Legal

Agreement Overview

These Terms of Service (the "Terms," "Agreement," or "TOS") constitute a legally binding agreement between you ("Client," "you," or "your") and Wealthhub PLC ("Company," "we," "us," or "our"), a company registered in England and Wales (Company Number: [Insert]), regarding your use of our discretionary investment management services.

By opening an account, accessing our platform, or using any of our services, you acknowledge that you have read, understood, and agree to be bound by these Terms, our Privacy Policy, Risk Disclosure Statement, and all applicable laws and regulations including FCA rules. If you do not agree to these Terms, you may not use our services.

IMPORTANT: This Agreement grants us discretionary authority to manage your investments, contains provisions that limit our liability, and requires you to understand the significant risks involved in investing. Please read these Terms carefully before opening an account.

Regulatory Status

Wealthhub PLC is authorized and regulated by the Financial Conduct Authority (FCA).

• FCA Reference Number: [Insert FCA Reference Number]
• Registered Office: London, United Kingdom
• Company Number: [Insert Companies House Number]

You can verify our regulatory status on the FCA Register at https://register.fca.org.uk

Acceptance and Modifications

Acceptance of Terms

You accept these Terms by:

• Completing the account registration process
• Electronically signing the Investment Management Agreement
• Funding your account with the minimum investment of £1,000 (or equivalent in other currencies)
• Using any Wealthhub services or features

Right to Modify

Wealthhub reserves the right to modify these Terms at any time. We will notify you of material changes by:

• Sending notice to your registered email address at least 30 days before changes take effect
• Posting notice on our website and in your account dashboard
• Requiring your acknowledgment for significant changes that materially affect your rights

Your continued use of our services after the effective date of modified Terms constitutes your acceptance of the changes. If you do not agree to the modified Terms, you may close your account in accordance with the termination provisions below.

Eligibility Requirements

To open an account with Wealthhub, you must meet all of the following requirements:

Age and Legal Capacity

• You must be at least 18 years of age (age of majority in the UK)
• You must have the legal capacity to enter into binding contracts
• You must not be subject to any legal disability that would prevent you from managing your financial affairs

Residency and Jurisdiction

• You must be a UK resident or have the legal right to invest in UK-regulated investment services
• You must have a valid UK address or equivalent proof of address
• You must provide acceptable proof of identity (passport, driving licence, or national ID card)
• You must not be a resident of a jurisdiction where our services are prohibited

Financial Requirements

• You must meet the minimum initial investment of £1,000
• You must have a valid UK bank account for deposits and withdrawals
• You must provide accurate financial information for suitability determination
• You must certify that invested funds are from legitimate sources

Prohibited Persons

You may not open an account if you:

• Are located in, or a resident of, a country subject to UK/UN/EU economic sanctions
• Appear on any UK government sanctions lists (HM Treasury sanctions list)
• Have been convicted of financial crimes or money laundering offenses
• Have been barred or suspended from financial services by the FCA or any regulatory authority
• Have previously had a Wealthhub account terminated for cause
• Are a Politically Exposed Person (PEP) without appropriate due diligence

Account Opening and Registration

Application Process

To open an account, you must:

1. Complete Application: Provide all required personal, financial, and employment information accurately and completely
2. Identity Verification: Submit government-issued photo ID and proof of address (dated within last 3 months)
3. Risk Assessment: Complete our investment questionnaire to determine your risk profile (Conservative, Balanced, or Growth-Oriented)
4. Review Disclosures: Review and acknowledge all required disclosures, including Risk Disclosure Statement and Client Agreement
5. Sign Agreement: Electronically sign the Investment Management Agreement
6. Fund Account: Make an initial deposit of at least £1,000 via bank transfer

Know Your Customer (KYC) Requirements

As required by the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, we must verify:

• Your identity using acceptable ID documents
• Your current residential address
• Source of funds and source of wealth
• PEP status and sanctions screening
• Purpose and intended nature of the business relationship

Account Approval

Wealthhub reserves the right to:

• Approve or reject any account application in our sole discretion
• Request additional information or documentation before approving an account
• Delay account opening pending completion of verification procedures
• Conduct Enhanced Due Diligence for higher-risk customers
• Refuse service to any person for any reason not prohibited by law

Account approval typically takes 24-72 hours after we receive all required information and documentation.

Account Types

We offer the following account types:

• Individual Accounts: Accounts owned by one person
• Joint Accounts: Accounts with two or more owners (joint tenants or tenants in common)
• ISA Accounts: Stocks and Shares ISAs (subject to HMRC annual subscription limits)
• SIPP Accounts: Self-Invested Personal Pensions (through our pension partner)
• Trust Accounts: Accounts held by trustees (requires trust deed and trustee authorization)
• Company Accounts: Accounts for limited companies (requires incorporation documents and board resolution)

Account Responsibilities

As an account holder, you are responsible for:

• Accuracy of Information: Providing true, accurate, complete, and current information
• Updates: Promptly updating your information when it changes (address, employment, financial situation, investment objectives, PEP status)
• Security: Maintaining the confidentiality of your login credentials
• Monitoring: Regularly reviewing your account statements and confirming accuracy
• Unauthorized Access: Immediately notifying us of any unauthorized account access or suspicious activity
• Account Activity: All activity that occurs under your account, whether authorized or unauthorized
• Tax Obligations: Reporting investment income to HMRC and paying applicable taxes

Security Best Practices:

• Use a strong, unique password and enable two-factor authentication
• Never share your login credentials with anyone
• Log out after each session, especially on shared devices
• Keep your email account secure as it is used for password resets
• Be wary of phishing attempts requesting your account information
• Verify our website URL (https://www.stenori.com) before entering credentials

Investment Management Services

Discretionary Authority

By opening an account with Wealthhub, you grant us full discretionary authority to manage your investment portfolio. This means we have the authority to:

• Make all investment decisions without prior consultation with you
• Buy, sell, and hold securities in your account across four asset categories: exchange-traded funds (ETFs), real estate, renewable energy, and foreign exchange (forex)
• Determine the timing, size, and allocation of investments
• Rebalance your portfolio monthly and make tactical adjustments as needed
• Select specific ETFs, property investments, clean energy securities, and currency pairs
• Execute all transactions on your behalf through our appointed custodians and brokers

Important: Our discretionary authority means you cannot direct specific investments, request specific trades, or override our investment decisions. This is a fully managed service, not a self-directed or execution-only platform.

Investment Strategy

Wealthhub employs systematic, diversified investment strategies across four asset categories:

• Exchange-Traded Funds (ETFs): Liquid, diversified exposure to equity and fixed-income markets through institutional-grade fund selection. Allocation ranges from 25-45% depending on risk profile.
• Real Estate: Income-generating property investments through Real Estate Investment Trusts (REITs) and direct equity positions in residential, commercial, and industrial assets. Provides inflation protection and portfolio stability. Allocation ranges from 15-35%.
• Renewable Energy: Strategic exposure to solar, wind, battery storage, and clean technology infrastructure capitalizing on secular decarbonization trends. Allocation ranges from 10-30%.
• Foreign Exchange (Forex): Systematic currency positioning exploiting macroeconomic divergence, interest rate differentials, and central bank policy shifts across major G10 currency pairs. Provides diversification benefits. Allocation ranges from 10-20%.

