Background of European Financial Planning Group SL:

Our aim is to provide independent insurance and financial advice to individuals, companies, and other professional advisers. As an independent adviser, we are not tied or under any contractual obligation to conduct insurance mediation exclusively with one or more product providers. We use a number of different insurance companies and offer a wide range of insurance products. We can provide a list of products and providers if requested. Along with advice regarding your insurance needs, we will also offer assistance with any claims or alterations you may have to make.

Treating Customers Fairly:

We fully subscribe and adhere to the principle of “treating customers fairly”. We regard the interests of our customers as paramount and this is always our primary concern. Therefore we ensure that:

a.) Our business dealings are conducted with the utmost integrity and any conflicts of interest are managed fairly in whatever situation.

b.) We always pay careful concern to the information needs of our clients and communicate with them in a way that is clear, fair, and not misleading.

c.) The advice we provide will take into account our client’s insurance requirements in order to provide them with the most suitable product.

d.) Our customers can rely on the suitability of our advice.

e.) Our systems and procedures reflect this culture and there are clear and regular reporting procedures to check the implementation of these points. There is a clear business strategy in our Company continually to reflect these principles.

Regulation:

European Financial Planning Group SL Limited is licensed and regulated by the Dirección General de Seguros y Fondo de Pensiones Nº J-3795 (DGSFP) and bound by the rules. Our licence number is Nº J-3795. Further details concerning licensing can be obtained directly from the Dirección General de Seguros y Fondo de Pensiones at the following address: Avenida del General Perón, 38, 28020 Madrid. Details of our licence can be verified on the DGSEP’s Website: www.dgsfp.mineco.es or tel: 0034 952 249 982. Under our licence we are authorised to provide advice on a wide range of insurance products and services in Spain.

Client Instructions:

We require our clients to give us instructions in writing to avoid possible disputes. We will only accept oral instructions provided they are confirmed in writing. We reserve the right to refuse to accept certain instructions, but this discretion will not be exercised unreasonably.

Reviews:

When a policy is up for renewal, we review the policy and compare it to similar products being offered by additional providers that we work with. This way you can rest assured, that we are actively ensuring that you have the most suitable and competitive policy to cover your needs.

Professional Indemnity Insurance:

We maintain professional indemnity insurance for the protection of our clients as required to do so by the Dirección General de Seguros y Fondo de Pensiones.

Remuneration:

We receive a commission from the insurer for providing you with the services detailed above. We reserve the right to act as an agent for third parties and to share remuneration received with them. In the event that another individual or company has introduced you to us, we reserve the right to pass on a portion of the commission we receive to this entity for effecting the introduction.

Fees and Charges:

Your insurance Premium is paid to the insurer upon policy inception and at renewal. In addition to this, we will charge fees in the following sums: New Business Agreement – up to €25, Mid Term adjustments – up to €15, Mid Term Cancellations - €25, Cancellation during cancellation rights period - €25, Renewal arrangements – up to €25, Duplicate Documents - €10

Any mid-term cancellations outside the cooling-off period will be charged €25 and will be subject to the insurer's short-period cancellation scale.

Any cancellations during the cancellation rights period will be charged at €25, along with any additional costs from the insurance company.

Your insurance company can provide you with further information regarding charges that could be applied in these periods.

Your Duty to Provide Information:

It is your responsibility to provide information to insurers when you take out your insurance policy, throughout the life of the policy and when you renew your insurance. It is important that you ensure all statements you make on proposal forms, claims forms, and other documents are full and accurate. Where statements of fact documents form the basis of your insurance contract, the information should be accurate and any errors advised to us immediately. You are responsible for checking that the policy terms and conditions meet your requirements and for notifying claims or circumstances that might give rise to a claim. To ensure full protection under your policy you should familiarise yourself with the coverage conditions and procedures relating to claims and their notification. Failure to disclose facts; pertaining to your insurance, or any inaccuracies in information given, could result in your insurance being invalid or cover not operating fully. It is important that you ensure all statements you make on Proposal forms, Claims forms, and other documents are true, full, and accurate. If a form is completed on your behalf, you should check that the answers shown to any questions are true and accurate before signing the document. You are advised to keep copies of any correspondence you send to us or direct to your insurer. If you are in any doubt over any of the policy terms and conditions, please seek our advice immediately.

