WHAT YOU NEED TO KNOW NOW

ABOUT OURFULL ADVISORY SERVICE

This document is split into two parts;

WHAT YOU NEED TO KNOW NOW and

WHAT YOU NEED TO KNOW IF YOU ENGAGE US

It sets out:

□thekeyfactsaboutourFullAdvisoryService;

□ourchargesfortheprovisionofthoseservices;

□thetermsandconditionsthatapply;

□information about our ongoing services.

This document also includes important information for you to consider carefully before you decide to proceed with us. If, having read this document, you ask us to proceed, then the terms set out in this documentwillformanimportantpartofthelegalagreementbetweenusandwillbelegallybindingon bothofus.Pleaseletusknowifanythinghereisunclearorifyouhaveanyquestions.

CLIENT CLASSIFICATION

Flying Colours classifies all clients as ‘retail clients’ for investment business and ‘consumers’ for non- investment insurance business, which means you are afforded all protections under the rules of the FinancialConductAuthority(FCA).Shouldyouwishtobeclassifieddifferentlyforinvestmentbusiness, pleasediscussthiswithyouradviser.Youradviserwillinformyoushouldyourcircumstancesdictatethat wewouldneedtoclassifyyoudifferentlyfornon-investmentinsurancebusiness.

Pleasenotethatshouldyouwishtobeconsideredasadifferentcategoryofcustomerforinvestment business,suchasaprofessionalclientoreligiblecounterparty,youmustinformusinwriting.Wewill provide you with a new Client Agreement and you may lose a number of protections which will be outlinedinthatnewagreement.

THE SCOPE OF OUR FULL ADVISORY SERVICE

BeforewestartprovidingourFullAdvisoryServicetoyouitisveryimportantthatyouunderstand thenatureandscopeofourservice.

The serviceis designed for those clients who require financial planning services. We will gather information from you and any existing providers you may have to get a view of your whole financialsituationandusethatinformationtocreateasetofrecommendationsdesignedtoimproveyour financialsituation, bearing in mind your objectives.The serviceincludes:

Phase 1: Initial Consultation (at Flying Colours’ own cost)

Theprocessbeginswithaninitialtelephoneconsultationtounderstand,inbroadterms,yourneedsand objectives.Wewillassesswhetherourservicesaresuitableforyourneeds,andagreetheexpectedtime frame for the initial advice process to be completed. This conversation usually lasts for between 10 – 20 minutes,thecostofwhichismetbyFlying Colours.

Phase 2: Detailed information gathering (at Flying Colours’ own cost)

Thesecondphaseoftheprocessistogathermoreinformationaboutyourcircumstancestoenableusto understand your situation fully. You will be asked to provide certain information about your financial situationwhichwillenableustoassessyourcircumstancesandobjectivesforthepurposeofcarryingout yourfinancialreviewandprovideyouwithourrecommendations.

After this conversation we will ask you to confirm whether or not you want us to preparearecommendationsreportand,ifapplicable,analyseyourexistinginvestments. We will be able to give an indicative timescale for this. Before this work is started, we will ask you to sign a specific Client Engagement Letter as, at this stage, we will have some idea of how we can help you.

Phase 3: Delivering your personalised financial plan

Once we have considered your answers to our questions and any other information you have provided, the final stage is for us to provide you with the recommendationsreport,whichwewillmakeavailabletoyouinelectronicformat.Wewillthenarrangea time to discuss the contents of our report and the recommendations we have provided. We ask you to raise any questions and/or objections you may have at this stage so that we can further tailorouradvicetoyourcircumstances,ifrequired.Wewillthenfinaliseyourreport.Finalversionsofthe report will be made available to you for your future records along with supporting documentation. The fees for this service are outlined in the section below named “Fees, costs andcharges.” YOU SHOULD READ THIS SECTION BEFORE ENGAGING US.

THROUGHOUTTHEADVICEPROCESSWEASKYOUTOANSWERALLQUESTIONSTRUTHFULLYANDACCURATELY AND TO LET US KNOW IF SOMETHING CHANGES.WECANNOTBE HELDRESPONSIBLEIFOURADVICEFAILSTOMEETTHERELEVANTSTANDARDSBECAUSEWEHAVERELIEDONINFORMATION PROVIDEDBYYOUTHATISINCOMPLETEAND/ORINACCURATE.

