Client Terms of Business and Management Agreement

a. Overview

These terms and conditions of business ("ACCL Terms and Conditions of Business"), together with the Application Form(s), Suitability Report and Fee Schedule constitute the contract between you and us for the provision of your Account and related Services (together referred to as this "Agreement"). This Agreement represents the entire agreement between the Client and us, superseding any prior documents, communications, or understandings.

This Agreement shall take effect from the date of signing and shall remain in force until amended.

It is important that you review this Agreement carefully as it sets out the framework within which Andrew Caddick Consulting Limited ("ACCL") will operate and our objectives in acting for you. Both you and we are bound by this Agreement; it governs our relationship and services in general. Should there be any aspect of this Agreement that you find unclear or disagree with, please contact us promptly via telephone at +350 200 67469, by post at ACCL, 3.3 Madison Building, Midtown, Gibraltar, GX11 1AA or alternatively, you can reach out to our Head of Investments, Andrew Caddick at

This Agreement should be read alongside any other product or service documentation provided to you, as certain products and services may have additional and specific terms and conditions.

ACCL reserves the right, at all times and at our absolute discretion, to decline providing Services or opening an Account, or to terminate this Agreement in accordance with paragraph 8 below.

Please read this Agreement carefully and keep it for your records.

b. Legal status

General information about Andrew Caddick Consulting Limited (ACCL)

ACCL is a limited liability company incorporated in Gibraltar. Our registered office is at Portland House, Glacis Road, Gibraltar, GX11 1AA or as notified from time to time. Our registered company number is 121678 The other address at which we conduct business is at 3.3 Madison Building, Midtown, Gibraltar, GX11 1AA.

We are authorised and regulated by the Gibraltar Financial Services Commission (the “GFSC”) to provide Investment and Pension Adviser Services under Part 7 of the Financial Services Act 2019 (“FSA 2019”) and we are listed on the GFSC's register under number 29519. You can verify this information on the GFSC's register by visiting their website at or by contacting the GFSC at +350 200 40283. ACCL is a member of the Gibraltar Investor Compensation Scheme (GICS).

c. Contact Details

Address: ​​​ACCL, 3.3 Madison Building, Midtown, Gibraltar GX11 1AA

Telephone Number: ​+350 200 67469

Email: ​​​

Terms and Conditions

1. Terms and Conditions

1.1​ The ACCL Terms and Conditions of Business together with Application Form(s), Suitability Report and Fee Schedule constitute the contract between you and us for the provision of your Account and related Services (together referred to as this "Agreement").

1.2 Unless we provide you with written notification to the contrary, our Services are offered to you on the basis that you are a Retail Client. As a Retail Client, you are entitled to the highest level of protection available under the Gibraltar Financial Services legislation. However, you have the option to request to be classified as a Professional Client for all the Services we provide to you, or for a specific product or service, provided you meet certain criteria. This reclassification would result in a reduced level of protection for you as a client. Our Client Categorisation Policy is accessible upon request. In the event that we inform you of our decision to treat you as a Professional Client, you have the right to request to revert to being treated as a Retail Client for all the Services we offer you or for a specific product or service. Please note that we retain the discretion to reject any such re-categorisation request. We reserve the right, at our absolute discretion, to decline providing Services or opening an Account.

2 Effective Date

2.1 This Agreement shall come into effect on the date of signature.

3 Services

3.1​ ACCL is authorised and regulated by the GFSC to provide Investment and Pension Adviser Services under Part 7 of the FSA 2019. These permissions enable ACCL to conduct the following regulated activities as described in Schedule 2 to the FSA 2019:

Paragraph No.

Regulated Activity


Reception and transmission of orders in relation to one or more financial instruments


Execution of orders on behalf of clients


Portfolio Management


Investment advice to institutional and retail clients


Advising on personal or occupational pension scheme

3.1 ACCL is not authorised and regulated to provide custody services to you or to hold your money.

3.2 For discretionary managed customers: We will offer investment management services to you. This entails managing your portfolio on your behalf and having full discretion over the portfolio to make investment decisions based on your specified investment objectives and risk profile. We will possess complete authority, at our discretion and without prior consultation with you, to engage in any transactions or arrangements that we consider appropriate for your account.

3.3 For non-discretionary managed customers: We will provide investment management advice services to you based on your risk profile and investment objectives, ensuring that any proposed changes to your fund are approved and understood by you.

