Moloney Mortgages Pensions & Investments

Moloney Mortgages Pensions & Investments Limited ('MMPI'; 'the company') is an independent financial services company specialising in the provision of impartial advice on, and the processing of applications for, Mortgages, Life & Pension products, General Insurance, Savings & Investments, International Capital Markets' products, Stocks & Shares (and other investment instruments from time to time).

Bryan Moloney established the company in 1993 as an independent advisory service to companies and private clients. Its primary aim is to provide valued solutions in the areas of residential and commercial mortgages; corporate pensions and investment; personal finances and general insurance; wealth management and succession planning. In recent years, the company has broadened its services to include Treasury Consulting, Compliance Matters and Financial Services Training Programmes.

The company is not tied to any one financial institution for any product or service and is free to exercise impartial judgement on all products and services in the marketplace.

Authorisations & Affiliations
The company is regulated by the Financial Regulator under Regulation 11 of the European Communities (Markets in Financial Instruments) Regulation 2007, (MiFID Regulations).

The company is a member of the Irish Mortgage Advisors Federation and Irish Brokers Association.

Company employees hold individual memberships of the Institute of Bankers in Ireland; Life Insurance Association, Institute of International Trade of Ireland; Association of Compliance Officers in Ireland, Irish Association of Corporate Treasurers, Institute of Directors in Ireland and Insurance Institute of Ireland.

Commitment to Customer Care
The company conducts all of its business with clients, having due regard for both the letter and spirit of the Consumer Protection Code ('the Code') published by the Financial Regulator in August 2006 and to other regulatory guidelines issued from time to time.

The Directors, Management and Staff of the company are committed to ensuring that we;

act honestly, fairly and professionally in conducting our business activities in the best interests of our clients and the integrity of the market,

act with due skill, care and diligence in the best interests of our clients,

do not recklessly, negligently or deliberately mislead clients as to the real or perceived advantages or disadvantages of any product or service,

have, and employ effectively, the resources and procedures, systems and control-checks that are necessary for the proper compliance with the Code and other regulatory guidelines issued from time to time,

seek from our clients sufficient information relevant to the products or services requested or offered,

make full disclosure of all relevant material information, including all charges, in a way that seeks to inform our clients,

seek to avoid conflicts of interest and, when they cannot be avoided, ensure that our clients are fairly treated,

correct errors and handle complaints speedily, efficiently and fairly,

do not exert undue pressure or undue influence on our clients,

ensure that any outsourced activity complies with the requirements of the Code,

without prejudice to the pursuit of our legitimate commercial aims, do not, through our policies, procedures or working practices, prevent access to basic financial services, and comply with all regulatory requirements applicable to the conduct of our business activities so as to promote the best interests of our clients and the integrity of the market. The Directors, Management and Staff of the company are further committed to ensuring that we;

act to the best advantage of our clients,

and, having taken all relevant factors into account, recommend for each client the most suitable product(s) available in the market-place, regardless of whether or not we hold an appointment in writing from the relevant product producer(s),

comply with our regulatory requirements regarding all relevant circumstances of any transaction including without limitation:

a) the nature of the transaction; b) the price and availability of the product or service, where appropriate, together with the general condition of the market at the time; c) the services which we hold ourselves out as providing; d) all charges, which will be levied on the product or service concerned; e) the size of the order or instruction; f) the nature and extent of enquiries made by us with product producers and other professional bodies including, where applicable, market makers; g) the terms of the order including, where appropriate, the date and time of the order.

give adequate notice to affected client(s) if our services are withdrawn and ensure that all outstanding client business is properly completed.

Remuneration
The company offers its impartial and wholly independent advisory services and financial training programmes in return for fees and commissions. An outline of our fees is negotiated in advance with each client prior to the commencement of work on a particular service.

Our standard consultation fees are €250 (+VAT) per hour, reviewed annually. Ongoing fees may also be negotiated for protracted contracts.

For certain services, we receive business introductory commissions directly from product and service providers, such as banks, building societies, insurance companies, insurance underwriters, stockbrokers, etc. For example, the company may receive an introductory commission of up to 1% of the loan amount for mortgage business. In addition, the company may charge fees for certain insurance and investment business depending on the complexity of our client(s) requirements.

General Insurance is remunerated by commission and a service charge is levied. Fees are currently charged at up to 15% of the total premium per policy with a minimum charge of €20.00 per transaction. Where a fee is charged, this is stated on each individual invoice. No charge is levied for the handling of any claim where cover has been arranged by MMPI.

Conflicts of Interest
It is our policy to ensure that we serve our clients' interests at all times to the very best of our ability.

We are careful that our relationships with product and service providers, clients and other related parties are maintained on a professional basis.

Where conflicts of interests arise and are unavoidable, it is our policy to fully advise client(s) of our position and to offer alternative arrangements, where appropriate.

Where, with our clients' agreement, we proceed with a case entailing a conflict of interest the company is committed to ensuring that the clients' interests are safeguarded.

