1.What is the purpose of this document? The Financial Conduct Authority (FCA) is the independent watchdog that regulates financial services. The FCA has asked us to provide this important information to help you decide if our products and services are right for you. It identifies key features about our services and how you will pay for them. It does not contain all the features of our services. More detailed information can be found on our website in the Terms of Business document appropriate for each of our services and in the key features and Key Investor Information documents for funds and our SIPP. Please read this document carefully and keep it for future reference. 2.What services does Bestinvest offer? a) Service choices i) Bestinvest Online Investment Service The Bestinvest Online Investment Service is an online, execution-only investment service where you make your own decisions about the investments that you buy and sell. Using our Bestinvest Online Investment Service, you can currently buy and sell online any combination of the investment types available through our services. You will not receive personal investment advice based on your circumstances as part of this service. We provide research, information about investments and tools to make it easier for you to make your own investment decisions. If you are unsure about the suitability of an investment please contact us to ask about our advisory services. IFSL funds: we manage a range of funds structured as OEICs (Open- Ended Investment Companies). These provide a simple and convenient way of accessing our active approach to asset allocation using a carefully blended selection of investments. You can find further information on these funds on our website or by contacting our client services team. Investment Management and Advisory Services We also offer a range of managed and advisory solutions designed to suit different needs: Investment Advisory Service: we will recommend a selection of investments that is designed to match the Bestinvest asset model that has been agreed with you. Managed Portfolio Service: we will manage on a discretionary basis an investment portfolio that has been recommended to you by one of our investment managers Investment Management Service: this service offers discretionary management of a bespoke investment portfolio. We will provide you with the features of these services (as contained in our 'Key facts about our services and costs - Advised services' document) separately if you decide to avail them. i Financial Planning The Bestinvest service may also include advice under its Wealth Management Service. This is provided by Bestinvest (Consultants) Limited and we will provide you with the features of this service separately if you decide to avail of it. b) Investment types Each of our services can involve one or more of any of the following investments: Units and shares in collective investment schemes (funds); Shares in UK listed companies; Exchange Traded Funds (ETFs); and Investment trusts. Other products will be made available, as required, during the course of you holding an account with us. c) Account types In order that you can manage your money and, should you wish, take advantage of the tax benefits that are normally available with ISAs and SIPPs, each of our services enables you to have up to three different types of account: i) Investment Account: we open an Investment Account for all clients using any of our services. This account enables you to invest money in any of the investments offered by our services and hold cash. This is also the account from which we may deduct any fees or charges arising from any of your accounts that are not covered by product charges. ISA Account: this account is for investments that you wish to hold in our stocks and shares Individual Savings Account. We also offer Junior ISAs. i SIPP Account: this account is for investments that you wish to hold within our Self-Invested Personal Pension Account. 1 of 8
