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TERMS OF BUSINESS
The following Terms of Business set out the basis on which Ambit Financial Services Ltd will provide business services to you as a client of the company. If you have any queries or need further clarification in respect of any of these terms, please contact us. If any material changes are made to these terms, we will notify you. These terms are effective from 20th January 2022 and shall apply to any business services provided to you now, or at a future date.
Code of Conduct
Scope of Services
We are in an ideal position to place business with all the leading insurers and product providers with whom we hold agency appointments – Aviva Life & Pensions UK Limited, BCP Asset Management DAC, BES Management Ltd, Cantor Fitzgerald Ireland Limited, Irish Life Assurance plc, J & E Davy, Mercer, New Ireland Assurance Company plc, Quilter Cheviot Limited, Royal London, Scottish Mutual International DAC, Scottish Provident Limited (Utmost), Standard Life Assurance Company, Wealth Options Limited and Zurich Life Assurance plc. We are not tied to any specific institution and are therefore able to provide impartial advice and choice. The Company is also a member of Brokers Ireland.
The Company also provides a comprehensive Financial Planning Service. This includes the provision of financial planning advice and a wide range of financial services products. These include Life Assurance, Income Protection, Serious Illness Cover, Pension Planning, Savings, and Investments.
Fair Analysis
The concept of fair analysis is derived from the Insurance Mediation Directive. It describes the extent of the choice of products and providers offered by an intermediary within a particular category of life assurance, and/or a specialist area. The number of contracts and providers considered must be sufficiently large to enable an intermediary to recommend a product that would be adequate to meet a client’s needs.
The number of providers that constitutes ‘sufficiently large’ will vary depending on the number of providers operation in the market for a particular product or service and their relative importance in and share of that market. The extent of fair analysis must be such that could be reasonably expected of a professional conducting business, taking into account the accessibility of information and product placement to intermediaries and the cost of the search.
In order to ensure that the number of contracts and providers is sufficiently large to constitute a fair analysis of the market, we will consider the following criteria:
We offer advice on a fair analysis basis in relation to products available from insurance companies.
We will provide assistance to you for any queries you may have in relation to the policies or other products or in the event of a claim during the life of the policies. However, it is your responsibility to read the policy documents, literature, and brochures to ensure that you understand the nature of the policy cover, particularly in relation to PHI and serious illness policies. Specifically, on the subject of permanent health insurance policies you should read the documentation so that you understand a) the meaning of disability as defined in the policy; b) the benefits available under the policy; c) the general exclusions that apply to the policy; and d) the reductions applied to the benefit where there are disability payments from other sources.
For a serious illness policy, you should read the documentation to understand the specific types of serious illness which are covered, the restrictions, conditions and general exclusions that attach to that policy.
Payments
You must keep up premium payments on any protection insurance policy in order to ensure that cover is maintained.
Ambit Financial Services Ltd reserves the right to take legal action to recover any monies owed by clients to the firm.
Conflicts of Interest
It is the policy of the Company to avoid any conflict of interest when providing business services to its clients. However, where an unavoidable conflict may arise, we will advise you of this in writing as soon as possible. Ambit Financial Services Ltd does not have a shareholding in any insurer and likewise no insurer has a shareholding in our firm.
Remuneration
The Company is remunerated through commissions and other payments from insurers and product providers. Where we receive recurring commission this forms part of the remuneration for initial advice provided and servicing your product.
Depending on the nature and complexity of the product or service which we provide we may need to charge you a fee in addition to, or in place of, commissions which we may receive. In other circumstances where you choose to pay in full for our service by fee, we will notify you in writing in advance of the fee basis. Commissions are not offset against fees unless agreed with you in writing.
We may also charge a fee for giving advice, service and/or arranging a transaction for you. The fee will depend on the nature and complexity of the advice or product and the fee basis will be agreed in advance with you and will also be payable in advance. Commissions received will not be offset against fees unless agreed with you in writing.
Regular Reviews
It is in your best interests that you review, on a regular basis, the products which we have arranged for you. As your circumstances change, your needs will change – you must advise us of those changes and request a review of the relevant policy/product so that we can ensure that you are provided with up-to-date advice and products best suited to your needs. Failure to notify us of changes in your circumstances, or request a review, may result in your having insufficient insurance cover and / or inappropriate investments.
