The Custody Agent has entered into an agreement with SEI whereby the Custody Agent has arranged for SEI to provide safe custody, administration and other associated services for clients who use ARIA IP. The Custody Agent entered the agreement as your agent and so there is a direct relationship between you and SEI which is governed by the enclosed Custody Terms. Upon entering into the ARIA IP Client Agreement, by signing the ARIA IP Declaration, you are legally bound by the Custody Terms and become a client of SEI in relation to the services provided under those Terms. SEI will be responsible for complying with the regulatory requirements relating to the Custody Terms and will treat you as a retail client giving you the highest level of regulatory protection available. The Custody Agent will retain regulatory responsibility for all other aspects of the services provided to you including the provision of Portfolio Management and the execution of any trades carried out on your behalf.

SEI is authorised and regulated by the Financial Conduct Authority (“FCA”). SEI’s Firm Reference Number is 191713. You can find more detailed information on SEI’s regulatory status on the FCA Register which is accessible at www.fca.org.uk/ register. The FCA is located at 12 Endeavor Square, London E20 1JN. Further contact details for the FCA can be found at www.fca.org.uk.

Unless SEI is obligated to do otherwise by the FCA, all of SEI’s communications with you will be through Fusion Wealth. All communications will be in English.

As your Custodian SEI is obligated to provide you with a periodic Custody Statement of the investments and money that SEI holds for you. SEI will provide this at least once a quarter either as part of the Valuation Statement provided by the Custody Agent or as a standalone Custody Statement.

If you have opted to receive your Valuation Statements in electronic format, SEI will facilitate the provision of an electronic Valuation Statement via the Custody Agent who will be able to provide more detail on how this will be made available to you upon request. In these circumstances, SEI will not provide you with an additional paper copy.

The services provided to you by SEI are part of a broader suite of services provided to the Custody Agent and SEI receives a bundled fee from the Custody Agent directly in relation to these services.

The Custody Agent charges you a fee which incorporates the services provided by SEI. Please note that SEI may retain some of the interest earned in Customer Money Bank Accounts and may charge you for overdrafts on your Account(s) should they occur. See section 7 above for further details on when this may occur.

Money held by SEI on your behalf is treated as client money in accordance with the FCA rules. These rules require SEI to hold your money in “client money” Bank accounts which are established with statutory trust status. This means that money held within the accounts is recognised by the Bank as belonging to clients of SEI rather than SEI itself. In this way SEI holds your money as a trustee.

SEI further segregates all Customer Money Bank Accounts from any bank accounts holding money belonging to SEI by arranging for the Customer Money Bank Accounts to be named in a manner which makes it clear that the money held within the accounts is for the benefit of Customers and not SEI.

You will deposit money into SEI’s UK Customer Money Bank Accounts. This may be subsequently deposited into Customer Money Bank Accounts at a range of other banks chosen by SEI. The spreading of Customer Money across a number of banks is designed to help reduce the risk of Customer Money being lost in the event of any one Bank failing.

SEI may deposit your money in a Bank outside of the UK, in Europe or the United States, where deemed prudent to do so.

In such circumstances, it is important to note that such Banks will be subject to a different legal and regulatory regime from that of UK banks and the rights and protections afforded to you under the FCA rules will not be available to you. For example, the Customer Bank Accounts may not be established with trust status and your money may be treated differently in the event of a bank failure than it would be if it was held with a UK bank. SEI is responsible for exercising reasonable care and due diligence in the initial selection and on-going monitoring of all banks where Customer Money is deposited with the security of Customer Money being SEI’s primary consideration. However, SEI will not be responsible for any acts, omissions or failure of the Banks.

SEI may place a portion of Customer Money in the Customer Money pool into unbreakable time deposits at a third party deposit taker, in line with the FCA’s client money rules.

Customer Money may be placed in a mix of terms – between instant access and unbreakable term deposits up to the maximum allowed by the FCA rules. The mix of terms will be balanced by SEI to deliver an appropriate combination of interest, diversification of risk and timely access to cash at the individual customer level. In the unlikely event that SEI places too much money on a time deposit it may take longer to return some cash.

A list of the Banks that SEI uses to hold Customer Money is available on request.

If any of the UK Banks chosen by SEI fail and cannot return your money, you may be eligible to claim compensation under the Financial Services Compensation Scheme (“FSCS”) depending on your individual circumstances. The current compensation limit is £85,000 per eligible claimant, per bank and the limit covers all money held with the bank through SEI or directly. Full details of the arrangements under the FSCS are available on their website at www.fscs.org.uk.

It is important to note that if one of the Banks fails, your money will be pooled with money held in Customer Bank Accounts for other SEI Customers and you will have a claim against the common pool of money rather than a claim against a specific sum in a specific account. As a result, any shortfall in the Customer Money Bank Accounts will be shared pro-rata between all SEI Customers (whose money is held by SEI).

In the event that you owe a debt to SEI in relation to services SEI has provided under the Custody Terms, SEI may use any of the money held for you to pay off or reduce that debt.

Under the Custody Terms, you have permitted SEI to collect and pay fees that you owe to the Custody Agent from money held for you in a Customer Money Bank Account.