Complaints & Disputes
It is the stated policy of the company to deal with complaints, at source, in an expedient manner. Where this cannot be achieved, it is company policy to meet with the individual customer(s) to resolve matters. A copy of the company's Complaints Procedures is available on request.

Should the customer(s) be dissatisfied with the outcome of the company's investigations into the complaint, the matter may be referred to;

Financial Services Ombudsman Bureau, 3rd Floor, Lincoln House, Lincoln Place, Dublin 2 Tel. 1890 88 20 90 www.financialombudsman.ie

Consumer Directorate, Financial Regulator, PO Box 9138, College Green, Dublin 2 Tel: (01) 410 4000 Remedies on Default of Company Under Section 38(1) of the Investor Compensation Act, 1998, Moloney Mortgages Pensions & Investments Limited ('the company') ensures that in its terms of business or in any documentation, which may be used by the company, that we inform actual and intending clients of the following information concerning investor compensation:

a) that 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; b) that Moloney Mortgages Pensions & Investments Limited is a member of that compensation scheme; c) that compensation may be payable where money or investment instruments owed or belonging to clients and held, or in the case of investment instruments, administered or managed by the company, cannot be returned to those clients for the time being and there is no reasonably foreseeable opportunity of the company being able to do so; d) that a right to compensation will arise only: i) if the client is an eligible investor as defined in the Act; ii) if it transpires that the company is not in a position to return client money or investment instruments owed to or belonging to clients of the company; and, iii) to the extent that the client's loss is recognised for the purposes of the Act; e) that where an entitlement to compensation is established, the compensation payable will be the lesser of: i) 90 per cent of the amount of the client's loss, which is recognised for the purposes of the Investor Compensation Act, 1998; or ii) compensation of up to €20,000

Remedies on Default of Customer
Where a customer defaults owing monies to Moloney Mortgages Pensions & Investments Limited, it is the policy of the company to pursue matters directly with the client(s) in order to achieve a satisfactory resolution.

In cases where this approach proves unsuccessful, it is the policy of the company to pursue the outstandings through appropriate legal channels.

In respect of non-life insurance policies, premiums are due on or before the inception, the renewal or alteration dates. Failure to make payment in full will result in advising the insurer in question and cover may be cancelled "ab initio" or restrictions in cover may be imposed.

Bank fees charged on unpaid cheques will be charged to the client and are payable in full with all other outstanding balances. No agency transfer may be effected until the account is cleared in full

Custody Arrangements
It is the policy of Moloney Mortgages Pensions & Investments Limited ('the company') not to hold investment instruments, policy documentation, share certificates or other items of record in safekeeping for its clients, unless specifically requested to do so in writing by way of contract or formal agreement.

It is acknowledged that, in the normal course of business, certain documentation (e.g. policy documents, contract notes, share certificates, etc.) may be received by the company and held on file, for the customer, pending completion of the underlying transaction(s). On completion of such transaction(s), all documentation, which rightfully belongs to the customer, will, as a matter of course, be forwarded to the customer without delay.

All insurance policy documentation should be read thoroughly to ensure that the cover arranged is in accordance with the insurance requirements of the client. It is of vital importance that this documentation is retained safely as such documentation forms the basis of contract between insurer and the insured.

A summary of covers for a non-life client may be supplied. These summaries are not intended to be a definitive interpretation of the policy cover, terms and condition, reference should be made to the policy documentation issued by insurers.

Client Premium Handling
Cash and negotiable Instruments (cheques) payable to MMPI may be accepted in circumstances permitted by the Consumer Protection Code. A Section 30 receipt will be issued in all cases. The company cannot accept cash or negotiable instruments in any other circumstances.

Return premiums obtained, following a midterm alteration or cancellation of a policy will be refunded to the client within 5 working days of being received by MMPI. These amounts will be netted against any outstanding balances due and will be net of commission and any cancellation fee or charge.

Client premiums paid by credit/debit card or other electronic means are subject to a charge on each transaction made up of the fee levied by the service provider, if any, together with any additional handling charge and/or other service costs that may be applicable.

Credit Terms - Client Premiums
The company is obliged under its regulatory status, to operate a strict credit control policy. Premiums must, therefore, be paid in full, on or before the renewal, inception or alteration date of the cover. In order to protect the interests of our clients, MMPI is prohibited from paying any premiums to Insurers, which have not first been paid to MMPI.

The company can, where circumstances permit, arrange suitable premium finance with an approved institution, subject to the terms and conditions imposed by the finance provider, a fee may be levied for this service.

Regulatory Requirements
Subject to the Supervisory & Reporting Requirements & Conditions of the Financial Regulator, Moloney Mortgages Pensions & Investments Limited is obliged to ensure that it has sufficient management resources to effectively conduct its business and to adequately reflect the risks associated with the company's business objectives.

The company is also required to have in place appropriate control systems and accounting records to facilitate the effective management of the business.

Promoters' Agreements
In addition to maintaining business arrangements with many of the Irish financial institutions, the company has also negotiated Promoters' Agreements with several leading international banks and insurance companies in London and Europe.