The Compound Pension Terms and Conditions

This is an important document which sets out the terms and conditions of your Compound Pension, together with information on how your Compound Pension is operated and administered. It forms the contract between you, us, and the Product Provider. You should read this document carefully and keep it safe along with any other documents provided to you about your Compound Pension. Please contact Compound if you have any questions about these Terms.

References to “you”, or “your” mean the person who is applying for, or has successfully applied for, a Compound Pension.

References to “we”, “us” or “our” mean Compound.

References to “Product Provider”, “they”, “them” or “their” mean Quai Investment Services Limited.

Any references in these Terms to tax and legislation are based on the Product Providers understanding of current law and HMRC practice. Tax and legislation are likely to change in the future.

1. ROLES AND RESPONSIBILITIES

1.1 The provision and operation of the Compound Pension involves various entities; this section sets out the roles and responsibilities for each entity so you can clearly see who is involved and in what capacity they act.

1.2 Quai Trustees Limited is the Scheme Trustee and therefore the legal owner of all assets and cash held in respect of your Compound Pension.

1.3 Quai Investment Services Limited is the FCA regulated firm with the permission to operate a pension scheme and is the provider of the Compound Pension. It is responsible for the running of the Scheme and for executing the required functions of a Scheme Administrator and authorises you as a Member of the Scheme. Quai Investment Services Limited have appointed Quai Administration Services Limited to provide administrative support in connection with the Scheme.

1.4 Compound provides the Compound App to allow all interaction and communication with regards to the Compound Pension, including any communications from the Scheme Trustee and Scheme Administrator.

1.5 Compound is an appointed representative of Risksave Technologies Ltd, which is authorised and regulated by the Financial Conduct Authority.

2. Compound App

2.1 Availability

2.1.1 We will make reasonable efforts to make sure that our App and Website are available but cannot promise that you will always be able to access them at all times. We may suspend or withdraw or restrict the availability of all or any part of the App where necessary for business and operational reasons but will always try to give you notice if this happens. You may also have difficulties accessing the App because of problems with telephone or broadband networks or because you are in an area that does not have adequate telephone coverage. Neither us nor the Product Provider will not be liable to you if the Compound App is temporarily unavailable for any reason.

2.1.2 We have the right to suspend your access to the App at any time, if in our reasonable opinion you have failed to comply with any material provisions of these Terms.

2.2 Intellectual Property

2.2.1 We own or licence all intellectual property rights in our App, and in all of the material available on it. This material is protected by copyright laws and treaties around the world, and we reserve all rights in respect of this.

2.3 Security

2.3.1 You must use the Security Details that we give you to access your Compound Pension and to give us any instructions.

2.3.2 You must take all reasonable precautions to keep safe and prevent fraudulent use of your Security Details. You must take reasonable care not to disclose, or to allow the disclosure of, your Security Details. Please note that we will never ask for your password. You should not respond to any unsolicited emails which look as if they originate from us which ask you to enter your password or personal information. We will never issue emails of this type unless specifically requested by you to do so.

2.3.3 We and the Product Provider may rely on any instructions that are received whilst your Compound Pension has been activated using your Security Details.

2.3.4 You will be responsible for (and both Compound and the Product Provider shall be entitled to rely upon) any relevant instruction which is authenticated using your Security Details, unless you establish that the relevant instruction is not an authorised instruction and either:

(i) We and the Product Provider acted upon the relevant instruction after you had told us and them, or we and them had actual notice, that your Security Details or any other access details in relation to your Compound Pension had been disclosed to or otherwise obtained by an unauthorised third party or if the safety of these Security Details was in jeopardy; or
(ii) The unauthorised use of your Security Details or any other access details in relation to your Compound Pension (and our and the Product Provider’s reliance on the relevant instruction) did not result from your failure to take reasonable care to protect such details or otherwise to comply with your obligations under these Terms.

2.3.5 You should change your Security Details and contact us immediately if you know or suspect that any of your Security Details or any other access details in relation to your Compound Pension have been disclosed to, or obtained by, an unauthorised third party or if the safety of these Security Details may be in jeopardy.

2.3.6 Both Compound and the Product Provider will act on any instructions given in accordance with these Terms that appear, in both our and their opinion, to be valid, and have no duty to make any further enquiries in relation to such instructions.

‍

2.4 Communication

2.4.1 Our service is provided exclusively via the Compound App. However, we may also contact you by telephone, email, or post, using your details provided.

2.4.2 It is your responsibility to ensure that all of your details are kept current and up to date.

‍

2.5 Risks of Online Communication

2.5.1 We will take all reasonable measures to make sure that the security of our systems is not compromised. However, there are inherent risks in using an online system. Communications between you, us, and the Product Provider through the internet or by phone are not guaranteed to be secure or reliable. Neither us nor the Product Provider cannot guarantee that they will be free from:

(i) Technical failure or corruption; or
(ii) Error or delay; or
(iii) Misuse, fraudulent use, or access by unauthorised persons.

2.5.2 Both us and the Product Provider will not be liable for losses caused because of anything that is outside of our, or their, reasonable control.

2.5.3 It is recommended that you and any person acting on your behalf use anti-virus software on your computer or any other electronic device that you use to access the App.

3. Operating the Compound Pension

3.1 The terms of your agreement with us and the Product Provider are set out in these Terms, each Application, the Scheme Trust Deed and Rules and the Compound Pension Key Features (the Scheme Trust Deed and Rules will prevail in the event of any conflict).

3.2 We, and the Product Provider, do not provide advice about their products or allowable investments. The Compound Pension is only available to investors on an execution only basis. If for any reason you are unsure about the suitability of the Compound Pension for your financial circumstances, you should seek financial advice from an FCA authorised and appropriately qualified financial adviser prior to opening a Compound Pension.