Our Full Advisory Service is not available and is not suitable for:

□anypersonwhoisormaybeconsidereda“U.S.Person”; (we can tell you if we consider you to be a “US Person”)

□anypersonwhoisundertheageof18;

□anypersonwhoisanon-UKresident

FEES, COSTS AND CHARGES (Re Phase 3 of the process above)

Wewillneverchargeyouuntilwehaveagreedwithyouhowand what wearetobepaid.Wewillalwaysconfirm this verbally and in written communication to you, this will be either in hard copy, by post or electronically and will showtheexactamountaswellasthepaymentmethod. We will ask you to sign the Client Engagement Letter to confirm that you are entering into a contract with us.

We charge a fee for preparing and producing a recommendations report.Thisfeeis3%ofthevalueoftheassets on whichwehaveadvised, subject to a maximum of £15,000 and minimum of £1,000.

EXAMPLES OF CHARGES

Advice area / Value of pot or investment / Initial charge (covering report and implementation)
Investment or pension / £50,000 / £1,500
Investment or pension / £150,000 / £4,500
Investment or pension / £500,000 / £15,000
Investment or pension / £600,000 / £15,000(maximum applied)

Ordinarily, we will take any initial charge directly from your funds before they are invested. However, in some cases we may agree to accept a payment from you by cheque or bank transfer, in which case we will issue you an invoice for the agreed fee.

Once a fee has been paid for work carried out, then it will not be refunded. A fee becomes due on production of your personalised report.

Additional or follow on work

Feesforanyadditionalworkwillbeagreedbetweenyouandyouradviserbeforeanywork isundertaken.Feescanbechargedasapercentageoftheassetsadvisedon,oras a bespoke fee which will be agreed at the time and never be more than our maximum.

There may be occasions when you requirefinancialadvicethatextendsbeyondthatwhichwouldbecoveredby our usual financial planning services. For instance, you may require advice in relation to estateplanningorcapitalgainstaxissues.Wemaybeabletoprovideyouwithdiscreteadviceinrespect ofsuchareasonanadhocbasis,ifandwhensuchsituationsarise.Beforeprovidingyouwithsuchadvice, wewillconfirmthescopeofourengagementandagreeourfeeswithyou.

Non-investment Insurance

Paymentwillbemadebycommissionfrom the product.Our minimum charge for this work is £1,000. Ifcommissionispayablebutdoes not cover our fee, we will agree a method of payment for any shortfall before commencing any chargeablework.YouwillreceiveaClientSpecificIllustrationwhichwilldetailanyotherfeesrelatingto yourparticularinsurancepolicy and confirm the commission payable.

METHODS OF COMMUNICATION

Unless you advise us otherwise, we will communicate with you via the following methods; Face to face, E-mail, Telephone,Letterandsecuremessagingviatheonlineportal.AlldocumentsandotherinformationyoureceivefromuswillbeinEnglishand allotherformsofcommunicationbetweenuswillbeinEnglish. Please let us know if you require any of our communications in a different sized font.

CLIENT MONEY

Flying Colours doesnothandleclients’money,whichmeanswedonotholdyourmoneyinourbank accounts. We never handle cash but we may accept a cheque made out to us if it is in settlement of fees or disbursementsforwhichwehavesentyouaninvoice.

DATA PROTECTION AND MARKETING

Flying Colours may use your data for marketingpurposes,tokeepyouinformedabouttheproductsandservicesofferedbyFlying Coloursand other providers of products and services with whom we may have a relationship from time to time. You havearighttorequestusnottouseyourdatafordirectmarketingpurposes.Ifyoudonotwishtoreceive direct marketing from Flying Colours, please write to us at Flying Colours, Marketing department, 2 Queen’s Square,Ascot Business Park, LyndhurstRoad,Ascot,SL59FE.Unlessyoutellusotherwise,youagreethat wemaycontactyoubymail,emailand/ortelephone.

TERMS OF OUR AGREEMENT WITH YOU

Thetermscontainedandreferredtointhisdocumentshallremaininfullforceandeffectforsolongas weprovideandcontinuetoprovideadvisoryservicestoyou.

Ifyoudecidetoreceivediscretionarymanagementandotherservicesfromusinadditiontoouradvisory services,thenwewillagreeadditionaltermswithyouwhichshallsupplementthetermscontainedinthis document.

AMENDING OUR AGREEMENT WITH YOU

Wemay,atanytime,enhancetheservicesweprovidetoyouifwereasonablyconsiderthatthisistoyour benefitandthereisnoincreasedcosttoyou.

We may also amend this agreement:

1.IfwearerequiredtodosoforreasonsofcompliancewiththerulesoftheFinancialConduct Authority,oranyotherapplicablelaworregulation;

2.Toreflectchangesinthecostsandchargesthatweincur(orreasonablyexpecttoincur)inproviding theservicestoyou,includingtotakeaccountofchangesintheratesofinflation,taxesorinterest;

3.Tomakethesetermsfairertoyouoreasiertounderstand,ortocorrectmistakes;

4.Toreflectchangesinmarketpracticeorconditions;and

5.Toenableustomakereasonablechangestothewayweprovideourservicesasaresultof changesinthefinancialservicessector,technology,oravailableproducts.

Ifweproposetomakeachangetothisagreementinawaythatisnotdetrimentaltoyou,wecanmake thechangeimmediately.WewillmakeinformationabouttherelevantchangeavailableonourWebsite within30daysofthechange.

If we propose to make a change to this agreement that may be detrimental to you, we will provide you with at least 30 days’ prior notice (unless we are required to make the change sooner, for example, for legal or regulatory reasons, in which case we will make information about the changeavailable to you as soonaspossible).Ifwemakeachangethatisdetrimentaltoyou,youmayterminateyouragreementwith us.

GOVERNING LAW AND JURISDICTION

OuragreementwithyoushallbegovernedbyEnglishlawandalldisputesshallbesubjecttothe jurisdictionoftheEnglishCourts.

BEFOREPROCEEDING,PLEASEBEAWARETHATTHEVALUEOFANYINVESTMENTYOUMAKEMAYGODOWN ASWELLASUP.

Flying Colours is a trading name of Flying Colours Finance Ltd, authorised and regulated by the Financial Conduct Authority under number 672022. You can check this information at

WHAT YOU NEED TO KNOW IF YOU ENGAGE US

ABOUT OUR ONGOING ADVISORY SERVICES AND LEGAL INFORMATION

Ifyoudecidetoimplementourrecommendations,we mayrecommendourOngoingAdvisoryServices to help keep you on track with your goals. This mayinclude but is not limited to:

□Accesstoasecureonlineportal;

□Regularinvestmentreporting;

□Regularupdatestoyourfinancialplan including an annual review with your adviser to check you are on track and if anything has changed; and

Access to a secure online portal

Oursecureonlineportalwillallowyoutoviewthevalueofyourinvestmentsinrealtime, check your current financial plan, send and receive messages with Flying Colours and update your personalsituation.

Regular updates to your financial plan

Onceayear,aroundtheanniversaryofyourplanbeingimplemented,wewillsendyouareport.This reportwillbestructuredtocomplementthereportwehavepreviouslyprovidedandwillalsocontain recommendationsforthenextperiod.AtypicalrecommendationcouldincludemaximisingyourISA allowance(ifsufficientfundsareavailable)ordrawingmoneyfromyourinvestmentsinthemosttax efficient manner.

In order to generate this report, we will need you to inform us of any changes in your personal circumstances,includinganyneworchangedfinancialgoals.Wewillusethisinformation,alongwith detailsofyourinvestments,togenerateanynewrecommendations.

YouarealwaysabletospeaktoaFlying Colours financialadvisertodiscussanyqueriesyoumayhave regardingtherecommendationsinyourreport.

OurAnnual Fee

If you agree to engage our Ongoing Advisory Services, we will charge you an ongoing fee. This fee is 1%pa with a minimum of £499pa.Examples follow:

Value of investment / Annual fee
£36,000 / £499 (Minimumapplied)
£50,000 / £500
£200,000 / £2,000

Thisfeeisforongoingadvisory services as indicated above.As the value of your portfolio grows, so will the value of the annual fee payable.

Other Bespoke Rates and Additional Work

Theremaybeoccasionswhenwewillagreeaservicethatwillbebasedon a fixed fee that is not covered in the information above.Feesforthisworkwillbeagreedbetweenyouandyouradviserbeforeanywork isundertaken.

TERMINATION AND CANCELLATION

Termination of Our Full Advisory Services

Youorwemayterminateourauthoritytoactonyourbehalfatanytime.Youwillbeliabletopayforany adviceorservicesthatyouhavereceivedpriortothedateoftermination.Thismeansthatif you have signed the Client Engagement Letter and we have created a recommendations report for you, then you will have to pay the agreed fee.

Termination of our Ongoing Advisory Service

YouhavearighttocancelourOngoingServiceatanytime.Wewilltakeanyfeesaccruedtothedateyou cancel theservice.

Cancellation of non-investment insurance products

Please note that non-investment insurance products on which we advise may attract cancellation rights. Fulldetailsofsuchcancellationrightswillbesetoutinseparateproductdocumentationwewillprovideto youbeforeyoupurchaseanysuchproduct.

CONFLICTS OF INTEREST AND RECEIPT OF NON-MONETARY BENEFITS

Inaccordancewithitsregulatoryduties,Flying Colours followsitsConflictsofInterestpolicy–asummary ofthekeypointsrelevanttotheprovisionofitsFullAdvisoryServicesaresetoutbelow.Furtherdetailsof ourConflictsofInterestpolicyareavailableonrequest.Byreceivingourservicesand,thereby,accepting the terms set out in this document you are agreeing and consenting to the terms of the Flying Colours ConflictsofInterestpolicy.

In the provision of its Full Advisory Services, Flying Colours will be considering whether or not to recommend to you the provision of its own discretionary management (available through Flying Colours – the regulated firm) and other ongoing services wherefeesarepayable–therefore,thereisthepotentialforthefinancialandcommercialinterestsof Flying Colours toconflictwiththeinterestsofitsclientswhenassessinganddecidingwhethertomake such recommendations.

As we offer independent financial advice, we are duty bound to act in your best interests and to advise themostsuitablefinancialproductsandservices.

There may be other occasions where we or one of our other clients have some form of interest in businessbeingtransactedforyou.Ifthishappensorwebecomeawarethatourinterestsorthoseofone of our other client’s conflict with your interests, we will write to you and obtain your consent before we carryoutyourinstructions,anddetailthestepswewilltaketoensurefairtreatment.

Where permitted by the FCA, Flying Colours may occasionally receive non-monetary benefits such as trainingfromInvestmentandInsurancecompanies.Thereceiptofsuchnon-monetarybenefitsdoesnot constitute any commitment on our part to support such companies by the referral of business or otherwise.Furtherdetailsareavailableonrequest.

COMPLAINTS

We would like all of our customers to feel happy with the products and service we provide, and we take anycomplaintextremelyseriously.Ifyouaren’thappywithourproductsorourservice,thenpleaseletus know.YoucaninformyourFlying Colours adviser,or rwriteto TheComplaintsManager,Flying Colours,2 Queen’s Square, Ascot Business Park, LyndhurstRoad,Ascot,SL59FE We’ll let you know we’ve received your complaint, investigate it thoroughly and then get back to you. If you aren’t happy with how we deal with your complaint or if it is unresolved after 8 weeks, you will be able to refer your complaint against us to the Financial Ombudsman Service. Their address is: The Financial Ombudsman Service, Exchange Tower, London E14 9SR. You can read more about the ombudsman here

THE FINANCIAL SERVICES COMPENSATION SCHEME

We are covered by the Financial Services Compensation Scheme (FSCS). You may be entitled to compensationfromtheschemeifwecannotmeetourobligations.Thisdependsonthetypeofbusiness andthecircumstancesoftheclaim.Asatthe30thJanuary2017thefollowinginformationisaccurate.

Investment

For eligible compensation claims, most types of investment business are covered for 100% of the first

£50,000, so the maximum compensation is £50,000.

Insurance

Non-compulsory insurance provision: protection for 90% of the claim with no upper limit.

Deposits

Moneyinaccountslikecurrentandsavingsaccounts,includingcashISAsarecoveredupto£85,000per authorised firm/banking group. It should be noted that “authorised firms/banking group” may have several different brands and you should check with the FSCS.

Further information about compensation scheme arrangements is available from the FSCS (

TREATING CUSTOMERS FAIRLY (TCF)

Flying Colours is committed to providing a high level of service to our clients by exceeding your expectationswhenitcomestoadministration,customercareandprovidingyouwiththecorrectadviceto meetyourneeds.Weregularlyreviewourservicelevelsandappreciateclientfeedbackonhowwecould dobetter.Ifyouhaveanycommentsorsuggestions,pleaseletusknow.

Client Agreement June 17 v.1 Ascot FINAL APPROVED 1.6.171