Your specific allocation across these categories is determined by your risk profile:

• Conservative: 25-35% ETFs, 25-35% Real Estate, 10-15% Renewable Energy, 10-15% Forex, remainder in cash/equivalents
• Balanced: 30-40% ETFs, 20-25% Real Estate, 15-20% Renewable Energy, 10-15% Forex, remainder in cash/equivalents
• Growth-Oriented: 35-45% ETFs, 15-25% Real Estate, 20-30% Renewable Energy, 15-20% Forex, remainder in cash/equivalents

Actual allocations may vary based on market conditions and available opportunities. We reserve the right to hold positions in cash or cash equivalents when we determine it is in your best interest.

Portfolio Rebalancing

Your portfolio is systematically rebalanced monthly to maintain optimal allocation. Rebalancing involves:

• Selling positions that have grown beyond target allocation
• Buying positions that have fallen below target allocation
• Adjusting for deposits and withdrawals
• Capturing gains from strong performers
• Adding to quality positions that have declined in value
• Responding to changing market conditions and opportunities

In addition to monthly rebalancing, we actively monitor all positions daily and may make tactical adjustments based on market conditions, risk management, or strategic opportunities.

Suitability and Best Interest

Wealthhub operates under FCA Conduct of Business rules and has an obligation to:

• Act honestly, fairly, and professionally in your best interests
• Provide investment advice and management that is suitable for your financial situation, investment objectives, risk tolerance, and capacity for loss
• Obtain necessary information about your knowledge and experience
• Assess appropriateness of our services for you
• Disclose material conflicts of interest
• Seek best execution for all transactions
• Charge reasonable fees for our services
• Provide clear, fair, and not misleading communications

We determine suitability based on information you provide in your account application and investment questionnaire. You are responsible for ensuring this information is accurate and updated when your circumstances change. You must notify us of any material changes to your financial situation, investment objectives, or risk tolerance.

Custody and Safeguarding

Your investments are held by our appointed custodians in segregated client money accounts in accordance with FCA CASS (Client Assets Sourcebook) rules. This means:

• Your assets are held separately from Wealthhub's own assets
• Your assets are protected in the unlikely event of our insolvency
• We do not use your assets for our own business purposes
• Daily reconciliation ensures accuracy of client asset records

Fees and Expenses

Management Fees

Wealthhub charges a flat annual management fee regardless of account size:

• All Account Sizes: 0.15% annually (15 basis points)

This low, transparent fee structure ensures alignment of interests between you and Wealthhub.

Performance Fees

In addition to management fees, Wealthhub charges performance fees on realized gains:

• Performance Fee Rate: 15% of realized profits
• High-Water Mark: Performance fees are only charged on net new profits above the previous highest account value
• Calculation: Performance fees are calculated on a monthly basis when profits are realized
• No Double Charging: Once a performance fee is paid on a gain, you will not pay again on that same gain

Example: If your account grows from £10,000 to £11,500 in a month (£1,500 gain), the performance fee would be £225 (15% × £1,500). The new high-water mark becomes £11,500.

Fee Calculation and Billing

• Management Fee Calculation: Calculated monthly based on your average daily account value for the month
• Deduction: Fees are automatically deducted from your account at the end of each month
• Pro-Rata: Fees for partial months are pro-rated based on the number of days your account was open
• VAT: All fees are subject to UK VAT at the applicable rate (currently 20%)

Example: For an account with an average monthly value of £50,000, the monthly management fee would be approximately £6.25 (£50,000 × 0.15% ÷ 12 months) plus VAT.

Other Fees and Expenses

• Underlying Fund Expenses: ETFs and funds held in your portfolio have internal expense ratios (typically 0.03% to 0.40% annually). These fees are not charged by Wealthhub but are embedded in the fund's net asset value.
• Transaction Costs: We do not charge trading commissions. Small regulatory fees or stamp duty may apply on certain UK equity transactions (0.5% stamp duty on UK stock purchases).
• Bank Transfer Fees: We do not charge for standard UK bank transfers. International wire transfers may incur bank charges.
• Currency Conversion: If you deposit or withdraw in a currency other than GBP, prevailing exchange rates apply with a typical spread of 0.5%
• Account Closure Fee: None - accounts can be closed at any time without penalty
• Inactivity Fee: None

Fee Transparency

All fees charged to your account are clearly disclosed in your monthly statements. You can view a detailed breakdown of fees in your account dashboard at any time. We provide annual cost and charges disclosure as required by FCA rules.

Fee Changes

Wealthhub reserves the right to change fee schedules with 30 days' advance notice. Fee increases will require your consent. If you do not agree to increased fees, you may close your account without penalty before the changes take effect.

Deposits and Withdrawals

Deposits

Accepted Methods:

• Bank Transfer (BACS/Faster Payments): Free, typically processed same day or within 2 hours for Faster Payments
• CHAPS Transfer: Same day, may incur bank fees
• Cheque Deposits: 5-7 business days for clearance (not recommended)

Deposit Requirements:

• Deposits must come from a UK bank account in your name
• Initial deposit must meet the £1,000 minimum
• Subsequent deposits have no minimum amount
• All deposits are subject to verification and anti-money laundering screening
• We may request source of funds documentation for large deposits
• Deposits from third parties are not accepted without prior authorization

Investment Timeline: Once a deposit clears, funds are typically allocated to your portfolio within 24-48 hours according to your risk profile.

Withdrawals

Withdrawal Process:

• Log in to your account and navigate to "Withdrawals"
• Enter the withdrawal amount and confirm your bank details
• Submit your withdrawal request
• Funds are typically transferred within 3-5 business days

Withdrawal Restrictions:

• Minimum Balance: You must maintain at least £1,000 in your account. Withdrawals bringing your balance below £1,000 will result in account closure.
• Settlement Period: Withdrawals may be delayed if you have unsettled trades (typically T+2 for most securities)
• Verification: Large withdrawal requests may require additional verification for security and AML purposes
• Same Account: Withdrawals can only be made to the bank account you used for deposits (to prevent money laundering)
• Frequency: No limit on number of withdrawals, but frequent large withdrawals may impact portfolio performance
• Market Conditions: During extreme market volatility, we may need to liquidate positions over multiple days to achieve best execution

Full Account Closure: To close your account and withdraw all funds, contact our support team. We will liquidate all positions, allow trades to settle, deduct any outstanding fees (including performance fees on realized gains), and transfer the remaining balance to your bank account within 5-10 business days.

ISA and SIPP Withdrawals

• ISA: You can withdraw from your ISA at any time without tax penalties. However, you cannot re-contribute the withdrawn amount in the same tax year without it counting toward your annual ISA allowance.
• SIPP: Withdrawals from SIPP accounts are subject to pension rules and typically cannot be accessed before age 55 (rising to 57 from 2028) without tax penalties. Early withdrawals may trigger significant tax charges.

Failed Transactions

If a deposit fails (e.g., insufficient funds), you are responsible for any fees charged by your bank. If a withdrawal fails (e.g., incorrect bank information), please contact support to update your information and resubmit the request.