3.3 The Compound Pension is only available through the Compound App if you are applying for a personal pension, or via your Employer for a workplace pension. When you open a workplace pension via your Employer, you will be given the relevant details on how to access the Compound App in your welcome email.

3.4 The Product Provider will act on all instructions transmitted to them from Compound on your behalf and they shall not be liable to you for any error that Compound may make in the detail or provision of such instructions.

3.5 All reports and documentation will be provided to you for access via the Compound App. In addition, the Compound website provides information about the Compound Pension, together with links to important information.

3.6 By applying for a Compound Pension, you agree that you do not require the Product Provider to provide reports, statements, contract notes or other documentation associated with your Compound Pension other than in electronic form via the Compound App. You must keep your contact details up to date so that we can notify you when any important documents are sent via the Compound App.

3.7 You accept that where we, or the Product Provider, are required to provide you with written notice then this will be given to you by means of electronic correspondence as set out above.

3.8 There may be circumstances which require the Product Provider to review these Terms and Conditions and the charges being made. In this event they will notify us, and we will notify you, of any amendments to these Terms at least 30 days prior to the change taking effect. However, the Product Provider does reserve the right in extreme circumstances to vary these Terms with shorter notice e.g., a change to an existing, or implementation of a new regulatory requirement which they must action immediately.

3.9 You authorise the Product Provider to provide HMRC, the FCA and any other relevant authority with all the relevant information about your Compound Pension and its investments as required by them.

3.10 In accordance with the FCA rules the Product Provider has categorised you as a Retail Client. As a Retail Client you will benefit from the greatest level of protection available under the regulatory system.

3.11 If you materially breach these Terms then we and the Product Provider reserves the right, without further notice, to close your Compound Pension account, require you to transfer out your Compound Pension account to an alternate provider; or any combination of these.

4. Joining the Compound Pension

The joining criteria and identity and tax residence checks sections below apply to both the personal pension and workplace pension. Please refer to the separate sections for additional Terms associated to the personal pension and workplace pension.

‍

4.1 Joining Criteria

4.1.1 Membership of the Compound Pension is at the Product Providers discretion.

4.1.2 You must be 18 years old or over. If you are 75 years old or over, you may open a Compound Pension via a pension transfer only (please refer to the Transfer In section below).

4.1.2 You may not open a Compound Pension jointly with anyone else.

4.1.3 You may only open a Compound Pension, if, at the time your Compound Pension is opened, you:

(i) Do not have dual tax residence and are resident for tax purposes solely in the United Kingdom; and
(ii) Have a permanent address in the United Kingdom; and
(iii) You are not a US person. For these purposes, a US person includes a citizen or resident of the United States of America. If you think you may be classed as a US person, please contact us for guidance.

4.1.4 If you stop being resident in the United Kingdom for tax purposes or stop having a permanent address in the United Kingdom, you must inform us. The Product Provider may, at their discretion, continue to hold your Compound Pension but you may not be able to make any further investments. The Product Provider may also have to report details of your Compound Pension to HMRC or other applicable authorities.

‍

4.2 Identity and Tax Residence Checks

4.2.1 Before your Compound Pension is opened, and during the course of the relationship, the Product Provider is required to carry out checks to verify your identity and tax residence in order to meet their legal and regulatory obligations, including under the UK Anti-Money Laundering and Counter-Terrorist Financing regulations. This may also include verification of any beneficial owner(s) of your Compound Pension, and anyone authorised to make payments into it.

4.2.2 The initial identity and tax residence checks are carried out by Compound on behalf of the Product Provider using approved electronic verification providers. These checks include verification of your name, address, date of birth, and National Insurance number, and screening against applicable sanctions and politically exposed person (PEP) lists.

4.2.3 In some cases, Compound may ask you to upload copies of identification or proof-of-address documents to complete the verification process.

4.2.4 Your Compound Pension account may be opened while these checks are ongoing, however, you will not be able to contribute, transfer, or withdraw funds until the checks have been successfully completed and confirmed to the Product Provider.

‍

4.3 Personal Pension

4.3.1 Your Compound Pension will be set up when we receive all necessary information from you or when all of our requirements have been met if this is later. The Product Provider reserves the right, at their absolute discretion, to refuse your Application without providing any reason for their decision. You will receive confirmation via email or via the App that your Application has been accepted.

4.3.2 You have the right to cancel your Application. You can find the cancellation form in the Compound Pension Key Features Document, and you have 30 calendar day from receipt of confirmation that your Application has been accepted to inform us that you have changed your mind and wish to cancel your Application. We will proceed with your Application during the cancellation period and follow any investment instructions that you have given to us during this period.

4.3.3 Where investments are made during this 30-day cancellation period, and we receive a valid notice of cancellation, you will be responsible for subsequently instructing disinvestment. Neither we nor the Product Provider will be liable if the amount realised is less than the cost of acquiring the investments.

4.3.4 Where you decide to exercise your right to cancel, we and the Product Provider are entitled to retain any fee for setting up your Compound Pension, but do not normally do so. However, where costs have been incurred by a third party, the amount incurred by that third party will be deducted from any amount returned.

‍

4.4 Workplace Pension

4.4.1 Your employer may automatically enrol you into the Compound Pension. If you do not want to be in the Compound Pension, you can opt out at any time. When you are enrolled you will be provided with information on how to do this from your employer. If you opt out within 30 days of being automatically enrolled, you will get back any contributions you have paid in, and you will be treated as if you never joined.