3.4 For advisory investment managed customers: We will offer investment advisory services to you. Our recommendations will be based on your specified investment objectives and risk profile. We take responsibility for ensuring the suitability of our recommendations and will evaluate their appropriateness for your overall portfolio. You maintain full control and accountability for all investment decisions, including the choice not to act on any recommendation we provide.

3.5 In the event that you opt for a transaction different from our recommendation, we will clarify the risks and reasons why the transaction does not align with our advice before proceeding with instructions regarding that investment.

4 Client Money

4.1​ ACCL will not accept or handle cash under any circumstances. Any funds intended for your transactions pursuant to this Agreement must be transferred to the Custodian.

5 Fees and Charges

5.1 Our fees for the Services, along with any transactional charges incurred under this Agreement, will be applied in accordance with the rates outlined in the Fee Schedule (subject to amendments) or as mutually agreed upon. The relevant Fee Schedule pertaining to the agreed Service should be reviewed alongside these ACCL Terms and Conditions of Business, forming an integral part of this Agreement.

5.2 Prior to the provision of Services, all associated fees and charges will be discussed and agreedupon with you.

6 Gibraltar Investor Compensation Scheme

6.1​ We are a member of the Gibraltar Investor Compensation Scheme (GICS), which means you may be entitled to compensation from the scheme if we cannot meet our obligations. For more information about compensation scheme arrangements, you can contact the GICS directlyor visit their website

7 Cancellation and ending this relationship

7.1 You have the right to cancel this Agreement within 14 days of entering into it, or from the date we furnish you with the terms and conditions relevant to the services, by serving written notice to us. Should you choose to exercise your cancellation right appropriately, we will discontinue the provision of our Services to you and terminate this Agreement. It is important to note that suchcancellation will not impact Services that have already been provided or are in progress, and you will be responsible for any fees and charges accrued from services rendered and transactions already initiated.

7.2 You have the right to cancel any ongoing advisory service or any other ongoing service that involves us providing you with personal recommendations. A 30-day notice of cancellation is required, and our pertinent ongoing Services will cease at the conclusion of the notice period. We

reserve the right to impose a fee for ongoing advisory services rendered up to the date of cancellation.

8 Termination

8.1​ You have the right to terminate this Agreement by providing immediate written notice to us, or upon our receipt of a written request from you to transfer your portfolio to another broker. Generally, we will terminate this agreement by giving you 30 days' advance written notice. However, we reserve the right to terminate this Agreement immediately if we have a valid reason to do so, including but not limited to:

• Receipt of notice of your death or legal incapacity;• Your bankruptcy, insolvency, or inability to meet your financial obligations as they become due, or if we have reasonable grounds to believe you may not fulfil your obligations under the Agreement;• Serious or persistent breach of this Agreement by you;• Provision of false or misleading information by you;• Reasonable suspicion of fraudulent or unlawful behaviour, or breach of any applicable laws or regulations related to the matters covered by this Agreement;• Providing services under this Agreement would put us in violation of any laws or regulations, or subject us to action from government, regulatory, or law enforcement authorities.

8.2​ Termination will be without prejudice to the completion of transactions already initiated, which will be carried out in accordance with the terms of this Agreement, as promptly as possible, unless otherwise mutually agreed upon in writing. You will be responsible for any transactions executed before termination and any outstanding fees.

9 Complaints

9.1​We place significant importance on addressing complaints and have implemented procedures in line with the GFSC regulations for the fair and prompt handling of complaints. Our written Complaints Policy is accessible upon request. Should you wish to lodge a complaint, you can approach your regular point of contact, or reach out to our compliance officer at 3.3 MadisonBuilding, Midtown, Gibraltar, GX11 1AA. Alternatively, you may contact us via email at

10 Recommendations

10.1 We will offer investment management and advisory services to you, providing recommendations in writing based on your specified investment objectives and risk tolerance. The method of evaluation will be confirmed to you in the suitability report setting out our recommendation, rationale, risk profile and supporting documentation including fees.

10.2 We take responsibility for the suitability of our recommendations and will evaluate their appropriateness for your overall portfolio. While you have full control and responsibility for all investment decisions, including choosing not to follow our recommendations, we will explain the risks and rationale if you opt for a different transaction than our recommendation. However,please note we may not be able to assist with your direction if you have not been accurately classified as having suitable investment knowledge. Prior to accepting instructions related to such investments, we will clarify why the proposed transaction deviates from our recommendation and the available options open to you.

