due and payable under these Order Handling Services shall be made in the Base Currency. Where a particular Transaction relates to a Security denominated in a currency other than the Base Currency, we will perform a currency conversion at the relevant prevailing exchange rate so as to facilitate the settlement of that Transaction. Similarly, where proceeds of any Transaction are in a currency other than the Base Currency, we will convert these proceeds into the Base Currency for the purposes of crediting such proceeds to your Stock Investing Account. You acknowledge and agree that, where you enter into Transactions relating to Securities which are not denominated in the Base Currency, you are exposing yourself to currency risk and you acknowledge and agree that it is your sole responsibility to manage this risk and that we are not liable to you for any losses arising in connection with such risk.
   4. We reserve the right to deduct any monies from your Stock Investing Account to satisfy your obligation to pay us any amount under these Order Handling Services Terms.
   5. If at any time in relation to the Order Handling Services we owe you and you owe us the same amount of money in the same currency, then each of our respective obligations to pay such monies to the other will be automatically satisfied and discharged. In the event that each of us owes one another different amounts of money in the same currency, then whichever of us owes more may pay the excess to the other and each of our respective obligations to pay such monies to the other will be satisfied and discharged.
   6. Plum may, at any time and without prior notice to you, set off any liability of yours to us under these Order Handling Services Terms against any liability of ours to you under these Order Handling Services Terms, whether either liability is present or future, liquidated or unliquidated. If the liabilities to be set off are expressed in different currencies, we may convert either liability at a market rate of exchange for the purpose of set off.
   7. You have sole responsibility for determining whether and to what extent any taxes or tax reporting obligations may apply in connection with your Transactions and your Positions. Plum shall have no responsibility for facilitating or otherwise making any payments of tax for or on your behalf and we provide no warranty or representation as to your tax position or the tax treatment of any Transactions. You must inform us of any changes to your tax status during the duration of these Order Handling Services Terms.
   8. Where you wish to deal in Securities, you may be required, either by us or the Third Party Broker, to complete certain US tax documentation prior to submitting any Orders in relation to Securities.
9. Market Data
10. 1. Plum may make available to you certain market data or other information in relation to the Securities (the Market Data). Any decision to make available Market Data is made in Plum’s sole discretion. The relevant Market Data is provided by a third-party unaffiliated to Plum called IEX Cloud Services LLC. Further information on IEX Cloud Services LLC can be found here: https://iexcloud.io.
    2. The provision of Market Data does not form part of the Order Handling Services and Plum does not accept any responsibility for its accuracy or completeness, nor do we owe any obligations to you under these Order Handling Services Terms with respect to the provision of that Market Data.
    3. You acknowledge and agree that you do not acquire any intellectual property rights in the Market Data and that IEX Cloud Services LLC retains all such intellectual property rights.
    4. You will indemnify and hold Plum its affiliates and subsidiaries harmless against all Losses and all other reasonable professional costs and expenses suffered or incurred by Plum arising out of or in connection with any use of the Market Data which:
    5. • (a) involves use of the Market Data otherwise than in connection with the receipt of the Order Handling Services by you;
       • (b) violates, or encourages the violation of, the legal rights of others;
       • (c) results in the conducting, promotion or encouragement of illegal activity; or
       • (d) is unlawful, invasive, infringing, defamatory or fraudulent.
10. Corporate Actions
11. 1. Unless otherwise agreed between you and us, any dividends or other cash distributions that are paid on Securities held by us on your behalf will be credited to the Stock Investing Account less any applicable withholding tax. The Currency Conversion Fee will be applied on dividends or other relevant cash distributions. We will not be responsible for claiming back any withholding tax on your behalf and, as per Clause 8.7, you have sole responsibility for addressing any tax obligations that arise in connection with Transactions.
    2. We may, are not required to, inform you of any ordinary or extraordinary general meeting of any issuer of a Security you hold in your Positions. We may, but are not obliged to arrange for you to receive any information that receive in relation to an issuer of a Security.
    3. We may, but are not required to, inform you or otherwise arrange for the exercise of any voting rights that relate to any Securities that we hold on your behalf.
    4. If we are holding Securities on your behalf for which there is a rights issue, we will use reasonable endeavours to notify you of such an event. On notification, you can take up the option to receive the rights and have the opportunity to subscribe for new stocks, ignore the rights or sell the rights, if possible. In order to prevent renounceable rights from becoming worthless when they expire, if you have not provided us with any instructions by any deadlines specified by us to you, we may, but are not required to, sell the rights (if possible) on your behalf before the expiry of the rights. The proceeds from the sale of the rights will then be credited to your Stock Investing Account net of any applicable fees or charges.
    5. We are not required to notify you of any class actions or group litigation that are underway or proposed in relation to any Securities that we are holding, or have previously held, on your behalf which are notified to us from time to time, nor are we required to act on any such notifications.
11. Termination
12. 1. You or we may terminate your Stock Investing Account at any time and for any reason by you giving us notice, or we giving you notice. Notice of termination will not affect any responsibility for any obligations arising out of or in connection with these Order Handling Terms, including any Orders that have yet to be executed – we will continue to execute those in accordance with these Order Handling Services Terms (which may include refusal to execute Orders).