3.Whose products do we offer for our? The services provided by Bestinvest (Brokers) Limited in these Key Facts are predominantly investment products (funds, shares and investment trusts). Custody of your investments will either be with SEI or another provider ( Third Party Platform ), as detailed in your account opening documentation. Typically, the ISA offered by our services is managed by Bestinvest (Brokers) Limited and the trustee and scheme administrator for our SIPP, known as The Best SIPP, is EBS Management plc. Where custody is provided by a Third Party Platform we may also utilise other ISA managers and SIPP providers/administrators when providing our services to you; this will be made clear to you before you invest. 4.What will you have to pay us for our services? a) Charges that apply to all services: Charges applied by the Funds:- i) Initial charge: for most funds offered by us through our services there is no initial charge our website will confirm this, or tell you before you buy it if an initial charge applies. Ongoing Charge Figure (OCF): this is the Fund managers annual management charge, plus additional third party costs and is taken annually by the fund manager from the value of the fund and for new purchases will normally be around 0.9% for equity funds, 0.3% for tracker funds and 0.6% for bond funds (although it could be higher or lower than this, as it is not set by us, but by the fund provider). For funds purchased historically, some fund managers charge a higher OCF but use part of it to pay Bestinvest an annual commission. Typically the commission is 0.5% a year but it can be anything between zero and 1% a year. We will rebate any commission we receive to you in full. i Stamp Duty Reserve Tax: this is currently 0.5% and applies to purchases of mainland UK registered companies that are UK listed (this does not apply to ETFs, OEICs, gilts, debentures, loan stock and Offshore companies, such as Guernsey registered companies, that are UK listed). iv) PTM Levy: is a flat rate charge of 1 on all trades over 10,000, collected by the Panel on Takeovers and Mergers, (POTAM), who oversee all take-overs and mergers within the UK. Please see the fee tables from page 5 onwards for other fees that may apply to your account(s). b) Charges specific to each service i) Bestinvest Online Investment Service custody provided by SEI Standard Tariff: We charge a tiered fee based on the average daily value of all assets in your account, excluding cash 1. Fees accrue daily, are calculated using the day end closing value and are levied monthly in arrears. For SIPP accounts, our tiered fee begins at 0.30% for assets up to 250,000 and reduces in levels down to 0% for any excess over 1,000,000. By way of illustration, on a 100,000 investment the Bestinvest Online Investment Service fee would be calculated as follows: - 100,000 at 0.30% = 300 per annum. On a 1,100,000 investment the Bestinvest Online Investment Service fee would be calculated as follows: - First 250,000 at 0.30% = 750-250,001-1,000,000 at 0.20% = 1,500-1,000,001-1,100,000 at 0% = 0 - Total = 750 + 1,500 + 0 = 2,250 per annum. For General Investment Accounts and ISA accounts our tiered fee begins at 0.40% for assets up to 250,000 and reduces in levels down to 0% for any excess over 1,000,000. By way of illustration, on a 100,000 investment the Bestinvest Online Investment Service fee would be calculated as follows: - 100,000 at 0.40% = 400 per annum. 1 For clients with one or more Online Investment Service accounts holding direct equities prior to 1 March 2014, fees will be charged on fund holdings only and a separate custody fee will apply to each account that holds equities please refer to Table 1 for full details. Clients subject to a separate custody fee can instead elect to move to our Standard Tariff if they wish. 2 of 8
On a 1,100,000 investment the Bestinvest Online Investment Service fee would be calculated as follows: - First 250,000 at 0.40% = 1,000-250,001-1,000,000 at 0.20% = 1,500-1,000,001-1,100,000 at 0% = 0 - Total = 1,000 + 1,500 + 0 = 2,500 per annum. VAT is not currently applicable on the tiered service fee. Online dealing in funds: there are no dealing fees or switch charges on investments in unit trusts and OEICs. Online dealing in securities other than funds: you pay a dealing fee on each (buy and sell) when investing online in securities, such as stocks and shares, ETFs and investment trusts. The standard online dealing fee is 7.50 per. All quotes to buy stocks and shares, ETFs and investment trusts will tell you what the dealing fees are and any taxes or levies that apply. These are payable immediately. The Bestinvest Online Investment Service is primarily an online service. If you place a deal in any type of investment by phone, each currently costs 75. Certain securities can be illiquid; these tend to be small cap companies, investment trusts and ETFs, and it is not always possible to trade online. Phone-dealing rates apply in these circumstances. We reserve the right not to make available