Risks and Disclaimers

Investment Risks

ALL INVESTMENTS INVOLVE RISK. YOU MAY LOSE SOME OR ALL OF YOUR INVESTED CAPITAL. THE VALUE OF INVESTMENTS CAN GO DOWN AS WELL AS UP.

Specific risks associated with your Wealthhub portfolio include:

• Market Risk: Securities prices fluctuate based on economic conditions, company performance, and market sentiment. Your portfolio value will rise and fall.
• ETF Risk: ETFs are subject to the risks of their underlying holdings and may trade at premiums or discounts to net asset value. Tracking error may cause ETF returns to deviate from their benchmark indices.
• Real Estate Risk: Property values and rental income can decline due to economic conditions, interest rate changes, oversupply, or property-specific issues. REITs are subject to liquidity risk and may reduce or eliminate distributions.
• Renewable Energy Risk: Clean energy investments exhibit higher volatility due to policy changes, technological disruption, commodity price fluctuations, and sector-specific risks. Government subsidies and incentives may be reduced or eliminated.
• Currency Risk (Forex): Foreign exchange positions involve leverage and can result in rapid losses. Currency prices are influenced by economic data, geopolitical events, interest rate changes, and central bank actions. Forex trading is highly speculative.
• Leverage Risk: Forex positions involve leverage, which magnifies both gains and losses. Small adverse price movements can result in losses exceeding your invested capital in forex positions.
• Liquidity Risk: Some investments may be difficult to sell quickly without significantly impacting price. During market stress, liquidity can decline sharply.
• Concentration Risk: Over-concentration in any sector, security, or strategy increases risk. Renewable energy and real estate positions may create sector concentration.
• Currency Exchange Risk: If you invest in a currency other than GBP, exchange rate fluctuations will affect your returns.
• Regulatory Risk: Changes in laws or regulations (including tax treatment, environmental regulations, or financial services rules) may adversely affect investments.
• Inflation Risk: Returns may not keep pace with inflation, reducing purchasing power over time.
• Counterparty Risk: Risk that custodians, brokers, or other counterparties fail to meet obligations.

No Guarantees

Wealthhub makes no guarantees regarding investment performance. Specifically:

• Past performance does not guarantee future results
• Target returns are goals, not promises
• No specific level of performance or return is guaranteed
• Your actual results may be higher or lower than any stated targets or historical returns
• Different time periods will yield different returns
• Individual results will vary based on timing of deposits, withdrawals, and market conditions
• You may get back less than you invested

Not FSCS Protected (with exceptions)

YOUR ACCOUNT INVESTMENTS ARE NOT BANK DEPOSITS AND ARE NOT PROTECTED BY THE FINANCIAL SERVICES COMPENSATION SCHEME (FSCS) AGAINST INVESTMENT LOSSES. FSCS protection may apply if:

• Wealthhub PLC becomes insolvent and cannot return your assets (up to £85,000 per person)
• Our custodian becomes insolvent and your assets cannot be returned (up to £85,000 per person)

Important: FSCS does NOT protect against investment losses due to market declines or poor investment performance. It only protects against the failure of the firm.

Tax Implications

Investment transactions may have tax consequences. You are responsible for:

• Consulting with your tax advisor regarding the tax treatment of your investments
• Paying all applicable taxes on investment income and gains (Capital Gains Tax, Income Tax on dividends)
• Reporting investment income on your Self-Assessment tax return to HMRC
• Understanding ISA and pension tax benefits and limitations
• Monitoring your annual Capital Gains Tax allowance (currently £3,000 for 2024/25)

Wealthhub will provide annual tax certificates and statements, but we do not provide tax advice. Portfolio rebalancing and trading may generate taxable events throughout the year. You should consult a qualified tax advisor for personal tax advice.

Communication in English

All communications, documents, and agreements with Wealthhub will be in English. It is your responsibility to ensure you understand all terms and conditions.

Prohibited Activities

You agree not to:

• Market Manipulation: Engage in or attempt to manipulate markets, prices, or trading activity
• Fraud: Provide false information, impersonate others, or engage in fraudulent activity
• Money Laundering: Use Wealthhub services for money laundering, terrorist financing, or proceeds of crime
• Illegal Activities: Use your account for any illegal purpose or in violation of any laws
• Unauthorized Access: Access or attempt to access accounts that do not belong to you
• System Interference: Interfere with or disrupt our systems, servers, or networks
• Reverse Engineering: Reverse engineer, decompile, or attempt to derive source code from our platform
• Data Mining: Use automated tools to access, scrape, or collect data from our platform without authorization
• Multiple Accounts: Open multiple accounts to circumvent limits or requirements without authorization
• Sanctions Evasion: Circumvent or evade UK/UN/EU sanctions or export controls

Violation of these prohibitions may result in immediate account termination, forfeiture of funds, reporting to FCA and NCA, and referral to law enforcement.

Account Termination and Suspension

Termination by You

You may close your account at any time by:

• Contacting our support team to request account closure
• Providing written notice via email to support@stenori.com
• Allowing 30 days' notice for orderly liquidation of positions

Upon termination request, we will liquidate all positions in an orderly manner to achieve best execution, allow trades to settle, deduct outstanding fees (including performance fees on realized gains), and transfer the remaining balance to your registered bank account within 5-10 business days.

Termination by Wealthhub

We reserve the right to terminate or suspend your account immediately, with or without notice, if:

• You violate these Terms or any applicable law or regulation
• You provide false or misleading information during account opening or afterwards
• Your account is involved in fraudulent, suspicious, or illegal activity
• You fail to maintain the minimum balance of £1,000
• You fail to respond to our requests for information or documentation
• Your account poses a risk to Wealthhub or other clients
• We are required to do so by law, regulation, or court order
• We determine, in our sole discretion, that continuing the relationship is not in our or your best interest
• You become subject to sanctions or appear on watchlists
• We can no longer provide suitable investment management services to you

We will provide written notice of termination and reasons where legally permissible (note: we cannot disclose if a Suspicious Activity Report has been filed).

Effect of Termination

Upon termination:

• Your access to the platform will be revoked
• All outstanding fees and expenses will be deducted (including performance fees on any realized gains)
• Positions will be liquidated in an orderly manner
• Remaining funds will be returned to you (subject to any legal holds or regulatory requirements)
• You remain responsible for any obligations incurred before termination
• Provisions of these Terms that by their nature should survive termination will continue to apply (limitations of liability, confidentiality, dispute resolution)
• We will retain records as required by FCA rules (typically 6 years)

Limitation of Liability

IMPORTANT LIMITATIONS ON OUR LIABILITY:

Nothing in these Terms excludes or limits our liability for:

• Death or personal injury caused by our negligence
• Fraud or fraudulent misrepresentation
• Any other liability that cannot be excluded or limited under UK law

Subject to the above, and to the maximum extent permitted by law:

• Wealthhub'S TOTAL LIABILITY TO YOU FOR ANY CLAIMS RELATED TO OUR SERVICES SHALL NOT EXCEED THE AMOUNT OF MANAGEMENT AND PERFORMANCE FEES YOU PAID IN THE 12 MONTHS PRECEDING THE CLAIM
• WE ARE NOT LIABLE FOR INVESTMENT LOSSES, INCLUDING LOSSES DUE TO MARKET DECLINES, VOLATILITY, OR INVESTMENT PERFORMANCE (whether positive or negative)
• WE ARE NOT LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES
• WE ARE NOT LIABLE FOR DAMAGES ARISING FROM YOUR BREACH OF THESE TERMS
• WE ARE NOT LIABLE FOR TECHNICAL ISSUES, SYSTEM DOWNTIME, OR SERVICE INTERRUPTIONS BEYOND OUR REASONABLE CONTROL (including internet failures, power outages, telecommunications failures)
• WE ARE NOT LIABLE FOR LOSSES RESULTING FROM YOUR FAILURE TO KEEP LOGIN CREDENTIALS SECURE
• WE ARE NOT LIABLE FOR THIRD-PARTY ACTS (including custodian failures, market failures, or force majeure events)

This limitation applies to all claims, whether based on contract, tort, negligence, strict liability, or any other legal theory.

