Contents

Treating Customers Fairly

Data Protection

Email

Complaints

Financial Services Compensation Scheme

Insider Lists

Stewardship

Treating Customers Fairly

FCA Principle 6 sets out the high level standard for how a firm should treat its customers. The Board and Senior Management fully support the TCF initiative and continuously strive to ensure it is embedded throughout the Group. Ensuring that we treat our customers fairly is very important to us and our employees are required to bear this in mind in the day to day performance of their duties and apply it appropriately to our retail and professional clients.

Data Protection

Information Commissioners Office (ICO) Registration Number (Z5442086). Our Privacy Notice can be found here.

Email

Any electronic communications that are sent to or received from clients or any third parties should be transmitted only through a valid WHI email address; this measure ensures that the communication passes through WHI servers, is scanned for viruses and is recorded.

Complaints

WH Ireland Limited (the Firm) is committed to ensuring that all complaints received are handled fairly, consistently and promptly and that the firm identifies and remedies any recurring or systematic problems, as well as any specific problem identified by a complainant. If you have a complaint, you can email us at compliance@whirelandplc.com.

For the purposes of the Financial Conduct Authority’s (FCA) requirements on complaints procedures a complaint is any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of a person about the provision of, or failure to provide, a financial service or redress determination.

A complaint must involve an allegation that the complainant has suffered (or may suffer) financial loss, material inconvenience or material distress.

An eligible complainant is one who is, or was a customer of the Firm. The Firm will endeavor to resolve a complaint at the earliest possible stage and all complaints should be referred to the Head of Compliance. Should a complaint not be resolved to the satisfaction of the complainant, the complainant may be entitled to refer the matter to the Financial Ombudsman Service (FOS).

The FOS is an agency for arbitrating on unresolved complaints between regulated firms and their clients. Full details of the FOS can be found on its website at www.financial-ombudsman.org.uk. The Firm will cooperate fully with the FOS in the handling of any complaints.

Financial Services Compensation Scheme

As an authorised firm, investors are likely to be covered by the provisions of the Financial Services Compensation Scheme (FSCS), if WH Ireland ceases trading. It can award up to £50,000 in compensation to any one investor where they decide that an investment business is in default and is unable to satisfy any claims against it. In addition, if one of the banks which we use for depositing cash balances is declared in default, each individual is entitled to 100% of the first £85,000 in total in compensation for losses across all their deposits with that institution. Full details of the FSCS detailing the restrictions and financial limits that apply are available on request from the FSCS. You can contact them on 020 7741 4100 or 0800 678 1100 or at www.fscs.org.uk. You can also write to them at FSCS, 10th Floor, Beaufort House, 15 St Botolph Street, London EC3A 7QU.

Insider Lists

This section of our website sets out the arrangements operated by WH Ireland Limited in relation to Article 18 of the Market Abuse Regulation (2014/596) and EU Commission Implementing Regulation (2016/347) (the Insider List Rules). These arrangements shall be operated whenever we act on behalf of a client who is subject to the Insider List Rules in relation to information to which the firm has access and which the firm has been informed is inside information for the purposes of the Insider List Rules (Inside Information).

The firm will maintain lists as required by the Insider List Rules of persons working for WH Ireland Limited on behalf of a client, or third parties, wall crossed under the safe harbour of Article 11 of the Market Abuse Regulation (2014/596), (market soundings), who have access to Inside Information. The Insider Lists shall contain the information required by the Insider List Rules and will be updated as required by those rules and kept for the period required by those rules.

The firm will maintain information in accordance with the relevant data protection laws including General Data Protection Regulation (EU) 2016/679 (GDPR), and will only ever pass on information contained in the Insider List in circumstances where there is a legal requirement therefore upon request the firm will provide Insider Lists to the Financial Conduct Authority (“FCA”) (or other relevant EEA authority) pursuant to the Insider List Rules.

The firm takes the necessary measures to ensure that every person whose name is on an Insider List acknowledges the legal and regulatory duties entailed and is aware of the sanctions attaching to the misuse or improper circulation of Inside Information. These measures include appropriate training of all staff.

Stewardship

FCA-authorised firms which manage investments for professional clients that are not natural persons must disclose on their website the nature of their commitment to the Financial Reporting Council’s Stewardship Code (‘Code’); or where they do not commit to the Code, their alternative investment strategy.

Adherence to the Code is voluntary. Whilst WH Ireland Limited supports the objectives of the Code, it does not consider it appropriate to commit to any particular voluntary code of practice that relates to only one jurisdiction. In addition, WH Ireland Limited principally manages investments for retail clients and natural persons, so the Code is not targeted at our business. Furthermore, the issues raised in the Code are largely dealt with by other obligations upon WH Ireland Limited, including under the FCA Rules and our Client Terms and Conditions.

WH Ireland Limited has well-established and robust conflicts of interest policies and procedures.

We periodically review our approach to the Code and will update this statement as necessary.

To find out more call us on +44 (0)20 7220 1666