Version 2026.4   Effective from April 2026

These Terms of Business are applicable from April 2026 and set out the general terms under which we will provide business services to you and the respective duties and responsibilities of both ourselves and you in relation to such services. Please ensure that you read these terms thoroughly and if you have any queries we will be happy to clarify them. If any material changes are made to these terms, we will provide each affected consumer with a copy of the revised Terms of Business and a separate notice setting out the particulars of the changes, clearly showing the position before and after the change. This will be delivered on paper or another durable medium (which includes email) at least 5 working days before the change takes effect, in accordance with Regulation 62 of the Consumer Protection Regulations 2025 (S.I. No. 81 of 2025).

Our principal business is to provide advice and arrange transactions on behalf of clients in relation to Mortgage Lending, Life, Pensions and Investments. We provide our services from the selection of products provided by the Companies we have agencies with. We recommend the product that, in our professional opinion, is best suited to you. In providing this service to you we will need to obtain personal information from you and the following outlines how we deal with this information and how it is used. Any questions or concerns you have can be addressed to us directly.

A separate Data Privacy Notice sets out the bases on which we gather, use, process and disclose any Personal Data we collect about you, or that you provide to us. A copy is available on our website and on request. The Data Privacy Notice applies to you whether you are a current, past or prospective customer. Please ensure that you provide a copy of the Data Privacy Notice to any third parties whose personal data you provide to us.

1. Authorisation and Codes of Conduct

Finplan Limited trading as Finplan, Finplan Mortgages and Finlife is regulated by the Central Bank of Ireland as an insurance intermediary registered under the European Union (Insurance Distribution) Regulations 2018, as an Investment Business Firm and Investment Product Intermediary authorised under the Investment Intermediaries Act 1995 (as amended), and as a Mortgage Credit Intermediary authorised under the European Union (Consumer Mortgage Credit Agreements) Regulations 2016 and Section 151A(1) of the Consumer Credit Act 1995. Our reference code is C53556. Our authorisation can be verified on the Central Bank of Ireland register at www.centralbank.ie or by calling 01 224 4000.

We are also subject to the Consumer Protection Regulations 2025 (S.I. No. 81 of 2025), the Minimum Competency Code and the Fitness and Probity Standards, which offer protection to consumers. These Codes and Regulations are available on the Central Bank’s website.

2. Our Services

We are an Insurance, Investment and Mortgage Credit Intermediary. Our principal business is to provide advice and arrange transactions on behalf of our clients in relation to life, pensions, investments and mortgage products. We are members of Brokers Ireland.

We provide advice on a “Limited analysis of the market” basis, which means we provide our services on the basis of a limited number of contracts and product producers/lenders that we have an agency with. We advise you, in our professional opinion, from that selection which will best suit your needs and objectives. While not tied to one product producer, the services are not provided on the basis of a fair analysis of the market (i.e. all providers and products).

As part of the process when giving our clients advice on investments, we will need to gather information with regard to your investment knowledge and experience. If this information is not provided, we will not be in a position to determine whether the product is appropriate for you.

Unless you have requested otherwise, we will communicate with you electronically where possible. You have the right at any time to request that we provide communications to you in paper format. Please contact us if you wish to exercise this right and we will update your preferences accordingly.

3. Your Right to Cancel

Life Assurance and Protection Policies

If you have taken out a life assurance or protection contract with us, you may cancel the contract by giving written notice to us within 30 days of being informed that the contract is on cover. This right applies regardless of whether the contract was concluded face to face or at a distance. The giving of notice of cancellation will release you from any further obligation under the contract. No costs may be imposed on you other than the cost of the premium for the period during which you were on cover. This right does not apply where the contract is for a duration of six months or less.

Pension Contracts and Investment Products

If you enter into an agreement with us for pension or investment intermediary services on a distance basis, you have the right to cancel that agreement within 14 days from the date the agreement was concluded, or from the date you received the contractual terms and conditions, whichever is the later. To exercise this right, you must notify us in writing within that period.

Mortgage Credit

In respect of mortgage credit, your right of withdrawal and the applicable timeframe will be set out in the European Standardised Information Sheet (ESIS) provided to you before any binding offer is made. Please read the ESIS carefully as it contains the specific terms applicable to your mortgage.

How to Cancel

To exercise any cancellation right, please write to: Ross Harrison, Finplan Limited, Bankside, Charlemont Place, Dublin 2, D02 H590.

4. List of Providers We Have Agencies With

5. Mortgages

Through the lenders or other undertakings with which we hold an agency, Finplan Limited can provide advice on and arrange mortgage products from the following range: fixed-rate loans, variable rate mortgages, capital and interest mortgages, interest-only mortgages, pension mortgages and residential investment property. We provide mortgage advice on mortgages from the selection of lenders we have agencies with.