Best Execution Disclaimer: While we seek best execution for all transactions, we cannot guarantee the best possible price will be achieved for every transaction due to market conditions, liquidity, and timing factors.

Indemnification

You agree to indemnify, defend, and hold harmless Wealthhub PLC, its affiliates, officers, directors, employees, and agents from any claims, damages, losses, liabilities, and expenses (including reasonable legal fees) arising from:

• Your violation of these Terms
• Your violation of any law or regulation
• Your violation of any third-party rights
• Unauthorized use of your account by third parties
• Any misrepresentation made by you
• Your failure to pay applicable taxes

Complaints and Dispute Resolution

Internal Complaints Procedure

If you have a complaint about our services, please contact us:

• Email: complaints@stenori.com
• Mail: Wealthhub PLC, Complaints Department, London, United Kingdom
• Phone: [Insert UK phone number]

We will:

• Acknowledge receipt of your complaint within 3 business days
• Investigate thoroughly and impartially
• Provide a final response within 8 weeks
• Work with you to resolve the issue fairly

Financial Ombudsman Service (FOS)

If you are not satisfied with our final response, or if we have not provided a final response within 8 weeks, you may refer your complaint to the Financial Ombudsman Service:

• Website: www.financial-ombudsman.org.uk
• Phone: 0800 023 4567 (free from landlines and mobiles) or 0300 123 9123
• Email: complaint.info@financial-ombudsman.org.uk
• Address: Financial Ombudsman Service, Exchange Tower, London E14 9SR

You must refer your complaint to FOS within 6 months of receiving our final response. The FOS provides a free, independent dispute resolution service.

Eligibility for FOS

The Financial Ombudsman Service is available to "eligible complainants" including:

• Individuals (consumers)
• Micro-enterprises (fewer than 10 employees and turnover/balance sheet under €2m)
• Certain small charities and trusts

Arbitration (for larger claims)

For disputes not eligible for FOS or where you prefer arbitration:

• Disputes may be referred to arbitration under the rules of the London Court of International Arbitration (LCIA)
• Arbitration shall take place in London, England
• The language of arbitration shall be English
• Each party bears its own costs unless the arbitrator awards costs to the prevailing party
• The arbitrator's decision is final and binding

Note: Nothing in this arbitration clause affects your right to refer complaints to the Financial Ombudsman Service if you are an eligible complainant.

Governing Law and Jurisdiction

These Terms are governed by the laws of England and Wales. For any disputes not subject to FOS or arbitration, you consent to the exclusive jurisdiction of the courts of England and Wales.

Miscellaneous Provisions

Entire Agreement

These Terms, together with our Privacy Policy, Risk Disclosure Statement, and any other agreements referenced herein, constitute the entire agreement between you and Wealthhub regarding our services and supersede all prior agreements and understandings.

Severability

If any provision of these Terms is found to be invalid or unenforceable by a court or regulator, the remaining provisions will continue in full force and effect. The invalid provision will be replaced with a valid provision that most closely reflects the original intent.

No Waiver

Our failure to enforce any provision of these Terms does not constitute a waiver of that provision or any other provision. Any waiver must be in writing.

Assignment

You may not assign or transfer these Terms or your account without our prior written consent. Wealthhub may assign these Terms to any affiliate or in connection with a merger, acquisition, or sale of assets, subject to FCA approval where required.

Force Majeure

Wealthhub is not liable for any failure or delay in performance due to circumstances beyond our reasonable control, including natural disasters, war, terrorism, pandemics, labor disputes, government actions, market closures, or technical failures.

Electronic Communications

You consent to receive communications from us electronically. We will communicate with you by email or by posting notices on our website or in your account. You agree that all agreements, notices, disclosures, and other communications provided electronically satisfy any legal requirement that such communications be in writing.

Third-Party Rights

These Terms are for the benefit of you and Wealthhub only. No third party has any right to enforce any provision of these Terms under the Contracts (Rights of Third Parties) Act 1999.

Confidentiality

We will keep your information confidential in accordance with our Privacy Policy and FCA rules. You agree to keep confidential any non-public information about Wealthhub's investment strategies, systems, and operations.

What Are Cookies?

Cookies are small text files that are placed on your device (computer, smartphone, tablet) when you visit a website. Cookies allow the website to recognize your device and remember information about your visit, such as your preferred language, login status, and other settings.

Similar technologies include web beacons, pixels, tags, and local storage. For simplicity, this policy refers to all these technologies collectively as "cookies" unless otherwise specified.

This Cookie Policy should be read alongside our Privacy Policy, which provides more information about how we collect and use your personal data.

Why We Use Cookies

Wealthhub uses cookies for several important purposes in compliance with the Privacy and Electronic Communications Regulations (PECR):

• Essential Functionality: Enable core features like secure login, account access, and transaction processing
• Security: Protect your account from fraud and unauthorized access
• Preferences: Remember your settings and preferences across sessions
• Performance: Analyze how our website performs and identify areas for improvement
• Analytics: Understand how visitors use our site to improve user experience
• Marketing: Deliver relevant information and measure communication effectiveness (with your consent)

Types of Cookies We Use

1. Strictly Necessary Cookies

These cookies are essential for the website to function properly. They enable basic functions like page navigation, secure login, and access to protected areas. The website cannot function properly without these cookies.

Examples:

• Session Cookies: Maintain your login session and remember your authentication state
• Security Cookies: Detect fraud and protect against attacks
• Load Balancing Cookies: Distribute traffic across our servers for optimal performance
• Cookie Consent: Remember your cookie preferences

Legal Basis: These cookies are necessary for providing our service and do not require consent under PECR.

2. Functional Cookies

These cookies enable enhanced functionality and personalization, such as remembering your preferences and settings.

Examples:

• Preference Cookies: Remember your language or region preferences
• Accessibility Cookies: Remember accessibility settings like font size or contrast
• UI Customization: Remember your dashboard layout and display preferences

Retention: Typically 1-2 years

Legal Basis: Your consent

3. Performance and Analytics Cookies

These cookies help us understand how visitors interact with our website by collecting anonymous information about pages visited, time spent, and any errors encountered.