SCHEDULE 1

DEFINITIONS

"Automated Order" means an Order the parameters of which are pre-determined and which is automated submitted to us on a set date.

"Base Currency" means the currency listed as the currency of your Plum Wallet.

"Currency Conversion Fee" means the Fee applied when converting from the Base Currency into another supporting currency or vice versa, the value of which will be listed on the Plum Website from time to time.

"Stock Investing Account" means the account opened by you with Third Party Broker for purposes of your access to and use of the Order Handling Services.

"Order Handling Services" has the meaning given in the Introduction.

"Order Handling Terms" has the meaning given in the Introduction.

"Eligible Counterparty" has the meaning given in the FCA Rules

"FCA"has the meaning given in the About Us section.

"FCA Rules" means the rules of the FCA as documented in the FCA Handbook from time to time.

"Fees" means any fees, commissions or similarly payable to us under the Order Handling Services Terms in respect of the Order Handling Services, as these are listed on the Plum Website from time to time.

"Force Majeure Event" means acts of God, fire, flood, drought, earthquake or other natural disaster, epidemic or pandemic; terrorist attack, civil war, civil commotion or riots, war, threat of or preparation for war, armed conflict, imposition of Sanctions, embargo, or breaking off of diplomatic relations; nuclear, chemical or biological contamination or sonic boom; any law or any action taken by a regulatory or governmental authority, including without limitation imposing an export or import restriction, quota or prohibition; collapse of buildings, fire, explosion or accident; any labour or trade dispute, strikes, industrial action or lockouts (other than in each case by the party seeking to rely on this clause, or companies in the same group as that party); non-performance by suppliers or subcontractors (other than by companies in the same group as the party seeking to rely on this clause); and interruption or failure of utility service.

"Losses" means any liabilities, costs, expenses, damages and losses (including, but not limited to, any direct, indirect or consequential losses, loss of profits, goodwill, reputation, loss of business opportunity or anticipated savings, and all interest, penalties and legal costs (calculated on a full indemnity basis)).

"Market Data" has the meaning given in Clause 9.1.

"Manual Order" means an Order where you determine the relevant parameters via the Plum App.

"Market Order" means an instruction to us seeking the creation of a Transaction immediately at the best available price in relation to the Security in question.

"Order" means any instruction given by you to us under the Plum App in relation to a Security and includes a Market Order, a Manual Order and an Automated Order.

"Plum App" has the meaning given in the Introduction.

"Plum Wallet" means the electronic money wallet held with the E-Money Provider.

"Positions" means the Securities that the Third Party Broker hold on your behalf following the conclusion of a Transaction.

"Professional Client" has the meaning given in the FCA Rules.

"Retail Client" has the meaning given in the FCA Rules.

"Risk Control" has the meaning given under Clause 4.1.

"Sanctioned Person" The target of any Sanctions or located, organised or resident in a country or territory with which Order Handling Services are broadly restricted or prohibited by any Sanctions.

"Sanctions" any economic, financial or trade sanctions or embargoes, export controls or other restrictive measures imposed by the United States of America (including those administered by the United States Department of the Treasury’s Office of Foreign Assets Control), the European Union, any member state of the European Union, the United Kingdom (including those administered by HM Treasury) or the United Nations.

"Sanctioned Person" The target of any Sanctions or located, organised or resident in a country or territory with which Order Handling Services are broadly restricted or prohibited by any Sanctions.

"Securities" means the financial instruments made available via the Plum App which are capable of being subject to Orders.

"Third Party Broker" means Alpaca Securities LLC.