Where SEI has held your Customer Money for 6 years, following the last movement on your Account (not including any applicable interest payment, fee collection or similar) and Fusion Wealth or SEI has been unable to trace and contact you, to pay you this money, over that time, SEI is able to treat this balance as unclaimed Customer Money. This means SEI will cease treating the amount as Customer Money and is able to pay the balance away to a registered charity of SEI’s choice.

In accordance with FCA Rules, SEI will retain a record of this action, which does not stop you from claiming this balance from SEI even after it has been paid away.

Contractual Settlement is a tool that facilitates cash and liquidity management for the investor. SEI will move cash into your Account and move the securities out of your Account on the day you are meant to settle your transactions, regardless of what may have actually happened with the broker or fund manager. We will do the opposite for purchases.

This process insulates you from the securities settlement process and simplifies the money movement processes. In rare cases, these postings may need to be reversed because of an unusual market event. If that did occur your Adviser will be notified by Fusion Wealth.

SEI is responsible for the holding the Assets within your ARIA IP account in safe custody. Your Assets are held in the name of SEI Global Nominee Ltd on behalf of you as a user of the ARIA IP platform and having appointed the Custody Agent as your Agent.

SEI Global Nominee Ltd is used to assist in ensuring all Customer Assets are segregated from the assets of SEI. SEI Global Nominee Ltd is a Nominee Company which is used by SEI as it has no material liabilities and is a separate entity from SEI. Therefore your assets would not be available to an administrator or liquidator of SEI, or its parent company, SEI Investments Company, in the event that bankruptcy proceedings against SEI should ever occur.

SEI may use a number of third party custodians (also known as sub-custodians) to administer and hold some of your Assets.

SEI will be responsible for exercising reasonable care and due diligence in the initial selection and on-going monitoring of the sub-custodians but will not be responsible for any acts, omissions or failure of the sub-custodians.

In certain circumstances, SEI may select a sub- custodian outside of the UK where deemed prudent to do so. In such circumstances, it is important to note that such sub-custodians will be subject to a different legal and regulatory regime from that of the UK and the rights and protections afforded to you under the FCA rules may not be available to you. For example, there may be different practices for the separate identification of your assets which may result in them being subject to third party claims in the event of the failure of the sub-custodian.

All custody accounts are operated in accordance with the applicable FCA rules. Under these rules, SEI is required, amongst other things, to make adequate arrangements to safeguard your ownership rights and to prevent the use of your Assets for SEI’s own account. SEI has put procedures in place designed to meet the following obligations:

• records and accounts are kept as necessary to enable SEI to distinguish Assets held for one Customer from the Assets held for any other Customer and from SEI’s own assets; and

• reconciliations are made to SEI’s own internal accounts and records and those of any sub-custodians with whom your Assets are held.

All Customer Assets will be held in omnibus accounts by SEI Global Nominee Ltd. This means that SEI Global Nominee Ltd will pool your Assets with the Assets of other Customers and therefore your individual entitlements may not be identifiable by separate certificates or physical documents of title. In the event of a shortfall in the accounts following a default of SEI Global Nominee Ltd or a sub-custodian, you may not receive your full entitlement and may share any losses pro-rata with other Customers.

Under FCA Rules, where SEI has custodied an asset for you for over 12 years, and in that time you have not sent any instruction to Fusion Wealth or SEI with respect to that asset and Fusion Wealth or SEI has been unable to trace and contact you about the holding, SEI is able to liquidate the holding and pay the proceeds away to a registered charity of SEI’s choice, or gift the holding to a registered charity of SEI’s choice.

In accordance with FCA Rules, SEI will retain a record of this action, which does not stop you from claiming a sum equal to the value of the holding at the time it was paid away/gifted.

In the event that SEI is unable to meet any of its liabilities, compensation may be available to you under the Financial Services Compensation Scheme (“FSCS”). The current compensation limit in relation to investment business is £50,000 per eligible claimant. Full details of the arrangements under the FSCS are available as outlined above.

When trying to identify a conflict, SEI takes into account (at a minimum) whether SEI (and/or any Directors, officers, employees or any person directly or indirectly linked to SEI):

• is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
• has an interest in the outcome of a service provided to a client or of a transaction carried out on behalf of a client, which is distinct from the client’s interest in that outcome;
• has a financial or other incentive to favour the interest of another client or group of clients over the interests of a different client or group of clients;
• carries on the same business as its client(s); or
• receives or will receive from a person other than its client(s), an inducement in relation to a service provided to its the client(s), in the form of monies, goods or services, other than the standard commission or fee for that service.

SEI is obligated to manage conflicts of interest fairly, both between itself and its clients and between one client or group of clients and another client or group of clients. SEI has both a Conflicts of Interest Policy and other Compliance Policies intended to operate, monitor and maintain effective organisational and administrative arrangements with a view to taking all reasonable steps to prevent conflicts of interest.

Whilst SEI makes every effort to ensure that all reasonable steps are taken to prevent conflicts of interest, in certain situations, a conflict may arise. If SEI is unable to manage conflicts through its Compliance Policies SEI may disclose the nature and/or source of conflicts of interest with and between its clients or may refuse to enter, or be forced to terminate, a relationship.

Further information regarding SEI’s Conflicts of Interest Policy is available upon request.