11 Code of Conduct and Ethics

11.1 ACCL prides itself on high ethical values dealing with all clients, banks, intermediaries, suppliersand other businesses with honesty, integrity and respect. ACCL upholds a zero tolerance ofbribery, corruption and other dishonest business practices.

11.2 Our Code of Conduct and Ethics Policy applies to all individual directors, officers and employeesof ACCL. Our reputation is of utmost importance and this reflects in the attitudes and the behaviour of each member of the team both in and out of the office. All individuals should conduct their affairs with fairness, honesty and integrity. Individuals should apply the same personal ethics in the workplace, treating fellow employees, clients, suppliers and all other third parties as individuals with the respect they deserve.

11.3 At ACCL, we strictly follow a code of professional conduct and adhere to the Gibraltar Financial Services (Investment Services) Regulations 2020, the FSA 2019, as well as all relevant laws, regulations, and professional standards. The following points outline our business principles:

• We will carry out our business fairly, honestly and openly • We will not make bribes, nor will we condone the offering of bribes on our behalf, so as to gain a business advantage • We will not accept bribes, nor will we agree to them being accepted on our behalf in order to influence business • We will avoid doing business with others who do not accept our values and who may harm our reputation • We will set out our policies and procedures in accordance with our values • We will keep clear and updated records • We will ensure that everyone in our business and our business partners are aware of ourPrinciples• We will regularly review our policies and procedures

12 Best Execution

12.1 ACCL has a regulatory obligation to consistently undertake all necessary measures to achieve the best possible result in terms of price, product selection, transaction charges, administration, and service quality. This obligation is in effect whenever ACCL initiates an order with, or forwards an order to, the Custodian or a third party for execution.

12.2 In doing so ACCL considers the various factors outlined below in order of precedence;

• Price to the client• Reasonable costs and charges to the client• Speed of service and execution of the client's business• Effective administration of where the Company places the client's business• Size and nature of the transaction

• The nature and procedures of the provider chosen and• Any other factors relevant to the execution of the client's transaction.

12.3 ACCL will only override the price and cost factors mentioned above if it may assist in delivering the best possible result for the client's specific current needs and circumstances.

12.4 In addition, ACCL will also take into consideration;

• The client's categorisation and how this affects the client

• The nature and characteristics of the client's transaction

• Where the client's transaction can be directed

• Any specific instructions the client gives the Company, whether received on an individual basis or as a general instruction to be applied to all of the client's transactions

12.5 If you would like to review our Best Execution Policy in its entirety, please reach out to us at

13 Data Protection

13.1 ACCL places utmost importance on respecting your right to privacy. All personal information provided by you or third parties and/or ACCL will be handled in compliance with relevant dataprotection and privacy laws in effect in Gibraltar, including the Gibraltar Data Protection Act 2004 and the Gibraltar General Data Protection Regulation (GGDPR) as amended, along with other applicable legislation and regulatory requirements concerning the use of Personal Data, including without limitation the privacy of electronic communications.

13.2​ Personal data refers to information that can directly or indirectly identify you. At ACCL, we are dedicated to processing your personal data in alignment with Gibraltar data protection laws. ACCL is recognised as the data controller under Gibraltar data protection laws. It may be necessary for you to provide us with personal data to facilitate the provision of requested products and services, fulfil any contractual obligations, inform you about our services, comply with relevant laws, regulations, and/or codes of practice, and for other purposes outlined in this notice that are in our legitimate interests.

13.3 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, any previous names, username or similar identifier, nationality and immigration status from passport or other identification, marital status, title, date of birth and gender.

Contact Data includes residential address, email address and telephone numbers.

Financial Data includes bank account details.

Tax Data includes National Insurance or Social Security Number and tax details.

Employment Data includes employment status and details including salary and benefits.

13.4 We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' usage data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering. Please contact our data protection officer at for further information.

14.​Anti-Money Laundering Countering the Financing of Terrorism and Proliferation

14.1​ ACCL is committed to full compliance with the Proceeds of Crime Act 2015, which serves as the primary authority in Gibraltar governing the enforcement of Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Countering Proliferation Financing (CPF) measures by businesses and individuals operating in Gibraltar. Additionally, we are committed to adhering to all other relevant laws and regulations concerning money laundering, terrorism financing, and proliferation financing.

