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• 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.

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:


"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:


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:

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.

SCHEDULE 1

GLOSSARY

Cash ISA Services

the provision of the Cash ISA product as set out by these terms

Cash ISA Terms

has the meaning given in the Introduction.

FCA

has the meaning given in the About Us section.

FCA Client Money Rules

means the rules and guidance as made or amended by the FCA from time to time in respect of the holding and safeguarding of customer funds, as currently set out in the Client Assets Sourcebook section of the FCA Handbook of Rules and Guidance.

FCA Rules

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

FCA Safe Custody Rules

means the rules and guidance as made or amended by the FCA from time to time in respect of the holding and safeguarding of customer assets, as currently set out in the Client Assets Sourcebook section of the FCA Handbook of Rules and Guidance.

Fees

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

Flexible ISA

an ISA product whereby funds withdrawn can be replaced without using up subscription limits.

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.

Individual Savings Account

A tax-efficient wrapper for either saving cash or investing in stocks & shares, with an annual subscription limit prescribed by HMRC.

QMMF

means the qualifying money market fund and is the BlackRock ICS Sterling Government Liquidity Fund (reference no. 632553) issued by the (Q)MMF Provider.

‘Qualifying’ indicates the fund is approved for use in segregation of client money, as per the FCA Client Money rules.

The (Q)MMF is a segregated compartment established and maintained by the Institutional Cash Series.

(Q)MMF Provider

means the provider of the QMMF issued by BlackRock Investment Management (UK) Limited (reference no. 119293), authorised and regulated by the Financial Conduct Authority.

Plum Cash ISA

a type of account that offers tax-free interest/return. That means you will be able to keep all of the interest/return you earn, as long as you abide by the conditions of the account.

Plum Account

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

Plum App

has the meaning given in the Introduction.

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.

Retail Client

has the meaning given in the FCA Rules.

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.

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 MMF Services are broadly restricted or prohibited by any Sanctions.

Transaction

adding or removing money from your Cash ISA.

Website

means

 https://withplum.com/

WithPlum

means the interface we provide to access Plum Cash ISA and Cash ISA Services and any other product or service offered by us from time to time.



Interest Pockets Terms

These Interest Pockets Terms



Plum GIA/ISA: Investment Terms and Conditions

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

Contents


Section 1 – General Terms of the Plum Investment Account


Section 2 – GIA/ISA Product Provider Terms


Section 3 – Plum’s Conflicts Management Policy



Section 4 - Order Handling and Best Interest Policy



Section 5 - Customer investments and risks



Section 6 - Glossary


Section 1 - General Terms of the Plum Investment Account

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

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

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

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

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


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.


Part B: Additional ISA Product Provider Terms




Section 3 – Plum’s Conflicts Management Policy




Section 4 - Order Handling and Best Interest Policy




Section 5 - Customer investments and risks



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


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.


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.


Section 3 – Plum’s Conflicts Management Policy




Section 4 - Order Transmission Policy



INTRODUCTION

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

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

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

YOU’RE CONSENT

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

ORDER EXECUTION

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

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

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

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

ORDER EXECUTION

The execution factors Quai take into account are:


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


TRANSMITTING ORDERS

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

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


SPECIFIC INSTRUCTIONS FROM YOU

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

ORDER AGGREGATION

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

EXECUTION VENUES

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

Platform Securities maintains their own order execution policy.

BEST EXECUTION POLICY

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


Section 5 - Customer investments and risks



This is not intended to be a comprehensive statement of all the risks to which investors might be exposed and there may be others that exist now, or which may arise in the future. We have set out the main risks to which investors will be exposed, as we understand them, but warn that investing is always exposed to new risks and that some risks once thought to be very low can rapidly develop into high and serious risks.


Appendix 1. SIPP Product Provider Privacy Statement



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

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

• How and why we collect personal information

• What we do with it

• When and why we share it with other organisations

• How long we keep it

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

Contact Us

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

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

How we collect personal information

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

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

• Your name

• Address

• Date of Birth

• National Insurance Number

• Plum Account Number

• Gender

• Email address

• Telephone Number

• Bank account details

• Emergency Contacts

• Medical information (in certain limited circumstances)

• Any further information required as part of a product application

Why we need it and what we do with it

We use your personal information in the following ways:


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

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

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

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

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

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

How long we keep it

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

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

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

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

What are your rights?

Under data protection legislation, you have rights including:


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

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

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

How to Complain

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

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

The ICOs address:

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

Helpline Number: 0303 123 1113

ICO Website – https://www.ico.org.uk



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.

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

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:


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):


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

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.