certain products or investments in our commercial discretion [depending on the service we provide and] due to reasons related to liquidity, pricing, complexity or other risks to clients or us. See Table 1 for a list of all charges applicable to the Bestinvest Online Investment Service custody provided by SEI. The above summarises the charges in respect of the Standard Tariff; in special circumstances and at our sole discretion other tariffs may be offered to you; please contact us if you are unsure which fees apply to you. Fee-based Bestinvest Online Investment Service custody provided by a Third Party Platform We also offer a non-advised service via the FundsNetwork and Cofunds investment platforms. Please contact us for details of these services. i SIPP Accounts See Table 5 for charges applicable only to SIPP accounts (for assets under SEI custody on behalf of Bestinvest). For service specific charges please refer to the SIPP Account column for the corresponding service that you are using from the relevant table. Please ask us if you are unsure which table is applicable to you. Your SIPP provider may levy additional annual and ad hoc charges please refer to their terms and conditions for further details. iv) Payment for ongoing services The Bestinvest Online Investment Service is considered on going and charges will be applied on an annual basis in respect of the services provided. Details of these arrangements will be confirmed to you as part of the account opening process. v) Cancellation of ongoing services You may cancel the ongoing service you receive from the Bestinvest Online Investment Service at any time and change to another service of your choice, which may include a new ongoing service. If you decide not to change to another service and wish to cancel your account there may be transfer fees. Please see the transfer fee section in the applicable table listed later in this document. You may also be liable for any fees, costs, charges or expenses that have accrued to the date of termination. You should also refer to the Termination clause in the applicable Terms of Business. 5. Fund-based commission We will refund to you on a quarterly basis in full any fund-based annual commissions that we receive. This is a cash payment and will be credited to the same Account in which the respective commission-paying funds are held. 6. Is interest paid on cash? Interest is calculated on the daily balance and paid monthly into your account. We may, at our discretion, vary the terms upon which interest is paid. We will notify you where we change those terms. For cash held on your behalf by SEI (the Custodian ), Bestinvest will receive an interest payment from the Custodian. SEI may retain a portion of the interest earned in client bank accounts in certain circumstances. Bestinvest may (dependent on the amount of interest generated) retain some or all of the Custodian s payment before making an interest payment to you. Details on the amount and frequency of such withholdings are available on request. 3 of 8
The current interest rates paid to you are: i) Assets held with SEI as custodian: Account Type Cash Balance Interest Rate (gross) Investment Account all balances 0% ISA/JISA Account all balances 0% SIPP Account all balances 0% Current interest rates (effective 01/03/2015) Interest is calculated on the daily balance and paid monthly into your account. We may, at our discretion, vary the terms upon which interest is paid. Assets held with other custodians: Please refer to our Third Party Platform s Terms of Business and the corresponding custodians terms of business. 7.Who regulates us? Bestinvest (Brokers) Limited, 6 Chesterfield Gardens, London, W1J 5BQ is authorised and regulated by the Financial Conduct Authority. Our firm reference number is 165169. Our permitted business is advising on investments, managing investments, arranging custody, and dealing in investments as agents (including execution-only dealing). You can check this on The Financial Services Register by visiting the FCA s website fca.gov.uk/register/ or by calling the FCA on 0845 606 1234. 8. What to do if you have a complaint? If you wish to register a complaint, please contact us: In writing: to The Compliance Officer, Bestinvest, 6 Chesterfield Gardens, London, W1J 5BQ. By phone: 020 7189 2400. If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service (FOS) (financial-ombudsman.org.uk). If you wish to contact the FOS, please contact them; In writing: South Quay Plaza, 183 Marsh Wall, London, E14 9SR. By phone: 0800 023 4567. 