14.2​ ACCL holds specific responsibilities to conduct enquiries and obtain documentation to authenticate the identity of customers upon engagement and throughout the course of any business relationship. Customers may be required to furnish additional pertinent information as per these laws and regulations, which could involve establishing the source of wealth and source of funds. By providing information, you affirm its accuracy and consent to ACCL sharing such information as necessary to fulfil our legal or regulatory obligations. Alternatively, ACCL may utilise electronic data reference sources to access information electronically stored about a customer's identity, including data held by government, consumer, and fraud prevention agencies. Upon completing the relevant forms or entering into an agreement with ACCL, you acknowledge that ACCL may, at any time, initiate electronic searches to prevent money laundering, fraud, terrorist financing, and verify the identity of relevant individuals. All checks must be successfully completed before ACCL can accept assets or conduct transactions on your behalf. ACCL retains the right to decline certain services or block a transfer if there are suspicions of any connection to money laundering, fraud, terrorist financing, or other criminal activities.

15.​Conflicts of Interests and disclosure of material interest

15.1​ In accordance with the rules set forth by the GFSC and ACCL's conflicts of interest policy, we have established procedures to identify, prevent, and manage conflicts of interest that may arise among ourselves or our employees and our clients, among our various clients, and between our third-party service providers and our clients.

15.2​ For any transaction we undertake or arrange on your behalf, there is a possibility that we may have a material interest, relationship, arrangement, or duty that could present or potentially create a conflict of interest with your interests concerning the investment or transaction in question, or the investments or assets associated with or derived from such investments. We are committed to ensuring equitable treatment for you in all such transactions and will diligently identify, prevent, or manage any conflicts of interest in accordance with our conflicts of interest policy.

15.3 We may, in accordance with applicable laws, participate in training events sponsored and/or conducted by product providers, fund managers, platforms, or other third parties. Any non-monetary benefit received from, or provided to, a third party is intended to enhance the quality of service delivered to you, must not compromise our regulatory obligations to you, and will be disclosed to you in advance.

16. Communication with You

16.1 Unless you inform us otherwise, we will communicate with you via telephone calls, video calls, post, email, or in person. In specific situations, we may request written confirmation of any instructions before execution.

17. Liability

17.1 ACCL, along with its directors, officers, or employees, shall not be held liable for any losses suffered by you directly or indirectly as a result of or in connection with the Services provided under this Agreement save for this Agreement does not exempt or limit (i) ACCL's liability in cases of negligence, fraud, wilful default, or a material breach of the Agreement, or (ii) any liability that ACCL may have towards you under applicable laws or regulations.

17.2 Our liability to you will be restricted to losses directly related to the specific incident prompting your claim against us. ACCL will not be responsible for any loss of profit, business revenue, anticipated savings, missed opportunities, or any indirect, special, exemplary, punitive, or consequential losses arising from this Agreement.

17.3 ACCL will not be held liable for any losses stemming from the performance of investments within the Service we offer you. It is important to understand that investment values can fluctuate, potentially resulting in a return that is less than your initial investment.

18. General

18.1 Jurisdiction

18.1.1​This Agreement is provided in English, and all communication related to our agreement will be conducted in English. The terms of the Agreement and the relationship established by it shall be governed by the Laws of Gibraltar and subject to the exclusive jurisdiction of the courts in Gibraltar.

18.2 Force majeure

18.2.1​Unless otherwise stipulated by legislation, we shall not be held liable to you or considered in breach of our agreement in the event of total or partial failure to perform our duties and obligations due to circumstances of Force majeure beyond our control.

18.3 Performance, associated risks and benchmarking

18.3.1 The services offered to you under our agreement may entail unique risks associated with their distinctive characteristics or may be subject to price fluctuations in financial markets beyond our influence. Past performance should not be considered indicative of future performance, and prices can move in either direction.

18.3.2 Assessing the relative risk is subjective and may evolve over time in reaction to particular events or updated social and economic projections. Establishing precise guidelines for measuring risk or predicting the potential impact, whether positive or negative, on an investment portfolio is not feasible.

18.3.3 The role of a benchmark is to serve as a reference point for clients’ portfolios. It does not guarantee that your portfolio will mirror the performance of the selected benchmark or adhere strictly to its allocation. The benchmark is intended to aid you in evaluating your portfolio’s performance. It does not imply that your portfolio will be constructed based on the investments comprising the benchmark indices, or that it will necessarily align with their asset allocation or performance.

18.4 Legal and tax advice

18.4.1 We do not offer legal or tax advice, and we are not legal or tax advisers. It is recommended that you seek independent legal or tax advice tailored to your specific circumstances. Relying on any information provided by us should not be considered a substitute for seeking your own independent legal or tax advice.