Examples:

• Google Analytics: Tracks website usage, traffic sources, and user behavior (with IP anonymization)
• Error Tracking: Identifies technical issues and system errors
• Performance Monitoring: Measures page load times and system performance
• A/B Testing: Tests different versions of pages to improve user experience

Retention: Typically 1-2 years

Legal Basis: Your consent

4. Marketing and Communication Cookies

These cookies are used to deliver information that may be relevant to you and your interests. They help measure the effectiveness of communications and limit repeat messages.

Examples:

• Email Tracking: Track engagement with email communications
• Content Personalization: Personalize content based on your interests and account type
• Communication Preferences: Remember your communication preferences

Retention: Typically 90 days to 2 years

Legal Basis: Your explicit consent

Third-Party Cookies

Some cookies on our site are set by third-party service providers we work with. We do not control these third-party cookies, and you should check the privacy policies of these third parties for information about their cookies.

Third-Party Services We Use

• Google Analytics: Website analytics and traffic analysis (Privacy Policy)
• Google Tag Manager: Tag and code management (Privacy Policy)
• Intercom: Customer support and messaging (Privacy Policy)
• Hotjar: User behavior analytics and heatmaps (Privacy Policy)

Note: We do not use advertising cookies or share your data with advertising networks.

Managing Your Cookie Preferences

Cookie Consent Manager

When you first visit our website, you'll see a cookie consent banner allowing you to accept or reject non-essential cookies. You can change your cookie preferences at any time by:

• Clicking the "Cookie Settings" link in the footer of our website
• Accessing your cookie preferences in your account settings
• Contacting us at dataprotection@stenori.com

Browser Settings

Most web browsers allow you to control cookies through their settings. You can set your browser to:

• Block all cookies
• Block only third-party cookies
• Delete cookies when you close your browser
• Alert you before accepting cookies

How to Manage Cookies by Browser:

• Chrome: Settings → Privacy and security → Cookies and other site data
• Firefox: Settings → Privacy & Security → Cookies and Site Data
• Safari: Preferences → Privacy → Cookies and website data
• Edge: Settings → Cookies and site permissions → Cookies and site data

Important Note: Blocking all cookies may affect the functionality of Wealthhub and prevent you from accessing certain features. Strictly necessary cookies cannot be disabled if you want to use our service.

Opt-Out Tools

You can opt out of certain third-party cookies using these tools:

• Google Analytics: Google Analytics Opt-out Browser Add-on
• Do Not Track: Enable "Do Not Track" in your browser settings

Mobile Application Tracking

Our mobile application may use similar tracking technologies, including:

• Device Identifiers: Advertising ID (IDFA on iOS, AAID on Android) - only with your consent
• SDKs: Third-party software development kits for analytics and functionality
• Push Notifications: Device tokens for sending account alerts and updates (only if you enable notifications)

You can control mobile tracking through your device settings:

• iOS: Settings → Privacy → Tracking → Allow Apps to Request to Track
• Android: Settings → Privacy → Ads → Opt out of Ads Personalization

Updates to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. When we make changes, we will update the "Last Updated" date at the top of this policy.

We encourage you to review this Cookie Policy periodically to stay informed about how we use cookies.

Contact Us About Cookies

If you have questions about our use of cookies or wish to exercise your rights, please contact:

• Data Protection Officer: dataprotection@stenori.com
• Mail: Wealthhub PLC, Data Protection Officer, London, United Kingdom

General Risk Warning

THE VALUE OF INVESTMENTS CAN GO DOWN AS WELL AS UP. YOU MAY GET BACK LESS THAN YOU INVESTED.

All investments carry risk. Before investing with Wealthhub PLC, you should carefully consider whether our services are suitable for your financial situation, investment objectives, experience, and risk tolerance. You should not invest money you cannot afford to lose.

This Risk Disclosure Statement outlines the main risks associated with investing through Wealthhub. It does not disclose all possible risks. You should seek independent financial advice if you are unsure whether our services are appropriate for you.

Past performance is not a reliable indicator of future results. Historical returns do not predict future performance, and you may experience significant losses.

Specific Investment Risks by Asset Category

Exchange-Traded Funds (ETFs)

ETFs form a core component of your portfolio allocation (typically 25-45%). Key risks include:

• Market Risk: ETF values fluctuate based on the performance of underlying securities. Broad market declines will reduce ETF values.
• Tracking Error: ETF returns may deviate from their benchmark index due to fees, trading costs, and fund management.
• Liquidity Risk: Some ETFs may have lower trading volumes, resulting in wider bid-ask spreads and difficulty trading at desired prices.
• Premium/Discount Risk: ETFs may trade at prices above (premium) or below (discount) their net asset value (NAV), particularly during market stress.
• Currency Risk: ETFs with international exposure create currency risk from exchange rate fluctuations.
• Concentration Risk: Sector-specific or thematic ETFs may be concentrated in particular industries, increasing risk.
• Counterparty Risk: Synthetic ETFs using derivatives face counterparty risk from swap providers.
• Expense Ratio Impact: ETF fees (typically 0.03-0.40% annually) reduce returns over time.

Real Estate Investments

Real estate exposure (typically 15-35% of portfolio) provides income and diversification but carries specific risks:

• Property Market Risk: Property values fluctuate based on economic conditions, interest rates, supply/demand dynamics, and location-specific factors.
• Interest Rate Risk: Rising interest rates typically depress property values and REIT prices. Mortgage costs increase, reducing profitability.
• Rental Income Risk: Tenant defaults, vacancies, or rent reductions reduce income. Economic downturns particularly affect commercial property.
• Liquidity Risk: Property is inherently illiquid. REITs provide better liquidity but can still experience trading difficulties during market stress.
• Leverage Risk: Many property investments use debt financing. High leverage magnifies both gains and losses.
• Sector-Specific Risks: Different property sectors (office, retail, industrial, residential) have varying risk profiles and can be affected differently by economic trends.
• Geographic Concentration: Property investments are location-specific. Regional economic downturns disproportionately affect local property values.
• Regulatory Risk: Changes to planning laws, building regulations, or taxation (such as changes to capital gains tax or stamp duty) can adversely affect property values.
• Environmental Risk: Climate change, flooding, and environmental regulations may impact property values and insurance costs.
• Distribution Risk: REITs may reduce or eliminate distributions during financial difficulties.

Renewable Energy Investments

Renewable energy exposure (typically 10-30%) offers growth potential but involves elevated risks:

• High Volatility: Clean energy stocks exhibit significantly higher price volatility than broad market indices.
• Policy and Regulatory Risk: Renewable energy valuations are highly sensitive to government subsidies, tax incentives, renewable energy mandates, and carbon pricing. Changes in government policy (e.g., reduction in feed-in tariffs or renewable obligation certificates) can severely impact values.
• Technology Risk: Rapid technological advancement can render existing technologies obsolete. Early-stage technologies may fail to achieve commercial viability.
• Commodity Price Risk: Input costs (polysilicon for solar, rare earth metals for wind turbines, lithium for batteries) fluctuate significantly.
• Competition Risk: Intense competition from established energy companies and new entrants can compress margins.
• Project Execution Risk: Development projects face construction delays, cost overruns, permitting challenges, and performance shortfalls.
• Financing Risk: Many renewable energy companies require significant capital investment. Access to financing may become restricted during credit market disruptions.
• Weather and Climate Risk: Solar and wind generation depend on weather patterns, creating revenue uncertainty.
• Grid Integration Challenges: Renewable energy intermittency creates grid stability issues. Storage solutions remain expensive.
• Political Risk: Changes in government (particularly in elections) can dramatically shift renewable energy policy.
• Sector Concentration: High allocation to a single sector increases portfolio volatility.
• Valuation Risk: Renewable energy stocks sometimes trade at elevated valuations based on growth expectations. Failure to meet expectations can trigger sharp corrections.