9. Are you covered by the Financial Services Compensation Scheme (FSCS)? You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim. Should you be entitled to compensation from the Financial Services Compensation Scheme, you may be able to recover up to 100% of the first 50,000 that you have invested. Further information about compensation arrangements is available from the FSCS. Their address is FSCS, 10th Floor, Beaufort HOouse, 15 St Botolph Street, London, EC3A 7QU and their website is fscs.org.uk. 10. Who holds my investments? For our non-advised services, the main appointed custodian for your investments, including cash, is SEI Investments (Europe) Limited ( SEI ) whose address is First Floor, Alphabeta,14-18 Finsbury Square, London EC2A 1BR. SEI is a UK custodian that is authorised and regulated by the FCA. Your investments are held in segregated accounts held in the name of SEI Global Nominees Limited, in accordance with the client money and assets rules of the Financial Conduct Authority. Other custodians may also be used and this will be made clear to you in the supporting terms of business in relation to the applicable service(s). 4 of 8
11.How do I know you are giving me a fair deal on my investments? Our procedures are designed to ensure that we obtain the best possible result for you. We have our own best execution policy (see the Terms of Business) that you agree to as part of opening an account with us. Where we use a Third Party Platform to execute your order they will be regulated by the FCA and also have an obligation to us to obtain best execution. 12.What happens if I change my mind about buying an investment? Bestinvest Online Investment Service You have 14 days from the account opening date to cancel an Investment Account, ISA Account or Junior ISA account; 30 days from the account opening date to cancel a SIPP Account and 30 days to cancel following each transfer of a pension from another provider to your SIPP (for SIPPs, full details of cancellation rights can be found in the Best SIPP Key Features Document). Please be aware that if you cancel any investments as a result of exercising your cancellation rights you may get back more or less than you put in as a result of price movements over the period. Please send any cancellation request to Bestinvest Brokers (Limited), 6 Chesterfield Gardens, London, W1J 5BQ You do not have the right to cancel any other type of investment that you can make through our Services; in particular, you cannot cancel the purchase of funds or shares purchased within any type of account mentioned above, unless they are being cancelled as a result of the account itself being cancelled within the time periods specified above. Investments that you buy for your Investment Account or ISA Account can be sold and cash withdrawn at any time although you may get back more or less than you put in. Table 1 Bestinvest Online Investment Service, Standard Tariff (Table 4 and for SIPP Accounts Table 5 also apply regarding additional standard admin charges) FEE (EXCLUDING VAT) Fee Type Investment Account ISA/JISA Account SIPP Account Is VAT payable? When is fee due? SERVICE AND DEALING FEES Bestinvest Online Investment Service Fee 2 Online dealing fee purchase/sale unit trusts and OEICs Tiered fee see table Tiered fee see table Tiered fee see table Paid monthly in No 2 below 2 below 3 below arrears FREE FREE FREE - - Online fund switch fee FREE FREE FREE - - Online dealing fee purchase/sale UK stocks and shares Telephone fee for each telephone (Bestinvest Online Investment Service only clients) Stamp Duty Reserve Tax (SDRT) payable on mainland UK registered companies that are UK listed only. 0% on Exchange Traded Funds, OEICs, unit trusts, gilts, debentures, loan stock and offshore companies PTM Levy (applicable on certain s over 10,000 on the LSE) 7.50 7.50 7.50 No 75 75 75 No 0.5% of the value of 0.5% of the value of investment you buy investment you buy this will be 1% on this will be 1% on Irish registered Irish registered stock stock 0.5% of the value of investment you buy this will be 1% on No Irish registered stock 1.00 1.00 1.00 No At point of ISA/JISA Administration Fee N/A FREE N/A - - SIPP Administration Fee N/A N/A FREE - - 5 of 8