"TPB Terms" has the meaning given in the About Us section.

"Trading Hours" means regular trading hours for the stock markets as listed on the Plum Website from time to time.

"Transaction" means a transaction that arises following the execution of an Order.

"Website" means https://withplum.com/.

ORDER HANDLING AND BEST INTEREST POLICY

Introduction

Plum is committed to treating customers honestly, transparently and in the best interest of our customers.

This Order Handling and Best Interest Policy (“Policy”) provides information to customers of Plum (references to "Plum", "us", "our" and/or "we" means Saveable Limited) on when, where and how we will treat your orders when received and transmitted for execution.

Purpose

The purpose of this Policy is to set out Plum’s approach to meeting our customer best interest and order handling obligations by setting the methods by which we take all sufficient steps to obtain the best possible results when acting on their behalf.

This Policy sets out our execution model and our overarching approach to overseeing execution, including the execution factors considered. In addition, the Policy sets out the key risks to best execution and the governance relevant to the monitoring and oversight of this Policy.

Our Execution Model

1. US Stocks
2. Through the Plum App, Plum offers its customers execution access to US stocks listed on the New York Stock Exchange (“NYSE”) and the Nasdaq Stock Market (“NASDAQ”). Plum receives the order from the customer through the Plum App and transmits the order to our third-party broker for execution.
3. Plum utilises a third-party broker, Alpaca Securities LLC (“Alpaca”), a US broker dealer registered with the Securities and Exchange Commission (“SEC”), and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (”SIPC”). Alpaca has relationships with multiple third party brokers that it can access for the purpose of directing orders in securities to particular market centres for execution and as such has the capacity to achieve best execution.
4. Under no circumstances will we act in any other capacity and a transaction will arise between you and Alpaca.
5. Details on how the Alpaca executes its orders can be obtained in the Alpaca Customer Agreement , https://files.alpaca.markets/disclosures/library/AcctAppMarginAndCustAgmt.pdf.
6. Money Market Fund ("Plum Interest")
7. Through the Plum App, Plum offers its customers execution access to Money Market Fund (MMF) which is the BlackRock ICS Sterling Government Liquidity Fund (reference no. 632553) issued by BlackRock Investment Management (UK) Limited (reference no. 119293), authorised and regulated by the Financial Conduct Authority. The MMF is a segregated compartment established and maintained by the Institutional Cash Series.
8. Plum receives the order from the customer through the Plum App and transmits the order to the MMF Manager for execution. The MMF Manager is BlackRock Asset Management Ireland Limited which is responsible for the day-to-day management of the MMF, either directly or by way of delegation.
9. Details of the MMF Managers and the executing broker’s Execution and Order Placement Policy is available here.

Order Execution

We will not execute any orders (either stock or MMF) that you submit via the Plum App, but rather will transmit orders for stocks to our third party broker Alpaca for execution or onward transmission by Alpaca to market centres or other third party brokers, or for MMFs to the MMF Manager BlackRock.

Whilst we are not ultimately responsible for execution of orders, we do have an obligation to take all sufficient steps to obtain the best result for our customers in transmitting orders to our third party broker.

Our primary obligation is to ensure that our customers’ orders are received and transmitted to Alpaca and/or the MMF Manager promptly and fairly. Unless instructed otherwise by the customer or where prevailing market conditions prevent us from doing so, all orders will be transmitted to Alpaca and/or the MMF Manager sequentially and promptly in accordance with our order handling process.

Plum cannot guarantee that the best execution is achieved for each and every trade. Plum’s best execution approach is focused on achieving the best possible results on a consistent basis, and not merely best execution for an individual order.

Orders for execution in US-listed securities on NYSE or NASDAQ are transmitted to Alpaca. Orders for full shares of a security will be executed by Alpaca, as agent, through any of their third party execution brokers or venues they interact with. Orders for fractions of a security will be executed by Alpaca, as principal. Where your order includes both a whole share and fraction of a share, it will be executed in a mixed capacity by Alpaca. Alpaca has a system in place with regards to its fractional shares and listed securities arrangements that aims to ensure that its customers obtain best execution and/or benefits from price improvements.

In all cases, Alpaca commits to execute at the National Best Bid or Offer (“NBBO”) as of the time of your order, for all whole share and fractional share components of a transaction, in line with its best execution objective.

Orders for execution in MMF will take place directly with the MMF Manager.

