Terms of Business

Croucher Durkan LTD trading as Secure Financial.

These Terms of Business set out the general terms under which our firm will provide business services to you and the respective duties and responsibilities of both the firm and you in relation to such services. Please ensure that you read these terms thoroughly and if you have any queries we will be happy to clarify them. If any material changes are made to these terms we will notify you.

Authorisation with the Central Bank of Ireland

Secure Financial is regulated by the Central Bank of Ireland as an Investment Intermediary authorised under the Investment Intermediaries Act, 1995; and insurance intermediary registered under the European Communities (Insurance Mediation) Regulations, 2005. Copies of our regulatory authorisations are available on request. The Central Bank of Ireland holds registers of regulated firms. You may contact the Central Bank of Ireland on 1890 777 777 or alternatively visit their website at www.centralbank.ie to verify our credentials. Our Authorisation reference is 388759

Codes of Conduct

Secure Financial is subject to the Consumer Protection Code, Minimum Competency Code and Fitness & Probity Standards which offer protection to consumers. These Codes can be found on the Central Bank’s website www.centralbank.ie

Our Services

Secure Financial are multi agency intermediary, authorised to provides life assurance, pensions, investments, listed shares and bonds and deposit products on a fair analysis basis i.e. providing services on the basis of a sufficiently large number of contracts and product producers available on the market to enable us to make a recommendation, in accordance with professional criteria, regarding which contract would be adequate to meet the your needs.

Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life, pensions, Investments, Listed Shares and Bonds and deposit products. A full list of insurers, product producers with which we deal is available on request. Secure Financial is a member of Brokers Ireland.

We provide advice on the following product providers:

Irish Life Assurance plc

New Ireland Assurance Co plc

BCP Asset Management DAC

Zurich Life Assurance plc

Friends First Life Assurance DAC

Wealth Options Ltd

Aviva Life and Pensions

Cantor Fitzgerald Ireland Ltd

Royal London

Independent Trustee Company Ltd

We will provide assistance to you for any queries you may have in relation to the policies or in the event of a claim during the life of the policies and we will explain to you the various restrictions, conditions and exclusions attached to your policy. However, it is your responsibility to read the policy documents, literature and brochures to ensure that you understand the nature of the policy cover; particularly in relation to PHI and serious illness policies.

Specifically on the subject of permanent health insurance policies it is our policy to explain to you a) the meaning of disability as defined in the policy; b) the benefits available under the policy; c) the general exclusions that apply to the policy; and d) the reductions applied to the benefit where there are disability payments from other sources.

For a serious illness policy, we will explain clearly to you the restrictions, conditions and general exclusions that attach to that policy.

Disclosure of Information

Any failure to disclose material information may invalidate your claim and render your policy void.

Remuneration Policy

Secure Financial is remunerated by commission and other payments from product producers on the completion of business. You may choose to pay in full for our services by means of a fee. Where we receive recurring commission, this forms part of the remuneration for initial advice provided. We reserve the right to charge additional fees if the number of hours relating to on-going advice/assistance exceeds 4 hours.

In certain circumstances, it will be necessary to charge a fee for services provided. These are listed below for life, pensions & investments, non-life business and Standard PRSAs. In other circumstances where fees are chargeable or where you choose to pay in full for our service by fee, we will notify you in writing in advance and agree the scale of fees to be charged if different from fees outlined below.

If we receive commission from a product provider, this may/will be offset against the fee which we will charge you. Where the commission is greater than the fee due, the commission may become the amount payable to the firm unless an arrangement to the contrary is made.

You may elect to deal with us on a fee basis. (It is common to distinguish on the basis of the seniority of the person and between advisers and support staff.)e.g.:

Principles / Directors € 220.00 per hour

Senior Advisers € 200.00 per hour

Associates € 125.00 per hour

Support staff € 100.00 per hour

Regular Reviews

It is in your best interests that you review, on a regular basis, the products which we have arranged for you. As your circumstances change, your needs will change. Please advise us of those changes and request a review of the relevant policy so that we can ensure that you are provided with up to date advice and products best suited to your needs. Failure to contact us in relation to changes in your circumstances or failure to request a review, may result in you having insufficient insurance cover and/or inappropriate investments.

Conflicts of interest

It is the policy of our firm to avoid conflicts of interest in providing services to you. However, where an unavoidable conflict of interest arises we will advise you of this in writing and allow you the time to decide if you wish to proceed. A full copy of our conflicts of interest policy is available on request.

Complaints

Whilst we are happy to receive verbal complaints, it would be preferable that any complaints are made, in writing. If complaints are not in writing we will write to you to confirm our understanding of your verbal complaint.

All complaints should be made in writing and addressed to: Gerry O’Dea, Secure Financial, 41 Cecil Street, Limerick

We will acknowledge your complaint within 5 business days and we will fully investigate it. We shall investigate the complaint as swiftly as possible, and, the complainant will receive an update on the complaint at intervals of not greater than 20 business days starting from the date on which the complaint is made.

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 and Pensions Ombudsman (01-5677000). A full copy of our complaints procedure is available on request.

Data Protection

Secure Financial complies with the requirements of the General Data Protection Regulation 2018 and the Irish Data Protection Act 2018.

Secure Financial is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.

The data will be processed only in ways compatible with the purposes for which it was given and as outlined in our Data Privacy Notice, this will be given to all our clients at the time of data collection.

We will ensure that this Privacy Notice is easily assessible. Please refer to our website secure financial.ie, if this medium is not suitable we will ensure you can easily receive a copy by hard copy.

Please contact us at dataprotection@securefinancial.ie if you have any concerns about your personal data.

Investor Compensation Scheme

We are members of the Investor Compensation Scheme operated by the Investor Compensation Company Ltd.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.

The Investor Compensation Company Ltd. (ICCL) was established under the 1998 Act to operate such a compensation scheme and Secure Financial 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 Secure Financial cannot be returned to those clients for the time being and where there is no reasonably foreseeable opportunity of Secure Financial being able to do so.

A right to compensation will arise only:

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

▪ If it transpires that Secure Financial is not in a position to return client money or investment instruments owned or belonging to the clients of Secure Financial; 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) 224 4955.