TERMS OF BUSINESS

RIGHT TO WITHDRAW

In the case of a non packaged product ISA or PEP recommended we will inform you in writing of any right to withdraw or cancel you may have or, if it is the case, we will inform you in writing that no such rights will apply.

In most cases you can exercise a right to cancel, by withdrawing from the contract recommended to you.  In general terms you will normally have a 30 day cancellation period for a life, pure protection, payment protection or pension policy and a 14 day cancellation period for all other policies. In most instances, you will not be able to exercise a right to cancel a mortgage contract, unless the contract is concluded at a distance (i.e. no face to face advice), at which point you may have a 14 day cancellation period. The start of the cancellation period will normally begin, for pure protection policies, when you are informed that the contract has been concluded or, if later, when you have received the contractual terms and conditions. In other cases, the cancellation period will begin on the day the contract is concluded or, if later, the day on which you receive the contractual terms and conditions. Instructions for exercising the right to cancel, if applicable, will be contained in the relevant product disclosure information which will be issued to you.If you cancel a single premium contract, we may require you to pay for any loss you might reasonably incur in cancelling it which is caused by market movements.  This means that, in certain circumstances, you might not get back the full amount you invested if you cancel the policy.

CLIENTS RISK

You are advised that because investments can fall as well as rise, you may not get back the full amount invested. Past performance is not necessarily a guide to future performance.  Specific warnings relevant to the investments, or investment strategies, we recommend will be confirmed to you in your Suitability Report.

DISCLOSURE OF CLIENTS PERSONAL DATA

The information you have provided is subject to the Data Protection Act 1998 (the “Act”).   Once you proceed by requesting advice from us you consent to us or any company associated with us processing, both manually and by electronic means, your personal data for the purposes of providing advice, administration and management.  “Processing” includes obtaining, recording or holding information or data, transferring it to other companies associated with us, product providers, the FSA or any other statutory governmental or regulatory body for legitimate purposes including, where relevant, to solicitors and/or other debt collection agencies for debt collection purposes and carrying out operations on the information or data. Product Providers, Lenders and Investment Managers may administer your policy, any existing policies you may have with them and provide other services, from centres in countries outside Europe (such as India and the USA) that do not always have the same standard of data Protection laws as the UK. However, they are required to put a contract in place to ensure that your information is adequately protected, and they will remain bound by their obligations under the Data Protection Act even when your personal information is processed outside Europe.

The information provided may also contain sensitive personal data as detailed by the Act.

You may be assured that we and any company associated with us will treat all personal data and sensitive personal data as confidential and will not process it other than for a legitimate purpose.  Steps will be taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary.  Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to the data.  Subject to certain exceptions, you are entitled to have access to your personal and sensitive personal data held by us.  ELCC does not sell data to any third party organisation, such as insurance companies and fund managers for the purpose of marketing our clients.  If at any time you wish us to stop processing your data (or not to start) please write to us at the above address and we will cease immediately.

PAYMENT FOR SERVICES

We normally derive our income from commission paid to us by life assurance companies and the operators of collective investment schemes through which investments are made.  We shall tell you the amount of commission payable to us on any such investment.  If we receive a commission or other form of benefit from the issuer of a security or from another intermediary, we will inform you, but we will not tell you its amount unless you ask us to do so. Alternatively, if you or we propose to operate on a fee basis, we will agree its basis, frequency and method with you in writing before we carry out any chargeable work.  Should we receive commission from any third party in relation to transactions arranged for you, we will offset the amount received against any fees due.

ACCOUNTING TO YOU

Unless in exceptional circumstances, we will confirm to you in writing the basis or our reason for recommending the transaction executed on your behalf.  In executing or transmitting orders on your behalf to third parties, we will take all reasonable steps to ensure that we obtain the best possible result for you in terms of best execution.  We will also make arrangements for all your investments to be registered in your name unless you first instruct us otherwise in writing. We will forward to you all documents showing ownership of your investments as soon as practicable after we receive them; where a number of documents relating to a series of transactions is involved, we will normally hold each document until the series is complete and then forward them to you.

INVESTMENT OBJECTIVES & RESTRICTIONS

Following the issue of this letter any subsequent advice or recommendation offered to you will be based on your stated investment objectives, acceptable level of risk and any restrictions you wish to place on the type of investments or policies you are willing to consider. Details of your stated investment objectives will be included in the suitability letter we will issue to you to confirm our recommendation. Unless confirmed in writing, to the contrary, we will assume that you do not wish to place any restrictions on the advice we give you.                                                                              

 12March 2008 (V2)