Table 1 (continued) Bestinvest Online Investment Service, Standard Tariff (Table 4 and for SIPP Accounts Table 5 also apply regarding additional standard admin charges) FEE (EXCLUDING VAT) Fee Type Investment Account ISA/JISA Account SIPP Account Is VAT payable? When is fee due? PRODUCT SPECIFIC FEES Account custody fee 2 (Equity holders after 1 March 2015) Account custody fee 2 (Equity holders before 1 March 2015) FREE FREE FREE - - 4.16 4.16 8.33 No Monthly TRANSFER AND ACCOUNT CLOSURE FEES Transfer in from another provider (including Protected Rights transfers into a SIPP) Transfer out of an investment to another nominee (to another pension scheme in the case of a SIPP Account) Transfer out to overseas pension scheme Transfer out of an investment as a share certificate Transfer out (please note "Transfer out of an investment to another nominee" fees detailed above also apply) Account closure CASH TRANSACTION FEES FREE FREE FREE - - 25 per asset 20 per asset 25 per asset 25 per asset - - 250 per account No 20 per asset - - FREE 50 Cash 75 In Specie 125 No - No If held more than 2 years: 75 If held less than 2 years: 175 Dividend and interest receipt FREE FREE FREE - - Cash transfer between accounts FREE FREE FREE - - Income payment to your bank account FREE FREE - - - MISCELLANEOUS FEES Paper contract notes 37.50 (covers all accounts) Quarterly 2 For clients with one or more Online Investment Service accounts holding direct equities prior to 1 March 2014, tiered service fees will be charged on fund holdings only and a separate custody fee will apply to each account that holds equities. Clients subject to a separate custody fee can instead elect to move to our Standard Tariff it they wish. 6 of 8
Table 2 Tiered fee for the Bestinvest Online Investment Service Fee for Investment Accounts and ISA/JISA Accounts GROUP ASSET BAND FEE 0-250,000 0.40% 250,001-1,000,000 0.20% 1,000,000 + 0.00% Note: other fee tariffs may be offered at our discretion. Table 3 Tiered fee for the Bestinvest Online Investment Service Fee for SIPP Accounts GROUP ASSET BAND FEE 0-250,000 0.30% 250,001-1,000,000 0.20% 1,000,000 + 0.00% Note: other fee tariffs may be offered at our discretion. Table 4 Table of fees applicable to all accounts (on the Bestinvest platform SEI providing custody) FEE (EXCLUDING VAT) Fee Type Investment Account ISA/JISA Account SIPP Account Is VAT payable? When is fee due? OTHER FEES BACS charge FREE FREE FREE - - CHAPS charge 35 35 35 No Cheque returned unpaid 40 40 40 BACS collection failure 40 40 40 Copy of tape of telephone conversation 40 40 40 When requested Online statements, valuations and contract notes Duplicate Valuation Statement or Contract Note charge (for each contract note) Probate valuation FREE FREE FREE - - 10 10 10 10 per holding 10 per holding 10 per holding (min 50) (min 50) (min 50) For all accounts other than those with SEI providing custody, please refer to the account provider s terms and conditions for details of their fees. 7 of 8
Table 5 Table of fees applicable to SIPP accounts (on the Bestinvest platform SEI providing custody ( The Best SIPP ) FEE TYPE FEE (EXCLUDING VAT) IS VAT PAYABLE? WHEN IS FEE DUE? SIPP ANNUAL FEES Annual administration fee 0 - - Annual child SIPP administration fee 0 - - Annual administration fee for plan in drawdown 0 - - SIPP set-up fee 0 - - BENEFITS AND PAYMENT FEES Sipps valued at 100,000 or greater (after tax-free cash) Sipps valued below 100,000 (after tax-free cash) FEE TYPE FEE (EXCLUDING VAT)FEE (EXCLUDING VAT) IS VAT PAYABLE? WHEN IS FEE DUE? Flexi-access drawdown fee 0 0 Initial calculation fee 90 100 Annual charge for income payments after tax free cash) 0 100 Ad hoc income payments 25 25 Alteration of payment amount or frequency 25 25 Annuity purchase through Bestinvest 75 75 Annuity purchase (external) 150 150 Arranging death benefit At cost At cost Pension splitting on divorce At cost At cost Refund of overpaid contributions 75 75 Drawdown Valuation 0 3 per line of stock CLOSURE FEES** If closed within one year 290 290 If closed within two years 175 175 thereafter free free **Drawdown closure fees are only payable if your SIPP is closed due to withdrawing all of the funds whilst utilising drawdown. Standard closure fees will apply if you transfer your SIPP to an alternative provider whilst in drawdown. For SIPP accounts held with custodians other than with SEI, please refer to the terms and conditions of the account provider and/or the SIPP provider. GO36V9-05.16 Bestinvest is a trading name of Tilney Investment Management Services Limited. Registered Office: 6 Chesterfield Gardens, Mayfair, W1J 5BQ. Registered in England and Wales. Registered No. 2830297. Authorised and regulated by the Financial Conduct Authority. 8 of 8