We will need to collect sufficient information from you before we can offer any advice on housing loans. This is due to the fact that a key issue in relation to mortgage advice is affordability. Such information should be produced promptly upon our request. Where the creditor is unable to carry out an assessment of creditworthiness because the consumer chooses not to provide the information or verification necessary for an assessment of creditworthiness, the credit cannot be granted.

6. Sustainability and Responsible Investing

Your Sustainability Preferences

Where we are providing advice on investment or pension products, we are required to ask about your sustainability preferences. We do this as part of our financial review process. Any preferences you express will be recorded in your financial review and taken into account in our recommendation, which will be reflected in your Statement of Suitability. Please note that your sustainability preferences will be considered alongside your primary financial needs and objectives and will not override them. Where your stated preferences cannot be fully accommodated from the range of products available through our panel, we will document this and explain the basis for our recommendation.

Principal Adverse Impacts

We are required to inform you under the Sustainable Finance Disclosure Regulation (SFDR) that we do not currently assess the principal adverse impacts of investment decisions on sustainability factors as part of our investment advice. This is because the standardised data needed to carry out a consistent and meaningful assessment across all products on our panel is not yet sufficiently available. We review this position annually.

Sustainability Information in Product Documentation

The product producers on our panel are subject to their own SFDR disclosure obligations. Information on how sustainability risks are managed within individual products is set out in the product documentation and Key Information Document provided to you before you proceed. You should read this documentation carefully.

7. Investment and Pension Risk Warnings

When providing advice on investment and pension products, we are required to draw your attention to the following important warnings:

These warnings apply to all investment and pension products we advise on, including unit-linked funds and insurance-based investment products. Additional product-specific risk information will be set out in the relevant product documentation provided to you before you proceed, including the Key Information Document (KID) where applicable. You should read all product documentation carefully before making any investment decision.

8. Remuneration

We are remunerated by commission and other payments from product producers on the completion of your business. You may choose to pay in full for our services by means of a fee. Where we receive recurring commission, this forms part of the remuneration for the services provided, which may include ongoing advice related to certain types of business. However, for some products such as life insurance policies (e.g. level term or mortgage protection), ongoing advice may not be applicable or required, and therefore these products may not be reviewable or changeable. In such cases, the commission reflects the initial advice and arrangement services provided at the time of taking out the product or policy.

Annual Updates

Where we receive recurring commission for pension or investment business, this forms part of the remuneration for the ongoing advisory service described in Section 11. In some cases, the product provider may deliver valuation statements directly to you. We will confirm the specifics of the service arrangements for your particular product(s) in your Statement of Suitability.

Additional Fees

We reserve the right to charge additional fees if the number of hours related to ongoing advice or assistance exceeds 8 hours.

Where fees are chargeable or where you choose to pay in full for our service by fee, we will notify you in writing in advance and agree on the scale of fees to be charged. Where it is not possible to provide the exact amount, we will provide you with the method of calculation of the fee. If we receive a commission from a product provider, this may be offset against the fee which we will charge you. Where the commission is greater than the fee due, the commission may become the amount payable to the firm unless an arrangement to the contrary is made.

A summary of the details of all arrangements for any fee, commission, other reward or remuneration paid or provided to us by the product producers is available on our website. If you need further explanation, please do not hesitate to contact us.

Clawback of Commission

Product producers and mortgage lenders may reclaim commission paid to us in certain circumstances, for example where a policy is cancelled or a mortgage is redeemed within a specified period of the business being placed. Where commission is reclaimed in these circumstances, this is a matter between Finplan and the product producer or lender. We will not seek to recover clawed-back commission from you as a client.

9. Mortgage Fees

We may receive up to 1% (or whatever maximum is applicable) of the loan for arranging mortgage finance from the lenders. The commission rate payable to us is 1% of the mortgage amount and is the same across all lenders on our panel. The actual amount of commission will be disclosed at a later stage in the ESIS (European Standardised Information Sheet) which will be forwarded to you. Information on the variation in levels of commission payable by the different creditors providing credit agreements being offered is available on request.

Please note that lenders may charge specific fees in certain circumstances and if this applies, these fees will be specified in your Loan Offer. You have the right to pay a fee separately and not include it in the loan. Typically, this situation arises in relation to specialist lending.

We reserve the right to charge fees for mortgages. The following fees will apply to mortgage applications below €300,000 unless agreed otherwise. Any fees payable will be agreed in advance:

The above fees will not apply if you are employed by one of our Employee Benefits Partners.

10. Client Monies and Receipts

We request that all cheques or negotiable instruments are made payable to the appropriate Product Provider for Life, Pensions, Investment business and lenders. We shall issue a receipt for each payment received; these receipts are issued with your protection in mind and should be stored safely. Every effort is made to ensure that clients’ money is transmitted to the appropriate Product Provider without delay. We are not authorised to accept cash.

11. Regular Reviews

Investment and Pension Business

Where we receive ongoing remuneration in respect of your pension or investment business, we provide you with an ongoing advisory service. We are available to you throughout the year to discuss your arrangements, answer queries, and assist you if your circumstances change. We will draw your attention to any significant developments that we consider may be relevant to your arrangements. In many cases, the product provider will also issue valuation statements directly to you. For pension products, this will typically be on an annual or six-monthly basis depending on the product. These provider statements do not replace the advice relationship with Finplan, and you should contact us at any time if you have questions about your policy or if your circumstances change.

If you would like a fuller review of your investment or pension arrangements at any time, please contact us and we will arrange this for you.

Protection and Mortgage Products

For life assurance, protection, and mortgage products, it is in your best interests to keep us informed of any changes in your circumstances that may affect your cover or your mortgage arrangements. Please contact us if your situation changes so we can advise whether your existing arrangements remain suitable for your needs.

12. Disclosure of Information

We act as your representative to the companies we have agencies with and we will provide assistance to you for any queries you may have in relation to the policies or in the event of a claim during the life of the policies. We will explain to you the various restrictions, conditions and exclusions attached to your policy. However, it is your responsibility to read the policy documents, literature and brochures to ensure that you understand the nature of the policy cover.

Material information about medical history, non-smoker status, occupation category and any hazardous pursuits are central to underwriting decisions and it is imperative that all information you provide to the insurer is accurate and complete. Any failure to disclose material information may invalidate a claim and render your policy void. You must inform and disclose any material information including any material changes that might take place between the time you complete an application form and the time you pay the first premium.

To assist us in providing you with a comprehensive service, please notify us of any changes to your personal circumstances, e.g. name change, change of address, etc.

13. Artificial Intelligence in Communications and Administration

We use Artificial Intelligence (AI) technology to support certain administrative functions, including drafting and summarising client communications, reviewing client information, and supporting the preparation of documentation. AI tools currently in use include features within our CRM system (Pipedrive) and other business productivity tools.

• AI is used solely to support the efficiency and accuracy of our administration. All advice, recommendations and assessments provided to you are carried out exclusively by qualified human advisers. No decisions about you or your financial products are made by AI. All decisions are made by a qualified human adviser.
• All AI-generated outputs are reviewed by a member of our staff before being used in any client communication or added to your file.
• Our use of AI for these administrative purposes is based on our legitimate interest in delivering an efficient and accurate service to our clients, balanced against appropriate safeguards for your rights and interests. Where clients consent to AI-assisted mortgage document processing, a separate AI Disclosure Notice is provided which sets out the specific tools, safeguards and rights applicable to that processing. For full details of how your personal data is processed, including in connection with AI tools, please refer to our Data Privacy Notice which is available on our website and on request.

14. Conflicts of Interest

It is our policy to identify and manage conflicts of interest fairly and in the interests of our clients.

Mortgage Business

We are remunerated by commission paid by mortgage lenders on the completion of mortgage business. The commission rate payable to us is 1% of the mortgage amount and is the same across all lenders on our panel. There are no volume-based bonuses, override commissions or tiered arrangements in place with any lender. As a result, our recommendation of a particular lender is not influenced by the commission it generates and is based solely on the suitability of the product for your individual circumstances and requirements.

Life Assurance, Pension and Investment Business

Commission rates paid by product producers vary between providers and between product types. This creates a potential conflict of interest in that we could, in principle, be influenced to recommend a product that generates a higher commission rather than one that is best suited to your needs. We manage this conflict by basing our advice on your personal circumstances, needs and objectives as established through our advice process. The product we recommend is selected on the basis of suitability for you, not on the basis of the commission it generates.

In all cases, we maintain a Conflicts of Interest Policy which sets out how we identify and manage conflicts of interest, and a copy is available on request. Where a conflict of interest arises that we are unable to adequately manage, we will disclose this to you in writing before providing any service. Our remuneration arrangements are set out in full in Section 8 of these Terms of Business.

15. Default on Payments by Clients

We will exercise our legal right to receive payments due to us from clients (fees) for services provided. Product producers may withdraw benefits or cover in the event of default on payments due under policies or other products arranged for you. We would refer you to policy documents or product terms for the details of such provisions.

16. Complaints

We have a complaints procedure in place which is available on our website at www.finplan.ie and on request. Your complaint can be made in writing, by email, by telephone or face to face. If your complaint is face to face or by phone we will write to you to confirm our understanding of your complaint. We will acknowledge your complaint within 5 working days if your complaint has not been resolved within those 5 working days, advising you of the name of the person dealing with your complaint. We will update you on our investigation within 20 working days and endeavour to have a final response for you within 40 working days. We will notify you if this timeline is not possible and inform you of the time it will take to provide you with a final response letter.

Please address any complaint to Ross Harrison, Finplan Limited, Bankside, Charlemont Place, Dublin 2, D02 H590.

If a complainant is dissatisfied with the outcome of our investigation, you are entitled to refer the matter to the Financial Services and Pensions Ombudsman (FSPO), 3rd Floor, Lincoln House, Lincoln Place, Dublin 2, D02 VH29. Tel: 01 567 7000. Email: info@fspo.ie. Web: www.fspo.ie. A complaint must generally be referred to the FSPO within 6 years of the date of the act or conduct giving rise to the complaint, or within 3 years of the date on which you first became aware of the act or conduct, whichever is the later.

17. Data Protection Complaints

If you are dissatisfied with how we handle your personal data or the use of AI in our services, you also have the right to complain directly to the Data Protection Commission at www.dataprotection.ie. Our Data Privacy Notice, available on our website and on request, sets out your full data rights including your right to access, correct, delete and restrict processing of your personal data.

18. Investor Compensation Scheme

We are members of the Investor Compensation Scheme. This provides for the establishment of a compensation scheme and the payment, in certain circumstances, of compensation to certain clients (known as eligible investors) of authorised investment firms, as defined in that Act. Compensation may be payable where money or investment instruments owned or belonging to clients and held, administered or managed by the firm cannot be returned to those clients for the time being and where there is no reasonably foreseeable opportunity of the firm being able to do so.

A right to compensation will arise only if the client is an eligible investor as defined in the Act; and if it transpires that the firm is not in a position to return client money or investment instruments owned or belonging to the clients of the firm; and to the extent that the client’s loss is recognised for the purposes of the Act. Where an entitlement to compensation is established, the compensation payable will be the lesser of 90% of the amount of the client’s loss recognised for the purposes of the Investor Compensation Act 1998, or €20,000. For further information, contact the Investor Compensation Co. Ltd. at (01) 224 4955.

19. Brokers Ireland Clients’ Compensation Scheme

We are also members of the Brokers Ireland Clients’ Compensation and Membership Benefits Scheme (BIC). Subject to the rules of the scheme, the liabilities of its member firms up to a maximum of €100,000 per client (or €250,000 in aggregate) may be discharged by the fund on its behalf if the member firm is unable to do so, where the above detailed Investor Compensation Scheme has failed to adequately compensate any client of the member. Further details are available on request.

20. Email Warning Regarding Account Details

21. Consumers in Vulnerable Circumstances

We are committed to supporting consumers who may be in vulnerable circumstances. Vulnerability may be permanent or temporary and can arise for many reasons, including serious illness, bereavement, cognitive decline, financial difficulty, or other life events that affect a person’s ability to engage with financial services.

Our staff are trained to recognise indicators of vulnerability and to respond appropriately. Where a member of staff identifies or reasonably suspects that a consumer may be in vulnerable circumstances, they will record this on the client’s file and ensure that additional care and appropriate assistance is provided throughout any advice or transaction process. We will review a consumer’s status on a regular basis to ensure our approach continues to reflect their circumstances.

If you feel that your circumstances may affect how you engage with our services, or if you would like to discuss any supports we can offer, please contact us at any time. We will treat all such information with the utmost sensitivity and in full compliance with our data protection obligations.

22. Trusted Contact Person

You may nominate a Trusted Contact Person (TCP), such as a family member, friend, or other trusted individual, whom we may contact if we have a concern about your welfare, your ability to engage with financial services, or a potential risk to your financial interests. The TCP has no authority to give instructions on your behalf or to access your account information without your explicit consent.

To nominate a TCP, we will ask you to complete a written consent form, and we will also obtain written confirmation from the nominated person that they are willing to act in this capacity. You may change or withdraw your TCP nomination at any time by notifying us in writing. Nominating a TCP is entirely voluntary.

23. Records Retention

We retain records relating to your business with us in accordance with our legal obligations under the Consumer Protection Regulations 2025 (S.I. No. 81 of 2025) and applicable data protection legislation. Where you engage with us and proceed to a product or service, we retain all relevant records for a minimum of 6 years from the date the business is completed.

Where you engage with us but do not proceed to a recommendation or product, we will, with your consent, retain relevant records for a period of 12 months. If you do not consent to this retention, records relating to the non-proceeded engagement will be deleted at the conclusion of that engagement, subject to any overriding legal obligation to retain them.

24. Governing Law and Business Succession

These Terms of Business shall be governed by and construed in accordance with the laws of Ireland and will be deemed to cover any successors in business to Finplan Limited.