Foreign Exchange (Forex)

FOREX TRADING INVOLVES SUBSTANTIAL RISK OF LOSS AND IS NOT SUITABLE FOR ALL INVESTORS.

Forex exposure (typically 10-20%) provides diversification but carries extreme risks:

• Leverage Risk: Forex positions typically involve leverage ratios of 20:1 to 50:1 or higher. This means small adverse price movements can result in losses exceeding your invested capital in forex positions. Leverage magnifies both profits and losses.
• Extreme Volatility: Currency prices can change rapidly and dramatically due to economic data releases, central bank announcements, political events, or market sentiment shifts. Losses can accumulate very quickly.
• 24-Hour Market Risk: Forex markets operate continuously from Sunday evening to Friday evening (UK time). Significant price movements can occur when UK markets are closed, preventing timely intervention.
• Liquidity Risk: While major currency pairs are generally liquid, liquidity can evaporate during market stress, causing slippage and difficulty closing positions at desired prices.
• Interest Rate Risk: Currency values are heavily influenced by interest rate changes and central bank policy. Unexpected rate changes can trigger violent price movements.
• Political and Geopolitical Risk: Elections, referendums, political instability, terrorism, and military conflicts can cause sudden, severe currency moves. Brexit provides a recent example of extreme currency volatility.
• Central Bank Intervention: Central banks can intervene in currency markets, causing unexpected price movements. Some central banks maintain currency pegs that can break suddenly.
• Counterparty Risk: Forex trading involves counterparty risk with brokers and liquidity providers. Counterparty failure could result in inability to close positions or loss of funds.
• Correlation Risk: During market stress, currency correlations can change dramatically, reducing diversification benefits.
• Economic Data Risk: Economic releases (GDP, employment, inflation, trade balance) can trigger immediate, sharp currency moves.
• Slippage Risk: Rapid market movements may result in orders being filled at significantly different prices than expected.
• Gap Risk: Currencies can "gap" (jump in price) over weekends or around major news events, bypassing stop-loss orders.
• Systematic Risk: Forex strategies that work in one market regime may fail in others. No strategy works in all market conditions.

Warning: You can lose more than your initial investment in forex positions due to leverage. Forex is speculative and not appropriate for conservative investors.

General Portfolio Risks

Market Risk

Overall market conditions affect all investments. Economic recessions, financial crises, or broad market declines will negatively impact your portfolio value regardless of diversification.

Inflation Risk

Inflation erodes purchasing power. If portfolio returns do not exceed inflation, you experience a real loss in purchasing power even if nominal values increase.

Interest Rate Risk

Changes in interest rates affect multiple asset classes. Rising rates typically depress bond values, property values, and equity valuations while strengthening certain currencies.

Currency Exchange Risk

If you invest in a currency other than GBP, exchange rate fluctuations will affect your returns when converted back to GBP. Currency movements can be substantial.

Liquidity Risk

During market stress, normal liquidity can disappear. You may be unable to sell positions quickly at reasonable prices. Forced liquidation at unfavorable prices can result in significant losses.

Concentration Risk

While we diversify across four asset categories, your portfolio may be concentrated at times in particular sectors (renewable energy), asset types (real estate), or strategies (forex). Concentration increases the impact of adverse developments in those areas.

Rebalancing Risk

Monthly rebalancing involves selling strong performers and buying weaker positions. This systematic approach may underperform during strong trending markets. Rebalancing also generates transaction costs and potential tax liabilities.

Model Risk

Our portfolio allocation relies on systematic models and historical data. Models can fail during unusual market conditions or structural economic changes. Past relationships between assets may not persist.

Operational Risk

Operational failures (systems outages, errors in trade execution, settlement failures, fraud) can cause losses. While we maintain robust controls, operational risk cannot be completely eliminated.

Custodian Risk

Your assets are held by third-party custodians. While custodian insolvency is unlikely and FSCS protection applies (up to £85,000), there remains some risk to client assets.

Regulatory Risk

Changes in financial regulation, tax law, or investment rules may adversely affect your portfolio. New regulations may require portfolio restructuring or strategy changes.

Force Majeure

Extraordinary events beyond our control (war, terrorism, pandemics, natural disasters, cyber-attacks, market closures) may prevent normal portfolio management and cause severe losses.

Specific Account Type Risks

Stocks and Shares ISA

• ISA tax benefits depend on current tax law, which may change
• Investment losses within an ISA cannot be offset against other capital gains
• ISA annual subscription limit (£20,000 for 2024/25) restricts contributions
• Withdrawals from ISAs can be re-contributed, but only within annual allowance limits

Self-Invested Personal Pension (SIPP)

• Pension funds are generally inaccessible before age 55 (rising to 57 from 2028)
• Early access may be possible in cases of serious ill-health, but unauthorized withdrawals trigger severe tax penalties
• Pension tax relief depends on current tax law and your marginal tax rate
• Pension lifetime allowance has been removed, but annual allowance limits apply (£60,000 for 2024/25, subject to tapering for high earners)
• Pension drawdown rules and tax treatment may change
• 25% tax-free lump sum rules may be modified by future governments
• Pension death benefits taxation varies depending on your age at death and prevailing tax rules

Performance Risks and Disclaimers

No Performance Guarantees

Wealthhub makes no guarantees regarding investment performance:

• Past performance does not predict future results
• Illustrated or target returns are not guarantees
• No specific level of return is promised
• Your actual results may be significantly higher or lower than any targets
• Losses may exceed gains over any given period
• Different time periods will yield vastly different returns

Benchmark Comparisons

When comparing performance to benchmarks:

• Benchmarks are unmanaged and do not include fees or expenses
• You cannot invest directly in an index
• Benchmark composition and risk characteristics differ from your portfolio
• Benchmarks may not be appropriate measures of our multi-asset strategy
• We may outperform or underperform benchmarks over different time periods

Individual Results Vary

Your actual returns depend on many factors:

• Timing of deposits and withdrawals (pound-cost averaging vs. lump sum)
• Market conditions during your specific investment period
• Your risk profile and asset allocation
• Fees and expenses charged to your account
• Tax treatment of investment income and gains
• Rebalancing frequency and market timing

Costs and Charges Impact

All fees and charges reduce your returns over time:

• Management Fees: 0.15% annually reduces returns by this amount before performance fees
• Performance Fees: 15% of realized profits further reduces returns in profitable periods
• Underlying Fund Expenses: ETF expense ratios (0.03-0.40%) reduce returns from those holdings
• Transaction Costs: Trading costs, bid-ask spreads, and market impact affect returns
• Currency Conversion: Foreign exchange spreads reduce returns on currency-denominated positions
• Taxes: Income tax on dividends and capital gains tax significantly reduce after-tax returns

Compound Effect: Even small differences in fees compound significantly over long periods. A 1% annual fee difference can reduce 30-year returns by over 25%.