Complaints
Any complaint that you may have in relation to the business service provided should be made in writing to the Company outlining the nature of your complaint and marked for the attention of Sean O’Gorman, Managing Director. Any such complaint will be acknowledged within 5 business days.
On completion of our investigation, we will provide you with a written report of the outcome. In the event that you are still dissatisfied with our handling or our response to your complaint, you are entitled to refer the matter to the Financial Services Ombudsman or the Pensions Ombudsman. A full copy of our complaint’s procedure is available on request.
Data Protection
We operate to the highest standards of client confidentiality and meet statutory requirements under the Data Protection Acts 1998 to 2018, and the European Union’s General Data Protection Regulation effective from 25th May 2018.
Our staff and support service providers will use your personal information to offer advice on suitable products, service your business on an ongoing basis, monitor services for quality control purposes, or as otherwise required by law. For these purposes we may share your contact details and other relevant information with product providers and our support service providers, for the purposes of providing you with appropriate advice.
We would also like to offer you products and services which we think may be of interest to you. In order to do so, we would like your consent so that we may contact you by letter, email, SMS text, or telephone (mobile and landline). You have the right to ask us not to send marketing information to you at any time.
Full details of our Data Privacy Notice – Customer Summary is available on request or on our website www.ambit.ie.
Consumer Protection
Investor Compensation Scheme
The Company is a member of the Investor Compensation Scheme. This provides certain remedies to eligible clients on default by the Company. The main details of the operation and conditions of the scheme are detailed below. The Investor Compensation Act, 1998 provides for the establishment of a compensations scheme and the payment, in certain circumstances, of compensation to certain clients (known as eligible investors) of authorised investment firms, as defined in that Act.
The Investor Compensation Company Ltd (ICCL) was established under the 1998 Act to operate such a compensation scheme and our firm is a member of this scheme. Compensation may be payable where money or investment instruments owed or belonging to clients and held, administered, or managed by the firm cannot be returned to those clients for the time being and where there is no reasonably foreseeable opportunity of the firm being able to do so.
A right to compensation will arise only:
Sustainable Finance Disclosure Regulation
‘Sustainable Finance Disclosure Regulation (‘SFDR’) This EU Regulation is effective 10 March 2021. As the area of the SFDR is new and evolving without sufficient information being currently available, we do not currently assess in detail the adverse impact of investment decisions on suitability when providing investment or insurance advice. The key product providers with which we engage have developed responsible investment as part of their investment philosophies and sustainability policies. However, detailed information on specific fund recommendations we recommend is not always available. As further information on the approach being taken by product providers, and their internal/external fund managers, becomes available over the course of the next year, we anticipate reviewing these areas in our assessments.’
Sustainability
We consider the adverse impacts of investment decisions on sustainability factors in our Investment Advice and our Insurance Based Investment Advice, both at the initial stages of our research in our recommendations and annually* as part of the investment services we provide to our clients.
(*Information point: Product Producers and Insurers will have to provide periodic updates under the regulations.
Am assessment of sustainability risks are integrated into our investment advice and our Insurance Based Investment Advice through the following means.
The product information provided to us by the Product Producers and Insurers on the integration of the sustainability risks
Our professional interrogation of the information provided by the Product Producers and insurers.
Our in-house investment research as we keep our investment knowledge current and relevant
We will advise you of the likely impacts of sustainability risks on the returns of the financial product we may recommend. This will be advised to you in your Statement of Suitability (SoS)*
*Information Point: The Statement of Suitability (SoS) is not specified as the document for this information, but we see this as a suitable place.
RENUMERATION SUMMERY AND WEBSITE
Sustainability:
We are usually renumerated by commission from the Product Producers and Insurers whom we facilitate Investment and Insurance Based Investment transactions on your behalf.
The commission payment will not influence our decision to recommend a particular product. We consider how the product Producers and Insurers have integrated sustainability risks into their investment product offerings prior to making our recommendations to our clients.
Ambit Financial Services Limited is regulated by the Central Bank of Ireland
Central Bank Reference No: C1714
Company Registered Address: Unit K3 t: 045 883828.
M7 Business Park e: [email protected]
Newhall
Naas
Co Kildare
Directors: Sean O’Gorman; Margaret O’Gorman
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