Under normal market conditions you should expect a market order to be fully executed. Partial order execution may occur in the event there are not enough shares to fill your order or due to unexpected technical reasons in which case the unexecuted part of your stock order will be cancelled.

For stock orders we do not aggregate a customer's orders with those of any other customers. Although, Alpaca may, when it considers it necessary and in our customers’ best interests, aggregate (i.e. combine together) multiple orders. You should be aware that aggregating orders in this way may be to your disadvantage. Because your investment may be bought or sold alongside the shares of other customers, the price obtained may not be the same as if it had been an individual order.

For MMF orders we will be routinely aggregating all client buy orders and all client sell orders, respectively for submission before the cut-off time. The orders to the MMF Manager will be submitted in Plum’s name.

We will carry out transmission of orders as promptly as possible, or as otherwise set out in the relevant terms and conditions, unless the characteristics of the order or prevailing market conditions make this impracticable. In accordance with our processes we will inform customers about any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty.

Plum has various arrangements in place to review, monitor and oversee the standards of execution received by Alpaca or the MMF Manager and their counterparties.

Taking “Sufficient Steps”

In seeking the best possible result for the customers, Plum applies an order handling process that is structured around order initiation, order decision, execution to final settlement.

Plum takes all sufficient steps to achieve the best possible results for its customer by verifying that Plum’s order handling arrangements work well throughout the different stages of the order routing and execution by its selected third party broker and MMF Manager.

Taking all sufficient steps” includes order execution arrangements to ensure intended outcomes can be successfully achieved on an ongoing basis. It includes taking sufficient steps in overseeing that the third-party broker and the MMF Manager that Plum uses for onward routing has the necessary arrangements in place to allow Plum to comply with its Policy, taking into account the execution criteria and execution factors.

Plum has identified a three step process for designing and maintaining an infrastructure design to achieve best execution for its customers.

Design: The design process is an ongoing process involving the continual review of execution arrangements made by Plum to deliver the best possible outcome for its customers and making enhancing arrangements as necessary. Matters relating to the design process are discussed within Plum’s governance arrangements relevant to best execution.

Implementation: The approved execution arrangements are implemented using routing technology and execution partnerships with third-party brokers, MMF managers and direct execution venue connection, as may be relevant. The execution arrangements are then subject to an ongoing review process which is done by ongoing monitoring of execution performance.

Updating: Any issues arising from the ongoing review process and/or monitoring of market structure developments are escalated, discussed and reviewed within Plum’s governance arrangements relevant to best execution.

Our Consideration For Execution Quality

Best execution is the duty that Plum owes the customer to take all sufficient steps to obtain the best possible result when receiving and transmitting orders for execution on the customer's behalf. In doing this we take into consideration the following execution factors:

• price
• costs
• speed
• likelihood of execution and settlement
• size of the order
• nature of the order
• any other consideration relevant to the execution of the order when executing an order on behalf of the customer.

The execution factors are considered in light of the execution criteria by assessing their relative weighting in light of elements that could influence the outcome of the execution and therefore the outcome for the customer.

In determining importance given to execution factors Plum will take into account relevant execution criteria and market conditions including (but not limited to):

• characteristics of the order (order type);
• liquidity in the relevant stock
• size of customer order;
• the time needed for completing the execution;
• availability for price improvement; and
• Plums’s fee model and the potential impact on total consideration.

In assessing the execution factors and the weighting of the criteria it is considered that in most instances priority should be given to the execution factor ‘price’ and ‘cost’. In certain circumstances Plum may determine that the speed and likelihood of execution may take precedence over immediate price and cost factors if these other factors are instrumental in delivering the best possible result. This may be the case for example for large customer orders in illiquid shares.

Customer fees and commissions are pre-agreed as per Plum’s fee model. As such, customers are not directly exposed to additional costs during the order handling and execution process. Both ex-ante and ex-post costs are made available to customers, and incidental costs and charges to customers such as implicit transaction costs are made available to customers in confirms and statements, including incidental costs and charges to customers such as implicit transaction.

Monitoring and Oversight

Plum monitors on a regular basis the effectiveness and application of this Policy.

The monitoring of executions and oversight is focused on an overall assessment to determine if the best result was achieved in accordance with this Policy.

Plum will correct any deficiencies identified as part of its monitoring. Plum evaluates the trading execution quality obtained on a periodic ex-ante basis and considers alternative methods designed to improve the execution process.

