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Brownell Insurance Ltd.

TERMS OF BUSINESS.

These terms of business set out the general terms under which our firm will provide insurance and investment business services to you and the respective duties and responsibilities of both the firm and you in relation to such services. Please ensure you read these terms thoroughly and if you have any queries, contact the undersigned who will be happy to clarify any topic.

Contact: Craig Brownell Tel: (01) 207 9400 Firm name and contact details:

Brownell Insurances LTD

Address: Unit 6, Block E. Nutgrove Office Park, Rathfarnham. Dublin 14. Tel: (01) 207 9418

Fax: (01) 207 9019

Email: craig@brownellinsurances.ie

Regulatory Status with the Central Bank of Ireland

Brownell Insurances Ltd is regulated by the Central Bank of Ireland. Copies of our

various authorizations are available on request.

Our Services

Insurance Brokers must be in a position to place insurance with at least five insurers of the relevant form and there generally can give consumers greater choice than agents and tied agents (except when the latter categories act as Authorised Advisors or Authorised Cash Handlers). We offer you independent advice based solely on the information provided by you. We hold written appointments from the Product Producers set out in Appendix 1 to this document.

Life Assurance companies provide products such as life cover, serious illness cover, income protection, savings, investments, pensions and Mortgages. Depending on your individual circumstances, we may provide you with advice in relation to the nature of these products and which product may be suitable for your needs. You may, however, have particular areas of interest and, in this case, we will be happy to give more detailed advice in these areas. We can give you a choice of different available products from the insurers listed in Appendix 1 and, on your instruction, we can receive and transmit orders for such products on your behalf to these insurers. With your agreement, we may review

Terms of Business

Brownell Insurances Ltd Life & Pensions

Mortgage Brokers Independent Financial Advisors

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the policies you take out on a periodic basis to ensure you are kept informed as to their benefit and to check whether they are still suitable for your needs. We will also provide assistance to you for any queries you may have in relation to the policies or in the event of a claim during the term of the policies.

We prefer our clients to give us instructions in writing to avoid possible disputes. We will, however accept oral instructions, provided they are subsequently confirmed in a letter. Any advice we give you normally will be in writing, but if given orally, will be recorded on your file.

Chinese Walls – Protection

Brownell Insurances Ltd and Alan B. Kidd Insurances t/a Kidd Insurances and Kidd Financial Services are both located in the same office building at Nutgrove office park, Dublin 14.

I can confirm that both companies are separate entities but there are some common Directors of both companies.

As a client of Brownell Insurance Ltd we can confirm that we will not pass your confidential details between these two separate companies without having first received your prior agreement.

I can also confirm that both companies are regulated by the Financial Regulator.

Commission and Charges

Commission and other payments from the completion of business remunerate Brownell Insurances Limited with the product producers listed in Appendix 1. Term insurance up to 90% first year premium & pensions variable up to 25%, In certain circumstances, it will be necessary to charge a fee for services provided. These are listed below. In set circumstances where fees are chargeable, we will notify you in advance.

Life fees

You may elect to deal with us on a fee basis. Directors Fee: up to € 215 per hour

Advisor Fee: up to €76 per hour

In determining the rate and any additional charges, factors such as specialist skills, complexity, value, risk and urgency will be taken into account. A typical life and pensions case can take from 5-20 hours of advisor time.

Conflicts of interest

It is the policy of our firm to avoid conflicts of interest in providing you with insurance and investment business services. If this is not possible, we will notify you as soon as practicable after we become aware of the conflict of interest and you may rest assured that you will be treated fairly where such a conflict is unavoidable

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Default on payments by clients

As we are not a cash handling insurance brokers we will not be responsible for the payment of initial or renewal premiums on any product we arrange on your behalf, in the event of a premium not received by an insurance company we will endeavor to forward you on any correspondence we receive in relation to the nonpayment but the responsibility must remain with you check your bank accounts for all paid or un paid premiums.

Insurers and other product producers may withdraw benefits or cover in the event of default on payments due under polices of insurance or other products arranged for you. We would refer you to policy documents or product terms for the details of such provisions.

Complaints

We ask that you make any complaint against our firm relating to investment business services provided by us in writing to Craig Brownell, Managing Director. We will acknowledge your complaint within 14 days and we will fully investigate it. 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 of, or response to, your complaint, you are entitled to refer the matter to the Financial services ombudsman, 3rd Floor, Lincoln House, Lincoln Place, Dublin 2.

Your Money

Brownell Insurances Ltd will accept cheques and direct debits in respect of all classes of Insurance in the circumstances permitted under the payments section 25G of the Investment Intermediaries Act, 1995. We are not authorised to accept cash in any circumstances.

Receipts

Brownell Insurances Ltd shall issue a receipt for each cheque received. This is required pursuant to Section 30 of the “Investments Intermediaries Act, 1995”. Receipts are issued with your protection in mind and should be stored safely.

Compensation Scheme

We are members of the Investor Compensation Scheme operated by the Investor Compensation Company Ltd – see Appendix 2 for details.

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Appendix 1

List of Product Producers

Life & Pensions Mortgages

Irish Life PIBA Broker net work Scottish Provident Standard Life Caledonian Life Wealth Options Canada Life New Ireland Eagle Star

Hibernian Life & Pensions Friends First

Hibernian Aviva Health

Others

Kidd Insurances

Kidd Financial Advisors.

Appendix 2

Investor Compensation Scheme

The Investor Compensation Act, 1998 provides for the establishment of a

compensation 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.

Brownell Insurances are a member of that compensation scheme.

The Investor Compensation Company Ltd (ICCL) was established under the 1998 Act to operate such compensation 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 there is no reasonably foreseeable opportunity of the firm being able to do so.

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A right to compensation will arise only:

if the client is an eligible investor as defined in the Act; and

if it transpires that the firm is not in a position to return client money or investment instruments owned or belonging to the clients of the firm; and

to the extent that the client’s loss is recognised for the purposes of the Act.

Where an entitlement to compensation is established, the compensation payable will be the lesser of:

90% of the amount of the client’s loss which is recognised for the purposes of the Investor Compensation Act, 1998; or

compensation of up to €20,000.

For further information contact the Investor Compensation Company Ltd at 01- 4344000.

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