Tax Considerations

Wealthhub DOES NOT PROVIDE TAX ADVICE. CONSULT A QUALIFIED TAX ADVISOR.

Tax implications of investing include:

• Capital Gains Tax: Realized gains above the annual exempt amount (£3,000 for 2024/25) are subject to CGT at 10% or 20% depending on your income tax band
• Dividend Tax: Dividend income above the dividend allowance (£500 for 2024/25) is taxed at 8.75%, 33.75%, or 39.35% depending on your tax band
• Income Tax on Interest: Interest income above the personal savings allowance is subject to income tax
• Rebalancing Triggers Tax: Monthly rebalancing generates realized gains that may be taxable in non-ISA accounts
• Foreign Tax: International investments may be subject to foreign withholding taxes
• Tax Law Changes: UK tax rules change frequently. Future governments may increase tax rates or reduce allowances
• Reporting Obligations: You must report investment income and gains on your Self-Assessment tax return if required

ISA and SIPP wrappers provide tax efficiency but have their own rules and limitations as described above.

Discretionary Management Considerations

By granting us discretionary authority, you accept that:

• You cannot direct or control individual investment decisions
• You cannot request specific securities be bought or sold
• You will not be consulted before trades are executed
• We will make decisions we believe are in your best interest, but you may disagree with those decisions
• Portfolio allocation and strategies may change without prior notice
• You bear all investment risk regardless of our decision-making
• We may hold cash positions when we believe appropriate
• Actual allocation may deviate from target allocation temporarily

Capacity for Loss Assessment

Before investing, you must honestly assess your capacity for loss:

• Essential Funds: Never invest money needed for essential living expenses
• Emergency Reserves: Maintain 3-6 months of expenses in cash before investing
• Time Horizon: Only invest funds you won't need for at least 5 years
• Risk Tolerance: Be honest about how you would react to a 30-40% decline in portfolio value
• Financial Security: Consider your job security, income stability, and other financial commitments
• Age and Health: Consider your age and health when determining appropriate risk levels
• Other Assets: Assess total investment exposure across all accounts

Complaints and Compensation

Financial Ombudsman Service

If you have a complaint about our services, you may refer it to the Financial Ombudsman Service if you are not satisfied with our response:

• Website: www.financial-ombudsman.org.uk
• Phone: 0800 023 4567
• Email: complaint.info@financial-ombudsman.org.uk

Financial Services Compensation Scheme (FSCS)

Wealthhub is covered by the FSCS. If we cannot meet our obligations, you may be entitled to compensation:

• Investment Protection: Up to £85,000 per person for protected investment business
• What's Covered: Loss of investments if we or our custodian fails
• What's NOT Covered: Investment losses due to market performance or poor investment decisions
• Information: www.fscs.org.uk or 0800 678 1100

Your Acknowledgment

By opening an account with Wealthhub, you acknowledge and confirm that:

• You have read, understood, and accept this Risk Disclosure Statement in full
• You understand that all investments involve risk of loss
• You understand that you may lose some or all of your invested capital
• You understand the specific risks associated with ETFs, real estate, renewable energy, and forex
• You have honestly assessed your capacity for loss and financial situation
• You have determined that our services are suitable for your circumstances
• You accept full responsibility for investment outcomes
• You will seek independent advice if you have any doubts
• You will notify us of any material changes to your financial situation

Overview

Wealthhub PLC is committed to operating with the highest standards of regulatory compliance and ethical conduct. We are subject to comprehensive regulation and oversight designed to protect investors and maintain the integrity of financial markets.

This page provides information about our regulatory status, oversight agencies, compliance programs, and investor protections under UK law.

FCA Authorization

Authorized and Regulated Status

Wealthhub PLC is authorized and regulated by the Financial Conduct Authority (FCA) to conduct investment business in the United Kingdom.

• FCA Reference Number: [Insert FCA Reference Number]
• Company Number: [Insert Companies House Number]
• Registered Office: London, United Kingdom
• Permitted Business: Discretionary investment management, arranging deals in investments, safeguarding and administration of assets

Verification of Authorization

You can verify our FCA authorization and review our regulatory permissions at:

• FCA Register: https://register.fca.org.uk
• Search for "Wealthhub" or use our FCA reference number
• View our permitted activities and regulatory limitations
• Check our regulatory history and any disciplinary actions

FCA Regulatory Framework

As an FCA-authorized firm, we comply with comprehensive regulatory requirements including:

• Principles for Businesses: 11 fundamental principles governing our conduct
• Conduct of Business Rules (COBS): Rules for treating customers fairly and acting in their best interests
• Client Assets (CASS): Rules for safeguarding client money and assets
• Senior Managers & Certification Regime (SM&CR): Individual accountability framework
• Prudential Requirements: Capital adequacy and financial resources requirements
• Systems and Controls (SYSC): Governance, risk management, and compliance systems
• Financial Promotions: Rules for advertising and marketing communications
• Market Conduct: Market abuse prevention and transaction reporting

Companies House Registration

Wealthhub PLC is registered with Companies House:

• Company Number: [Insert Companies House Number]
• Company Type: Public Limited Company (PLC)
• Registered Office: London, United Kingdom
• Incorporation Date: 2013

You can view our company information, accounts, and filings at: https://find-and-update.company-information.service.gov.uk

Client Asset Protection (CASS)

Segregation of Client Assets

Wealthhub operates in full compliance with FCA Client Assets Sourcebook (CASS) rules. This means:

• Segregated Accounts: Your investments are held in segregated client money accounts separate from Wealthhub's own assets
• Statutory Trust: Client assets are held on trust, meaning they are legally protected in the event of our insolvency
• No Commingling: We do not use your assets for our own business purposes
• Daily Reconciliation: Client money and custody assets are reconciled daily to ensure accuracy
• External Audit: Client money arrangements are subject to independent annual audit

Approved Custodians

Your investments are held by FCA-regulated custodians meeting stringent requirements:

• Appropriate regulatory authorization
• Adequate financial resources
• Effective systems and controls
• Regular assessment and monitoring by Wealthhub

Client Money Distribution

In the unlikely event of Wealthhub's insolvency:

• Client assets would be identified and returned to clients
• Client money would be distributed to clients according to CASS rules
• You would be treated as a creditor for any shortfall
• FSCS protection would apply for eligible claims (up to £85,000)

Financial Services Compensation Scheme (FSCS)

What is FSCS?

The Financial Services Compensation Scheme is the UK's statutory compensation scheme for customers of authorized financial services firms. FSCS can pay compensation if a firm is unable, or likely to be unable, to pay claims against it.