Generally, Plum's monitoring process will focus on the outcomes that have been achieved for customers and whether these are overall consistently giving customers the best outcome they could have had, given the relevant assessment criteria.

In order to analyse and draw conclusions from monitoring of quality of execution obtained by Alpaca and the MMF Manager, Plum’s monitoring is focused on the overall execution process as well as including identifying executions where trade is executed outside the best bit or offer at the time of the trade or where delays have occurred during the execution process.

The review occurs within Plum's governance arrangements relevant to best execution and includes an overall assessment of whether the execution policies and the arrangements include all sufficient steps that Plum could be taking to achieve best execution of customers' orders.

Consent

Once we have transmitted your orders to Alpaca and/or the MMF Manager, we cannot control when and how the Alpaca and/or the MMF Manager will execute your orders. By opening a Stock Investing Account and/or a Plum MMF Investment Account you are deemed to consent to our Order Handling and Best Interests Policy.

RECURRING INVESTMENT TERMS

1. These Recurring Buy Transactions Terms & Conditions, along with our General Terms & Conditions, Stock Investing Terms & Conditions and any other documents we provide in relation to our services form a legal agreement between you and Plum.
2. These Recurring Buy Transactions Terms & Conditions will remain in effect after the initial Recurring Buy Transaction is executed in full and until you cancel your Recurring Buy Transaction using app settings in your Plum Stock Investing Account.
3. You can easily cancel any scheduled buy orders by tapping the Recurring Buy Order card on the instrument selection screen. This will open up the Order Details Screen. Here you can tap the red button that says “Cancel”.
4. By setting up a Recurring Buy Transaction, you authorise us to automatically create a Buy Order for you under the Stock Investing Terms & Conditions without any other consultation, consent or approval.
5. You can set up a Recurring Buy Transaction to purchase the company stocks you select, at regular intervals in the future, for the market price at the time your order is executed. Once you click “Confirm”, you authorise your Recurring Buy Transaction to repeat indefinitely and as such it’s important that you regularly review your recurring orders. Plum is not obliged to verify the information and details of the Recurring Buy Transactions provided by you, which shall be assumed accurate and complete.
6. Plum is not responsible for any losses incurred by you as a result of unauthorised, incorrect or failed transactions due to incomplete or outdated information (including having insufficient funds in your Plum Wallet to complete the transaction).
7. It is your responsibility to maintain an adequate balance and/or sufficient credit limits in order to avoid overdraft, non-sufficient funds, or fees charged by Plum.
8. Plum is not responsible for the delay caused (if any) in executing the Recurring Buy Transactions for any reason and/or for any merchant-initiated transactions.
9. Plum is unable to provide any guarantee relating to the performance of particular investments or strategy connected with Recurring Buy Transactions.
10. Plum reserves the right to refuse to process, cancel, terminate or reverse any Recurring Buy Transactions at its sole discretion and without any prior notice, even after funds have been debited from your Plum Wallet.
11. For the use of the Recurring Buy Transactions feature, Plum will not charge you any fees other than those specified under the Stock Investing Terms and Conditions.
12. Plum will reverse any transaction where there is suspicion that the order is erroneous or involving (or has a high risk of involvement in) market abuse, money laundering, terrorist financing, fraud or any other type of financial crime. In this instance, Plum will remain under no obligation to allow you to reinstate a buy order at the same price or under the same terms as the canceled transaction and cannot be held liable for any damages or losses caused due to the actions taken by Plum under these terms.
13. Plum does not provide personalised investment recommendations, investment advice, tax related advice or other financial related advice of any kind. Any explanation or information provided by Plum in relation to Recurring Buy Transactions is not intended to be (nor should it be considered as) advice. This information is provided by us solely for informational purposes.
14. You should perform your own independent research on potential investments and consult with your financial adviser to determine whether an investment or the use of the Recurring Buy Transactions feature is appropriate given your financial needs, objectives, and risk appetite.
15. You should understand that the Recurring Buy Transactions feature is speculative and that you could sustain significant losses due to volatility in the stock market. Once you’ve confirmed the details of your recurring order, the feature will automatically execute orders with no additional manual intervention for yourself.

DEFINITIONS:

Recurring Buy Transaction(s): is a feature that allows you to create investment buy orders that will repeat at a fixed frequency (be that daily, weekly or monthly), as specified by you.