Data Protection:

We take protecting our customers very seriously and abide by the rules of the General Data Protection Regulation (GDPR). Please refer to our Privacy Notice for information on how we hold and process your data. Copies of the Privacy Notice are supplied on all emails and can be viewed at the website www.efpg.es or hard copies supplied on request.

Termination of Terms:

These terms may be varied or suspended at any time by notice in writing. Any such variation will not affect rights or obligations already accrued by either party.

Cancellation:

Where applicable the Mid Term cancellation refund will be issued within 6 – 8 weeks from the active cancellation date of the policy.

Cancellation Rights:

You have the right to cancel your policy during a period of 14 days either from the day of purchase of the contract or the day you received your policy documents, whichever is the latter. If you wish to do so and the insurance has not yet commenced you will be entitled to a full refund less any admin charges. Alternatively, if you wish to do so and the cover has commenced, you will be entitled to a refund, subject to a deduction for the time for which you have been covered on a pro-rata basis, plus a 35.00 Euro admin cost incurred in issuing the policy. A refund of the premium may not be given if you made a claim under the policy or an incident has occurred which may give rise to a claim under the policy. To exercise your right to cancel please contact us. If you do not exercise your right to cancel your policy will continue in force for the term of the policy and you will be required to pay the full premium.

Complaints:

We will always aim to provide a first-class service. However, should you have any complaint about the advice you receive or any of our services, please in the first instance write to the Compliance Office at our company address below (on the website footer). Your complaint will be acknowledged within five working days, at which point you will be sent the complaints procedure and be advised of who will be handling your complaint. A formal written response will be provided within 8 weeks from the date of the receipt of the complaint. If the complaint cannot be resolved within this timescale we will write advising you of the current progress. If we cannot settle a complaint you may be entitled to refer it to The DGSFP Avenida del General Peron, 38, Madrid, 28020, Spain. Tel: 0034 952 249 982. Your insurer will also operate a complaints procedure, details of which will be included in your policy.

Entire Agreement:

This agreement constitutes the entire understanding and agreement between the parties in relation to the subject matter of this agreement. Each party acknowledges that it has not entered into this agreement in reliance wholly or partly on any representation or warranty made by or on behalf of the other party (whether orally or in writing), other than as expressly set out in this agreement.

Governing Law and Jurisdiction:

This agreement shall be governed by and construed in accordance with the law of Spain. Any dispute arising out of or in connection with, or concerning the carrying into effect of this agreement, shall be subject to the exclusive jurisdiction of the courts of Spain and the parties hereby submit to the exclusive jurisdiction of those courts for these purposes.

Payment/Documentation:

The provision of insurance services is subject to the satisfactory payment of the appropriate premium. Premiums are due for payment by the inception/renewal date of the policy. Premiums resulting from a request for an amendment are due immediately upon request. We will provide full information about your payment options at the appropriate time. We may keep certain documentation such as your insurance certificate until we receive full payment (we will seek the agreement on this if appropriate). In these circumstances, we will ensure that you receive full details of your insurance cover and will provide you with any documents which you are required to have by law. Failure to make arrangements to pay premiums by the due date will lead to cancellation of cover in respect of new policies and renewals, or the required change not being actioned in respect of amendments. If you are unable to pay the premium by the due date, please let us know immediately.

Agent of Insurer:

Where we do not act as an agent of the insurer, we will treat monies held as Client Money and will hold these in a non–statutory client account.

Non-Statutory Trust:

The aim of the trust is to protect the client in the event of the failure of the firm, or the failure of the bank or a third party at which the money may be held. In such a circumstance, the firm's general creditors should not be able to make claims on client money, as it will not form part of the firm’s property. The fact that we will hold money in trust gives rise to fiduciary duties, which will be owed to you until the client's money reaches the insurer or product provider. This means that we may use and are entitled to use client money held on behalf of one client to pay another client’s premiums before the premium is received from the other client, and pay claims and premium refunds to another client before we receive the payment from the insurer. However, we are not entitled to use client money to pay commissions before we receive the relevant premium from the client.

Interest on Client Money:

Any interest earned in client money held by us will be retained by us for our own use, rather than paid to you. We will take your reading of this document, and continuance of the application process to indicate that you understand, and have given your consent for us to hold your monies in the statutory trust and to receive interest.

Payment to Third Parties:

We may transfer client money to another entity, such as another settlement agent or broker. This would be, for the purpose of effecting a transaction on your behalf through that person.