FSCS Coverage for Investments

Wealthhub clients are covered by FSCS for protected investment business:

• Coverage Limit: Up to £85,000 per person per firm
• What's Covered: If we or our custodian fails and cannot return your investments or client money
• What's NOT Covered: Investment losses due to poor performance, market declines, or bad investment decisions
• Temporary High Balances: Higher limits (up to £1 million for 6 months) may apply for certain life events (e.g., property sale proceeds)

How to Claim

• Website: www.fscs.org.uk
• Phone: 0800 678 1100 or 020 7741 4100
• Post: FSCS, 10th Floor, Beaufort House, 15 St Botolph Street, London EC3A 7QU

Important Limitations

• FSCS only covers UK-regulated firms
• The £85,000 limit applies per person, per firm (not per account)
• Joint accounts are covered separately (up to £170,000)
• FSCS does not protect against investment losses from market movements
• Claims must be made within time limits (usually 6 years)

Anti-Money Laundering (AML) Compliance

Legal Framework

Wealthhub complies with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and related legislation. Our AML program includes:

Customer Due Diligence (CDD)

• Identity Verification: Verification using government-issued photo ID (passport, driving licence)
• Address Verification: Proof of address dated within last 3 months
• Source of Funds: Understanding the origin of funds used for investment
• Source of Wealth: Understanding how your wealth was accumulated
• Politically Exposed Persons (PEP): Enhanced due diligence for PEPs and their associates
• Beneficial Ownership: Identification of ultimate beneficial owners for entities

Enhanced Due Diligence (EDD)

We conduct Enhanced Due Diligence for higher-risk situations including:

• Politically Exposed Persons (PEPs)
• High-value accounts (typically over £100,000)
• Customers from high-risk jurisdictions
• Complex ownership structures
• Unusual transaction patterns

Ongoing Monitoring

We continuously monitor account activity for potentially suspicious transactions:

• Transactions inconsistent with customer profile
• Large or frequent cash-equivalent movements
• Rapid movement of funds (in and immediately out)
• Transactions involving high-risk jurisdictions
• Structuring to avoid reporting thresholds

Sanctions Screening

We screen all customers and transactions against:

• HM Treasury's Office of Financial Sanctions Implementation (OFSI) sanctions lists
• UN Security Council sanctions lists
• EU sanctions lists (where applicable)
• Politically Exposed Persons (PEP) databases

Suspicious Activity Reporting (SAR)

If we detect suspicious activity, we are legally obligated to file a Suspicious Activity Report with the National Crime Agency (NCA). Important points:

• We cannot inform you that a SAR has been filed (tipping off is a criminal offense)
• We may need to delay or refuse transactions while investigations occur
• Account closure may be necessary in some circumstances

Record Keeping

We retain AML records for at least 5 years after the business relationship ends, as required by law.

Data Protection and Privacy

UK GDPR Compliance

Wealthhub complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Key principles:

• Lawfulness, Fairness, Transparency: We process data legally and inform you clearly
• Purpose Limitation: We use data only for specified purposes
• Data Minimization: We collect only necessary data
• Accuracy: We keep data accurate and up to date
• Storage Limitation: We don't keep data longer than necessary
• Integrity and Confidentiality: We protect data with appropriate security
• Accountability: We can demonstrate compliance

Data Protection Officer

Our Data Protection Officer oversees compliance with data protection laws:

• Email: dataprotection@stenori.com
• Mail: Wealthhub PLC, Data Protection Officer, London, United Kingdom

Information Commissioner's Office (ICO)

We are registered with the ICO. You can lodge complaints about our data handling with:

• Website: www.ico.org.uk
• Helpline: 0303 123 1113
• Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Compliance and Risk Management

Compliance Function

Wealthhub maintains a comprehensive compliance function including:

• Compliance Officer: Dedicated compliance professional overseeing regulatory adherence
• Compliance Manual: Detailed policies and procedures covering all regulatory obligations
• Monitoring and Testing: Regular monitoring of compliance with FCA rules
• Training: Mandatory compliance training for all employees
• Breach Reporting: Procedures for identifying, reporting, and rectifying breaches

Risk Management

Our risk management framework identifies, measures, and manages key risks:

• Investment Risk: Portfolio risk monitoring and limits
• Operational Risk: Business continuity, systems, and controls
• Conduct Risk: Fair treatment of customers
• Financial Risk: Capital adequacy and liquidity management
• Cyber Risk: Information security and data protection

Internal Audit

We engage independent third parties to conduct periodic internal audits of:

• Compliance with FCA rules
• Effectiveness of systems and controls
• Client asset protection (CASS audit)
• AML and sanctions compliance
• Cyber security measures

Professional Indemnity Insurance

Wealthhub maintains Professional Indemnity Insurance as required by FCA rules. This insurance provides coverage for claims arising from professional negligence or errors in providing investment management services.

• Minimum coverage levels as specified by FCA rules
• Policy with A-rated insurer
• Annual renewal with gap coverage during renewal periods

Conflicts of Interest

Conflicts of Interest Policy

Wealthhub maintains a Conflicts of Interest Policy to identify and manage conflicts that may arise. Key conflicts and how we manage them:

• Fees: Our asset-based fees create incentive to grow accounts. Managed through fiduciary duty and fair treatment principles.
• Performance Fees: Could incentivize excessive risk-taking. Managed through disciplined risk management and adherence to customer risk profiles.
• Trade Allocation: Managing multiple accounts requires fair allocation. We have procedures ensuring equitable treatment.
• Related Parties: Any dealings with related parties are disclosed and conducted at arm's length.

Disclosure of Conflicts

Where conflicts cannot be adequately managed, we disclose them to you clearly before providing services. You can request our Conflicts of Interest Policy at any time.

Best Execution

Wealthhub has a duty to take all sufficient steps to obtain the best possible result when executing orders for clients. Our Best Execution Policy considers:

• Price
• Costs and fees
• Speed of execution
• Likelihood of execution and settlement
• Size and nature of the order
• Market conditions

We regularly review execution quality and our executing brokers to ensure we continue to achieve best execution. Our Best Execution Policy is available upon request.

Complaints Procedure

How to Complain

If you wish to make a complaint:

• Email: complaints@stenori.com
• Mail: Wealthhub PLC, Complaints Department, London, United Kingdom
• Phone: [Insert UK phone number]

Our Process

• Acknowledgment: We'll acknowledge your complaint within 3 business days
• Investigation: We'll investigate thoroughly and impartially
• Response: We aim to resolve complaints within 8 weeks
• Final Response: Our final response will explain our decision and your right to refer to the Financial Ombudsman

Financial Ombudsman Service

If you're unhappy with our final response, or if 8 weeks have passed without a final response, you can refer your complaint to:

• Financial Ombudsman Service: www.financial-ombudsman.org.uk
• Phone: 0800 023 4567 (free) or 0300 123 9123
• Email: complaint.info@financial-ombudsman.org.uk

You must refer your complaint within 6 months of our final response. The FOS service is free for consumers.

Regulatory Contact Information

Financial Conduct Authority (FCA)

• Website: www.fca.org.uk
• Consumer Helpline: 0800 111 6768
• Address: Financial Conduct Authority, 12 Endeavour Square, London E20 1JN

Financial Services Compensation Scheme (FSCS)

• Website: www.fscs.org.uk
• Phone: 0800 678 1100
• Address: FSCS, 10th Floor, Beaufort House, 15 St Botolph Street, London EC3A 7QU

Financial Ombudsman Service (FOS)

• Website: www.financial-ombudsman.org.uk
• Phone: 0800 023 4567
• Address: Exchange Tower, London E14 9SR

Information Commissioner's Office (ICO)

• Website: www.ico.org.uk
• Helpline: 0303 123 1113
• Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF