Terms and Conditions of Business May 20, 2012

Churchills International Consulting Limited are Independent Financial Advisers and are authorised and regulated by the Financial Services Authority (the FSA) and are bound by FSA's rules. We confirm that you are a "retail client", as defined by the FSA rules. Our FSA Registration Number is: 309451.

We hope the following and the Key Facts documents will assist you in understanding the services we provide.

INDEPENDENT FINANCIAL ADVICE

As Group Employee Benefit Consultants Churchills International Consulting Ltd only provide recommendations and advice concerning the Employee Benefits Programme, administered on behalf of your Employer. If you require financial advice concerning any arrangements other than your Employee Benefits with your employer then you should seek advice from an alternative Independent Financial Adviser, contact www.unbiased.co.uk for further information.

We offer independent financial advice, but occasions can arise where we, or one of our other customers, will have some form of interest in business, which we are transacting for you. If this happens, or we become aware that our interests or those of one of our other customers conflict with your interests, we will inform you in writing and obtain your consent before we carry out your instructions.

COMMISSIONS

We can derive income from commission paid to us in respect of transactions we undertake on your behalf.

We will tell you the amount of commission or any other form of benefit from the issuer of a security or from another intermediary. Alternatively, we can agree a fee and refund commission to you or use it to pay the fee.

CHARGES

Where, on receipt of instructions from you, a financial report is prepared or additional work has to be undertaken that does not relate to investments on which commission is payable, or advice is given but no transaction arranged on your behalf, fees will be costed on a time spent basis at a rate agreed with you in writing. Where we propose to charge a fee we shall agree the rate with you prior to any work being carried out.

STATEMENT OF REVIEW

When we have arranged any investments, pensions and employee benefits for which you have given instructions we will not give you any further advice unless you request it, but will be glad to advise you at any time you ask us to do so.

STATE SECOND PENSION

We do not advise our clients on the suitability of contracting out or into the State Second Pension (S2P).

ENHANCED/PRIMARY/FIXED PROTECTIONS

Please note that it is the employee's responsibility to advise if they have "Enhanced/Primary/Fixed Protections" on their pension. Joining the Employee Benefits Programme, i.e, Death in Service or Group Personal Pension Plan could adversely affect their Enhanced Protection status. Churchills do not accept any liability or responsibility for employees joining the Employee Benefits Programme when they have selected "Enhanced/Primary/ Fixed Protections".

ADVICE

We prefer instructions to be given to us in writing to avoid any possible disputes. If any instructions are given to us orally then they should be confirmed in writing. We may refuse at our discretion to accept certain instructions, although such discretion will not be exercised unreasonably.

RECORDS

We keep records of all your investment transactions for at least six years. You, or your appointed agent, have the right to inspect the records at a mutually convenient time. As we treat all our clients' records as confidential, we reserve the right to give you copies of your records, where in certain circumstances to release the original would compromise other clients' confidentiality.

REGISTRATION AND POLICY DOCUMENTS

We will register all investments in your name unless otherwise agreed in writing. All contract notes and documents of title in respect of your investment will be forwarded to you, unless otherwise instructed in writing, as soon as practicable after being received by us. Where a number of documents relating to a series of transactions are involved and the documents will normally be retained by us until the series is complete and then we shall forward them to you.

TERMINATION

You, or we, may terminate our authority to act on your behalf under these terms of business at any time, without penalty. Notice of this termination must be given in writing and will take effect immediately upon receipt of the notice. Termination will not prejudice the completion of transactions already initiated on your behalf or any rights or obligations already arising.

CLIENT MONEY

Churchills International Consulting Ltd is able to hold and control client money only in respect of non-investment insurance contracts. We do not hold client money for investment contracts e.g., Bonds, Pensions, etc. Any monies or premiums paid are to be paid directly to the client firm.

THIRD PARTY RIGHTS

These terms of business exclude any rights, which may be conferred upon third parties by the Contracts (Third Party Rights) Act 1999.

DISABILITY DISCRIMATION ACT

If you prefer, we are able to make available to you information by audio cassette or Braille.

DATA PROTECTION AND DIRECT MARKETING - INFORMATION HELD ABOUT YOU

Information about you and your investments (personal data) you provide to us is subject to the Data Protection Act 1998 (Act). By signing this Agreement you consent to us or any company associated with us to process, both manually and by electronic means, your personal data for the purposes of providing advice, administration and management of your investments.

We may also process information about other individuals (e.g., your spouse), which you provide to us. In providing such information on other individuals you agree that you have obtained those individuals’ consent to our processing information about them for the purposes of this Agreement. "Processing" includes obtaining, recording or holding information or data, transferring it to other companies associated with us, product providers, the FSA or any other statutory, governmental or regulatory body for legitimate purposes including, where relevant, to solicitors and/or other debt collection agencies for debt collection purposes and carrying out operations on the information or data both inside and outside the European Economic Area. We may also contact you (including by telephone) with details of products, promotions, services or for related marketing purposes in which we think you may be interested.

Please notify us if you do not want us to contact you for marketing purposes by e-mail, telephone, post or SMS.

Your personal data may also contain sensitive personal data for the purposes of the Act, being information as to your physical or mental health or condition; the commission or alleged commission of any offence by you; any proceedings for an offence committed or alleged to have been committed by you, including the outcome or sentence in such proceedings; your political opinions, religious or similar beliefs, sexual life; or your membership of a Trade Union.

Please notify us if you do not consent to us processing any such sensitive data.

We maintain all the information on computer and/or paper files. Your acceptance of these Terms of Business means you agree to us holding your information. Information will only be disclosed to third parties where it is necessary to do so in whatever format is considered appropriate by the firm.

Please notify us if you do not wish to receive information about the products or services of other carefully selected third parties from within the Financial Services and Insurance industry.

If at any time you wish us to cease processing your personal data or sensitive personal data, or contacting you for marketing purposes, please contact The Compliance Officer on 01636 815533 or in writing to Churchills International Consulting Limited, Compliance Officer, Chartwell, Edingley, Nottinghamshire, England, UK, NG22 8BZ

You may be assured that we will treat all personal data and sensitive personal data as confidential and will not process it other than for legitimate purposes. Steps will be taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary. Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to the data. Subject to certain exceptions, you are entitled to have access to your sensitive personal data held by us. You may be charged a fee (subject to the statutory maximum) for supplying you with such data.

OUR DETAILS

Churchills International Consulting Limited (Company Number: 01659058)
Chartwell
Edingley
Nottinghamshire
NG22 8BZ

Contact Us
by e-mail: anna@churchillsconsulting.com
by telephone: 01636 815533
by Post: At the above address

Churchills International Consulting Ltd are authorised and regulated by the Financial Services Authority (FSA Reg. No. 309451). Registered in England and Wales No. 01659058, and its registered office is at 12 Bridgford Road, West Bridgford, Nottingham, NG2 6AB.