4.4.2 If you decide to opt out after 30 days, you will not get back the money you have already paid in and it will remain invested, together with any money paid in by your employer, until you are at normal minimum retirement age.

4.4.3 Once you have opted out, you can opt in again at any time and, whilst you are still eligible, your employer must automatically re-enrol you into a Qualifying Pension Scheme every three years. If this happens, you can opt out again, as explained above.

4.4.4 If you leave your current employer, or decide to stop contributing to your Compound Pension, your pension savings remain with us. Even if you move jobs or become self-employed you can keep paying into your Compound Pension account. Alternatively, you may be able to transfer the value of your Compound Pension to another Registered Pension Scheme.

5. Contributions

The general section below applies to both personal contributions and contributions made by your employer in respect of your workplace pension. Please refer to the separate sections for additional contribution terms associated to any personal contributions and contributions made by your employer.

‍

5.1 General

5.1.1 The Product Provider will not accept contributions to your Compound Pension if you are no longer eligible to make contributions to the Scheme.

5.1.2 The Product Provider may decline to accept any contributions into your Compound Pension if it does not comply with the requirements of the Scheme Rules or the Finance Act.

5.1.3 Contributions to your Compound Pension cannot be refunded other than:

(i) In accordance with your instruction to a) cancel your person pension, or b) to opt out of your workplace pension; or
(ii) Where conditions are met to allow a ‘refund of excess contribution lump sum’ payment to be made i.ie., where your contribution exceeds your earnings in a tax year; or
(iii) Where explicit instruction is received from HMRC or other relevant authorities.

‍

5.2 Personal Contributions

5.2.1 Contributions may be single or regular and can only be paid in Sterling. The minimum contribution you can make is £25.

5.2.2 Single contributions can be made by bank transfer using the variable Direct Debit service available through the Compound App.

5.2.2 Regular contributions will be collected from your bank account, by direct debit on the defined day of the month unless that is not a Business Day in which case, the direct debit will be taken on the next available Business Day. If you want to change the amount of your regular contribution or cease making a regular contribution, then we must receive your instruction at least 10 Business Days before the regular contribution is due to be taken otherwise your change or cessation will only take effect for the following month.

5.2.3 Personal contributions will normally be treated as having been paid net of basic rate tax. Where applicable, the Product Provider will automatically claim basic rate tax relief from the government on your behalf and apply it to your Compound Pension. They will do this on any applicable contribution, whether it’s a single or regular contribution and you will continue to receive tax relief until your 75th birthday.
If you pay one of the higher rates of income tax, you’re entitled to receive tax relief at the higher rate; this additional relief is claimed through your annual self-investment tax return, or by applying direct to HMRC and is paid to you, not your Compound Pension.
To benefit from tax relief, you must be a relevant UK individual. This means that you must be:

(i) In receipt of Relevant UK Earnings; or
(ii) A resident in the UK for at least part of the Tax Year; or
(iii) A resident in the UK in one or more of the preceding five Tax Years and when you joined the Compound Pension: or
(iv) A crown servant, or the spouse or registered civil partner of a crown servant.

HMRC may take several months to process the tax reclaim and any money reclaimed is not available for investment until the Product Provider has received it from HMRC.

5.2.4 When completing the application declaration, amongst other things, you are confirming that your contribution is eligible for tax relief. The Product Provider does not accept personal contributions that are not eligible for tax relief.

5.2.5 If you make contributions to your Compound Pension which, when combined with contributions to other UK pension schemes, exceed the amount of which you are entitled to tax relief, the Product Provider may agree to refund the excess contributions to you provided there is sufficient cash in your Compound Pension to make the refund to you and repay any amounts due to HMRC. Any investment loss or growth in respect of a refunded contribution will be deemed to be outside the Scheme.

5.2.6 You are responsible for informing us by the 5th April in the year of assessment in which the event occurred or within 30 days after the event occurred (whichever is the latest), if you are not entitled to tax relief on all or part of your contribution. As a guide, circumstances where you may not be entitled to tax relief on your contributions are where, at the end of the Tax Year, your contributions exceed the higher of the basic amount or 100% of your Relevant UK Earnings.

5.2.7 If you make a payment by direct debit and seek to clawback that payment your Compound Pension will be disinvested to cover the amount being reimbursed as well as any tax relief, the Product Provider may have claimed on your behalf from HMRC. The relevant cash amount will then be deducted from your Compound Pension and any tax relief will be returned to HMRC. If there are insufficient assets in your Compound Pension to cover the reimbursement amount, you will be held personally liable for the outstanding balance, and we will contact you to settle the outstanding amounts.

‍

5.3 Employer Contributions

5.3.1 Under automatic enrolment, there is a minimum total contribution that must be paid into your workplace pension. These amounts are set by auto-enrolment legislation, and you can find details at gov.uk/workplace-pensions.

5.3.2 Regular contributions will be paid to the Product Provider by your employer. Contributions will be made from either your net salary or by using salary exchange (also known as salary sacrifice). Your employer will inform you which contribution method is applicable to your workplace pension. The below explains the difference between both choices.

‍

Contributions made from your net salary:
Your contributions are taken from your salary after tax and National Insurance Contributions (NIC). In this case your contributions are eligible for tax relief. Please refer to the ‘personal contribution’ section above for how the Product Provider will claim tax relief on your behalf.

‍

Contributions made by salary exchange (also known as salary sacrifice):
This is an agreement between you and your employer where you voluntarily exchange part of your gross salary in return for an employer pension contribution into your Compound Pension.
Because your salary is exchanged rather than paid directly to you, you will not pay tax or National Insurance Contributions (NIC) on the amount you have exchanged. Therefore, tax relief is not eligible on these contributions.

5.3.3 The Product Provider will require your employer to complete a contribution schedule which indicates the payments they are committed to making on your behalf. Where payments are not forthcoming, the Product Provider is obliged to notify The Pensions Regulator.

5.3.4 You can increase or decrease your contributions at any time. If you stop your contributions altogether, your employer may also stop contributing too. If you would like to alter your payments, please talk to your employer in the first instance.

5.3.5 You can make personal contributions to your workplace pension. Your employer may allow you to do this from their payroll but if not, you can make them directly to the Product Provider. Please refer to the ‘personal contribution’ section above.

6. Transfers

6.1 Transfers In

6.1.1 Subject to the Product Provider’s consent, applicable legislation and HMRC rules, you may Transfer In cash from another UK registered pension scheme into your Compound Pension. Alternatively, if you are transferring a pension where investments are held via an investment platform service and the pension investments that are held are also available under the Compound Pension, then you may request for those investments to be transferred In-specie.

6.1.2 For all transfers it is your responsibility to ensure a transfer of pension benefits is in your best interests, therefore, you should consider taking advice from a suitably qualified financial adviser. The Product Provider’s acceptance of a transfer is in no way an endorsement of the suitability of the transfer for your circumstances.

6.1.3 The Product Provider does not accept transfers of defined benefits or safeguarded rights of any size.

6.1.4 You have the right to cancel each transfer that the Product Provider receives from other pension providers. You have 30 calendar days from receipt of your Transfer In funds to notify us that you have changed your mind and wish to cancel your transfer. The Product Provider will follow any investment instruction you have given to us during this 30-day cancellation period. Under the cancellation terms, if you choose to exercise your cancellation right, any investment acquired by the transferred monies will be sold, and together with any uninvested cash from the Transfer In, will be returned to the original pension provider. The amount to be repaid may be less than the original amount received by the Product Provider if the value of investments has fallen at the time it is sold.
PLEASE NOTE: It may not always be possible to return a pension transfer payment to the original pension scheme if you cancel after the transfer has been received by the Pension Provider. In these circumstances you will need to arrange for another pension scheme to accept the transfer. Any funds will be retained until such a time as a replacement provider has been notified to us.

6.2 Find and Combine

6.2.1 You may use the Compound find and combine service within the Compound App to locate and transfer your old workplace pensions into your Compound Pension.

6.2.2 When you or your employer applies for your Compound Pension, we ask for some personal information about you (such as name, date of birth and National Insurance number). We will use this information to locate your pension arrangements on your behalf to determine which ones are Qualifying Pension Arrangement(s).

6.2.3 By providing your signature in the find and combine service within the Compound App you authorise and agree for us to:

(i) Search for your pension arrangement(s) which are in existence at the date on which you provide your signature; and
(ii) Communicate with the providers and/or trustees of your existing pension arrangements in order to obtain the relevant information by using one or multiple methods of communication, including but not limited to those listed below:

a. Letter of Authority (LoA). This will be a standard LoA which contains an electronic or physical (wet ink) copy of your signature; and/or
b. Activating/registering your online pension account with your current pension provider; and/or
c. Emails; and/or
d. Phone calls; and/or
e. Physical post; and
(iii) Communicate with your previous employers to obtain relevant information about your pensions; and
(iv) Share your personal information in order to assist with finding your pension.
(v) Subject to your authorisation, we may generate a wet signature from your digitally rendered signature for the purpose of transferring your pension.

6.2.4 Where we have been able to locate your pension arrangement(s), you will be presented with the information in the Compound App, at which point you can choose whether or not to proceed with the transfer into your Compound Pension.

7. Cash

7.1 All monies received by the Scheme Trustee in respect of your Compound Pension will be held by them as the Trustee, in an account designated as a trust account segregated from their own funds in accordance with the FCA Rules. The trust account is a pooled account with one or more banks; in the event of a bank’s failure, your claim will be for a share of the cash held in all pooled accounts at the bank.

7.2 The banks the Product Provider and the Scheme Trustee use are entirely independent of them. They will exercise reasonable skill and care when selecting and monitoring such banks, but they do not accept any liability for any default or delay in the distribution of funds in the event of their failure. Interest may be payable on accounts containing your money. Any interest earned will be retained by the Product Provider.

8. Investments

The general section below applies to both the personal pension and workplace pension. Please refer to the separate sections for additional investment terms associated to the personal pension and workplace pension.

8.1 General

8.1.1 The Compound Pension is an execution only service and neither we nor the Product Provider is required to assess whether the investment options available are appropriate for you. This means that neither we or the Product Provider have not determined whether these are suitable for your personal circumstances, knowledge, or experience of investments. If you are unsure as to the suitability of any investment for you, you seek advice from a regulated independent financial adviser.

8.1.2 The Product Provider will accept instructions from us, on your behalf, to acquire investments for your Compound Pension. This is subject to:

(i) The completion by you of additional documentation if requested by them; and
(ii) The legislation applicable to Registered Pension Schemes; and
(iii) All other relevant statutory provisions.

8.1.3 The Product Provider will be entitled not to acquire an investment in accordance with your instructions if:

(i) Insufficient cleared funds are available in your Compound Pension; or
(ii) In their reasonable opinion, the carrying out of the instruction is impossible, unlawful, or impracticable; or
(iii) They have given you notice to transfer your Compound Pension to another Registered Pension Scheme in accordance with these Terms and in their reasonable opinion it is not practicable to complete the acquisition of the investment before the date on which your Compound Pension must be transferred or the investment is illiquid; or
(iv) In their reasonable opinion, the acquisition of such an investment may impose tax or other costs on them or liabilities which in each case they may not be able to meet from your Compound Pension; or
(v) In their opinion, acquiring any investments may require them to offer to purchase further shares pursuant to the City Code of Takeovers and Mergers or any other code or legislation, or any further assets.

The Product Provider will inform us if they do not acquire an investment on your behalf.

8.1.4 The Product Provider will use all reasonable endeavours to execute any instruction they receive in accordance with these terms and conditions promptly. This is not always possible, so provided that they do not act unreasonably, then they will not be liable for any loss or profit forgone between the time an investment instruction was received and when it was executed.

8.1.5 The Product Provider will only make available investments that are in accordance with the legislation governing the investments of Registered Pension Schemes or any other relevant statutory provision. The Permitted Investments broadly comprise:

(i) Stocks and shares quoted on the UK stock exchange that has a ‘Recognised Investment Exchange’ status, including securities traded on the Alternative Investment Market (AIM)
(ii) Unit trusts and investment trusts (including OEICs)
(iii) Deposit accounts; and
(iv) Government and Corporate bonds.

The Product Provider does not support investments in so called “esoteric” or other non-mainstream products.

8.1.6 The Permitted Investments available for your Compound Pension are set out in the Compound App.

8.1.7 All investments other than cash are held by the Product Provider in an appropriate nominee name with a third-party custodian or held directly in the name of the Trustee. The Trustee is the legal owner of all cash and assets within the Scheme.

8.1.8 The Product Provider will be entitled to dispose of any investments if in their reasonable opinion:

(i) Continued retention of such investment would be unlawful or would impose tax or other costs on them or expose them to liabilities which in each case they may not be able to meet from your Compound Pension; or
(ii) They need to dispose of that investment to meet any fees or charges payable from your Compound Pension which they may otherwise not be able to meet from your Compound Pension; or
(iii) That investment is no longer a Permitted Investment as described in point 8.1.5 above; or
(iv) A disposal of the investment is required by the terms of any agreement to which they are a party.

8.1.9 The Product Provider will not exercise voting rights in respect of any investment unless you ask them to; however, they are not under any obligation to vote in accordance with your wishes. The Product Provider will not appoint a proxy in respect of any investments in your Compound Pension.

8.1.10 The Product Provider will not be responsible for any loss (including loss of profit) in relation to, or diminution in value of, any investment:

(i) Acquired by them at your request unless such loss of diminution results from fraud, wilful misconduct, negligence or breach of regulatory duty, or the fraud, wilful misconduct, negligence, or breach of regulatory duty of any of their employees or agents; or
(ii) Not acquired by them or not disposed by them in accordance with their rights under these Terms; or
(iii) Disposed of by them in accordance with these Terms unless such loss of diminution results from their fraud, wilful misconduct, negligence, or breach of regulatory duty of any of their employees or agents; or
(iv) Which results from any action or omission of any nature whatsoever by any investment manager or by any nominee, banker, custodian, or other person providing services to any investment manager.

Notwithstanding their entitlement not to acquire or dispose of any investment as requested by you or to dispose of an investment without consultation, they will not be under any duty to consider, or advise on, the general or specific merits or suitability of any actual or proposed investment or disposal.

8.1.11 The Product Provider reserve the right to amend the types of investments at any time. Where possible, however they will only reduce the range of types of investments after giving you 3 months’ notice.

8.1.12 If tax is deducted from your investment which is reclaimable by the Trustee, then the Product Provider will reclaim this money from HMRC and credit it to your Compound Pension. Such tax reclaims will be submitted to HMRC by the 31st January following the tax year in which the deduction was made. The credit will be applied to your Compound Pension once it is received from HMRC.

8.2 Personal Pension

8.2.1 When you open your Compound Personal Pension via the Compound App, your account will be allocated a default investment option based on your retirement age. This default option is a Vanguard Target Retirement Fund. No contributions are invested until you decide to pay into your pension, at which point you can either remain in the default option or select a different fund from the range offered.

8.2.2 You may change your choice of fund at any time via the Compound App. If you choose to do this, it is referred to as a switch, which will involve the sale of units from your current fund and the purchase of units in your new chosen fund.

.8.2.3. All contributions and transfers will be invested into the fund you have chosen at the time of payment.

‍

8.3 Workplace Pension

8.3.1 When you are enrolled into your workplace pension, a default investment option is selected based on your retirement age. This investment option is a Vanguard Target Retirement Fund and details of this will be provided by your employer.

8.3.2 You can change your investment fund at any time via the Compound App. If you choose to do this, it is referred to as a switch, which will involve the sale of units in your existing fund and the purchase of units in your new chosen fund.

8.3.3 All contributions and transfers will be credited to either the default fund or the fund(s) you have subsequently chosen.

9. Dealing

9.1 The Product Provider is responsible for arranging the execution of any Order they receive from you via us. You may only place Orders for Permitted Investments available to you through the Compound App.

9.2 You are responsible for the accuracy of your Orders. You may not be able to cancel or change an Order after you have submitted it.

9.3 You must have sufficient Available Cash or Available Investments to settle any Orders that you place together with any related charges.

9.4 The Product Provider reserves the right for any reason to refuse to execute an Order, but they will act reasonably in doing so. There may be circumstances, including (without limitation) suspension of dealing in extreme market conditions in which they may not be able to execute an Order. They will, if possible, notify you, via us, of the reason. Provided they have acted reasonably, then they will not be liable for any loss or profit foregone between the time an Order was received and when it was executed, if ever.

9.5 The Product Provider may combine your Order with other customers’ orders if they reasonably believe that this will not be to your disadvantage. The Product Provider may have to execute your Order in tranches and provide an average price per Order.

9.6 If the Product Provider receives an Order from you via us then:

(i) In the case of an Order to buy a fund, arrange to pass that Order on the next Business Day to the relevant fund manager for execution; and
(ii) In the case of an Order to sell a fund, arrange to pass that Order no later than the next Business Day to the relevant fund manager; and
(iii) In any other case, arrange to pass that Order to an appropriate broker to execute on the relevant exchange. If this Order cannot be completed before the exchange closes at the end of the first Business Day, then it will be cancelled, unless you have instructed Compound to continue to try and execute it on the following Business Day.

Our record of the time and receipt and execution of an Order will be conclusive unless it is obvious that it is wrong.

9.7 You must notify Compound if you receive confirmation of an order which you did not place, or which has not been completed in accordance with your instructions.

9.8 We will send you contract notes (via the Compound App or email) confirming the details of your transaction by the end of the Business Day in which we receive confirmation from the market of the terms under which your Order has been executed, or in relation to funds, by the end of the Business Day after we have received it from the relevant fund manager.

9.9 Compound and the Product Provider’s Order Handling policies are available on request.

10. Fees, Charges and Expenses

10.1 The fees and charges payable and the timing of these fees in respect of your Compound Pension and the circumstances in which they may be increased are set out in the Compound Charges Guide which is available via the Compound App as amended from time to time.

10.2 We will also be entitled to charge the following costs to your Compound Pension:

(i) All expenses incurred by us (including claims, losses, and liabilities) in acquiring, holding, disposing of, or valuing any investment or other assets of your Compound Pension; and
(ii) All fess, charges, disbursements, and other costs charged by any investment manager, nominee, banker, custodian, anyone else providing related services or agent appointed in relation to your Compound Pension or any part of your Compound Pension; and
(iii) All taxes, duties, or levies to which we become liable as a result of acquiring, holding, or disposing of any investment or other asset allocated to your Compound Pension; and
(iv) An amount equally to any tax for which we become (or reasonably expect to become) liable in respect of your Compound Pension if your Compound Pension does not constitute or ceases to constitute pension business as defined in Section 431b of the Income and Corporation Taxes Act 1988 (ICTA).

10.3 We may reimburse ourselves in respect of liability, charges, or costs by way of making a charge to your Compound Pension as we may reasonably determine which we have incurred as a result of one of the following events occurring:

(i) We become liable to pay any levies in relation to the Financial Services Compensation Scheme; or
(ii) We become liable to pay any tax or levies imposed on your Compound Pension or on any contribution paid by you; or
(iii) We become liable to make any other payment to the UK Government or any governmental agency or self-regulatory organisation of which we are (or become) a member, to the extent directly or indirectly attributable to your Compound Pension.

The above will not apply to the extent that the relevant event is attributable, directly, or indirectly, to any fraud, negligence, wilful default, or regulatory breach on our part.

10.4 All charges, costs, and liabilities which we are entitled to charge to your Compound Pension will be paid by us from your Compound Pension. If at any time the credit balance in your Compound Pension is not enough to cover all such charges, costs, and liabilities in full, we may:

(i) Dispose of any investments at their discretion and without liability in order to pay the amounts due; or
(ii) Require you to pay them the amounts due.

If for any reason the value of your investments is insufficient to meet any such fees, charges, expenses, tax, or scheme sanction charges payable or tax refunds due, you agree to pay the Product Provider on demand the amount of any such shortfall.

11. Limits and Allowances

11.1 Annual Allowance

11.1.1 The government has put in place an Annual Allowance which includes any money that you and your employer contribute to the Compound Pension, or any other pension savings you may hold. Any tax relief you receive will count towards your allowance too. If you exceed the Annual Allowance, you will pay tax on any amount paid above it.

‍

11.2 Money Purchase Annual Allowance

11.2.1 Once you have accessed your pension savings, the total contributions you can make over a tax year may be limited depending on how you accessed your money. This limit is called the Money Purchase Annual Allowance. It applies to all pension savings you may have and will apply from the point that you first access them.
It is your responsibility to monitor contributions made into your Compound Pension against the Annual Allowance and Money Purchase Annual Allowance. If you become subject to the Money Purchase Annual Allowance as a result of accessing your pension savings, you must inform us of this immediately and provide the date that this occurred.
These sections 11.1 and 11.2 are only intended to summarise pension tax legislation, Please refer to gov.uk website for up-to-date information on tax rates and allowances. Understanding the Annual Allowance and how it could affect you is very important. If you think your contributions may exceed any of these allowances, we and the Product Provide recommend you seek advice from a FCA authorised and appropriately qualified financial adviser.

‍

11.3 Lump Sum Allowance

11.3.1 This is a limit on how much tax-free cash you can take from your pension, either via a Pension Commencement Lump Sum (PCLS) or the 25% tax free portion of an Uncrystallised Fund Pension Lump Sum (UFPLS). This will be set at £268,275.00.

‍

11.4 Lump Sum and Death Benefit Allowance

11.4.1 This is the total limit on tax-free withdrawals from your pension, along with any Serious Ill Health Lump Sums and Deceased payments where they are paid tax free. This will be set at £1,073,100.00.
If the value of tax-free cash that you take from your pension arrangements exceeds either the Lump Sum Allowance or Lump Sum and Death Benefit Allowance, you will be liable to pay a tax charge on the amount over it. Any applicable charge(s) will be deducted from your Compound Pension before any money is paid to you.

12. Payments Out

12.1 Taking Benefits

12.1.1 You may normally choose to Crystallise some or all of your Compound Pension at any time on or after Minimum Pension Age. An application to take benefits must be made via the Compound App, or any such alternative means as we make available to you.

12.1.2 If you choose to take pension benefits from your Compound Pension then you should seek financial advice or seek guidance from MoneyHelper at https://www.moneyhelper.org.uk. If you do not wish to do this, we will accept authorised instructions from you directly but the Product Provider may require further attestations and declarations to ensure that you have understood the potential risks.

12.1.3 You may be able to Crystallise your Compound Pension before Minimum Pension Age if:

(i) The Product Provider is satisfied that you are, and will continue to be, incapable of carrying on your current occupation due to physical or mental impairment. You will need to provide evidence that they require; or
(ii) You had transitional rights at April 2006 to a protected pension age under Schedule 36 of the Finance Act 2004 and you satisfy the conditions.

12.1.4 When you Crystallise part or all of your Compound Pension to draw benefits you can normally choose to take up to 25% of the amount Crystallised (subject to your Lump Sum Allowance) as a Pension Commencement Lump Sum. A higher or lower amount may be available if you had transitional rights at 6 April 2006 and you satisfy the conditions.

12.1.5 If the value of the tax-free cash taken from your pension exceeds your personal Lump Sum Allowance or Lump Sum and Death Benefit Allowance there will be an additional tax charge, based on your marginal rate of tax.

12.1.6 The remainder of the amount Crystallised after the payment of any Pension Commencement Lump Sum, any pension commencement excess lump sum and any additional tax charge will be allocated to provide a pension Income for you in the form of:

(i) Flexi-access Drawdown; or
(ii) A lifetime annuity bought from an insurance company of your choosing; or
(iii) A combination of the above; or
(iv) A small funds lump sum; or
(v) An Uncrystallised Pension Lump Sum.

12.1.7 If you choose to take Flexi-access Drawdown then:

(i) You can request regular or ad hoc payment of Income directly from your pension. There is no maximum or minimum limit on how much you can withdraw each year, however, we may require you to maintain a minimum amount in your Compound Pension if you wish for it to remain open.
(ii) If you request a regular Income, the Product Provider will pay your pension Income at the frequency you request. They will make the payments by direct credit to your personal bank account net of all relevant taxes. In the event of your death the Product Provider will cease making any further payments to your personal bank account.
(iii) You can ask us to instruct the Product Provider to increase, reduce, stop, or restart payments or make one-off payments from time to time. If you wish to change the level of your payment you must ask us at least 10 Business Days before the payment date.
(iv) You must ensure that sufficient cleared funds are held in your Compound Pension 10 Business Days before the payment date, or the Product Provider will not be able make the payment. If insufficient funds are available to make the payment in full, the Product Provider will not make a partial payment.
(v) The day the Product Provider first makes a payment of Income to you from your Flexi-access Drawdown fund, or via a Small Pot Lump Sum, you will become subject to a reduced Annual Allowance, known as the Money Purchase Annual Allowance (MPAA) for the remainder of your lifetime. We will notify you this has occurred and the effective date. It is your responsibility to inform any other pension schemes of which you are a member and to ensure that your contributions to all pension schemes (including your Compound Pension) remain within the permitted maximums.
(vi) You can choose to buy a lifetime annuity at any time with part of, or the entire drawdown pension fund. You can also transfer your Flexi-access Drawdown fund to another pension provider.

12.1.8 If you choose to take an Uncrystallised Fund Pension Lump Sum then:

(i) You can take a lump sum directly from your Uncrystallised Fund. 25% of the lump sum will be tax-free with the remainder subject to income tax at your marginal rate.
(ii) There is no maximum and minimum limit on the amount of lump sum that you can withdraw, however, we may require you to maintain a minimum amount in your Compound Pension if you wish for it to remain open.
(iii) There is no limit on the number of Uncrystallised Fund Pension Lump Sumps that you can withdraw from your Compound Pension.
(iv) The Product Provider will pay your Uncrystallised Fund Pension Lump Sum net of all relevant taxes by direct credit into your personal bank account.
(v) The day the Product Provider first makes an Uncrystallised Fund Pension Lump Sum payment to you, you will become subject to a reduced Annual Allowance, known as the Money Purchase Annual Allowance (MPAA) for the remainder of your lifetime. We will notify you this has occurred and the effective date. It is your responsibility to inform any other pension schemes of which you are a member and to ensure that your contributions to all pension schemes (including the Compound Pension) remain within the permitted maximums.

12.1.9 A tax charge may arise as a result of taking a Pension Commencement Lump Sum if you have recycled the lump sum in whole or in part. Recycling will arise if:

(i) The amount of contributions from all sources paid to all Registered Pension Schemes in respect of you is greater than 30% more than might have been expected based on previous contributions; and
(ii) The Pension Commencement Lump Sum plus any similar lump sums from any Registered Pension Scheme taken in the previous 12 months exceeds £7,500.00; and
(iii) The cumulative amount of the additional contributions exceeds 30% of the Pension Commencement Lump Sum; and
(iv) The recycling was pre-planned.

12.1.10 Should a tax charge arise you agree that such tax shall either be paid from your Compound Pension or paid by you personally, as the case may be.

12.1.11 If you choose to buy a lifetime annuity you must select the features you require from the relevant annuity provider. The Product Provider does not offer annuities. To facilitate your request, the Product Provider will transfer your Compound Pension in cash to your chosen provider and to cease to have responsibility for those benefits.

‍

12.2 Transfer Out

12.2.1 Any request to transfer the assets from your Compound Pension to another provider must be made via an approved transfer provider application, subject to the applicable legislation and HMRC rules.

12.2.2 If the Product Provider agrees, they may transfer assets out of your Compound Pension:

(i) To another pension scheme that is a Registered Pension Scheme within the meaning of section 153 of the Finance Act 2004 or which under that section is treated as a Registered Pension Scheme; or
(ii) In accordance with any court order.

12.2.3 The Product Provider will not make a transfer in accordance with these Terms and the Trust Deed and Rules unless:

(i) They have an authorised instruction from you or the appropriate person to make the transfer; and
(ii) They have received all required documentation and information from you, or the appropriate person, that they in their reasonable opinion believe is necessary; and
(iii) They have received all charges due to them; and
(iv) All costs chargeable to your Compound Pension and all liabilities (including all costs arising in relation to any Transfer Out) have been satisfied.

12.2.4 If you wish to Transfer Out in cash, there must be enough settled cash in your Compound Pension. If investments have to be sold to raise the required cash this may take some time. Most asset classes can be sold quickly but some investment funds are illiquid and may take some considerable time to realise.
Where the Product Provider is unable to realise the value to transfer all or any of the investments of your account, they may, in their absolute discretion, defer the transfer out requested under these Terms until they are able to realise the relevant investments and has received the cleared funds.

12.2.5 Where accepted by the receiving scheme, you can transfer the value of your Compound Pension by transferring the investments In-specie.

12.2.6 After satisfaction of all liabilities and the transfer of all assets from your Compound Pension the Product Provider will close your account and you will cease to be a Member of the Scheme.

‍

12.3 Pension Sharing Order

12.3.1 If the Product Provider receives a pension sharing order under the Welfare Reform and Pensions Act 1999 in respect of your rights under the Scheme, they must comply with it. This will reduce the value of your Compound Pension. The Product Provider may need to deduct a charge from your Compound Pension in order to cover any costs of complying with this order. Where they do this, it will be based on the amount of time they take to make the necessary changes.

‍

12.4 Unauthorised Payments

12.4.1 If the Product Provider makes any payments or transactions that are considered unauthorised under HMRC rules, a tax charge may apply. If they know the value of the tax charge, they can take it from your Compound Pension. If they do not know the amount, they may take an amount that they decide or may delay making a payment to you.

12.4.2 The Product Provider relies on information provided by you, your Dependant or Beneficiary to calculate the tax charge. If they are unable to take the tax charge from your Compound Pension you, your Dependant or Beneficiary will need to reimburse them.

12.4.3 The Product Provider can refuse a transaction if they believe that it could lead to an unauthorised payment charge or any other tax charge.

‍

12.5 Serious Ill Health

12.5.1 Serious Ill Health is defined by HMRC as likely having less than a year to live. If you are suffering from Serious Ill Health, you can take all your Benefits as a single lump sum (known as Serious Ill Health lump sum) at any age and can be paid subject to the following conditions:

(i) A registered medical practitioner must provide the Product Provider with written evidence stating that your life expectancy is less than a year before the payment is made. The completed declaration will then need to be received and accepted by the Product Provider before the Serious Ill Health lump sum can be paid.
(ii) You must have some of your Lump Sum and Death Benefit Allowance remaining at the time of payment.

The Product Provider can withhold a payment until they have received any evidence they have requested.

12.5.2 The Product Provider will make payment directly to you by bank transfer, to an account held in your name that has been verified by an authorised person. They will not make payments to third parties unless instructed by someone with a valid Power of Attorney.

‍

12.6 Payment of Benefits on Death

12.6.1 In the event of your death the Scheme Trustee retains absolute discretion to pay any individual or individuals in the proportions that they see fit following deduction of all fees, taxes, and charges due at the time of payment. Any nomination made by you will be considered but is not binding and may not be followed.

12.6.2 Upon your death Benefits may be paid as a lump sum as defined in the Finance Act 2004 or

transferred to another Registered Pension Scheme.

13. Personal Information

13.1 The Product Provider may use your personal information, including your sensitive personal information, and store it on their system and may otherwise process it for the administration of your Compound Pension account. The Product Provider needs to know your personal information in order to provide you with the services as set out in these Terms and to ensure that they administer your Compound Pension as efficiently as possible. This includes such information as is required to comply with all legal and regulatory requirements. Please refer to Appendix One for their Privacy statement.

13.2 The Product Provider will not collect personal information from you that they do not need in order to provide the services they have agreed to provide to you.

13.3 The Product Provider may pass personal information relating to you to their associates or the bank for administering your Compound Pension and verifying your identity and by dealing with them you confirm that you accept and consent to this. The Product Provider may also need to seek additional information from you to verify your identity. In which case they may:

(i) Delay opening your Compound Pension account; or
(ii) Withhold from you the ability to withdraw any funds until they have successfully verified your identity.

13.4 The Product Provider may disclose personal information if they are required to do so by law or are requested to do so by the Financial Conduct Authority, or any other relevant regulatory authority.

13.5 You can ask questions about how the Product Provider has handled your personal information or raise a complaint about how they have handled your personal information, by emailing the Data Protection Officer (see Appendix One). If you are not satisfied with their response, or believe they are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (IC). For further information about the ICO and their complaints procedure visit https://ico.org.uk/concerns/

14. Annual Reporting and Valuations

14.1 Every January, April, July, and October the Product Provider will provide you, via the Compound App, with a statement of the current value of your Compound Pension. Where appropriate the investments allocated to your Compound Pension will be valued at the close of business on 5th January 5th April 5th July and 5th October each year. If the 5th is not a Business Day, then the valuation will be as at the last Business Day before the 5th.

14.2 The Product Provider will provide you with a Statutory Money Purchase (SMPI) each year which will include what you can expect to receive on retirement based on the current value.

14.3 The value of your Compound Pension is based on the total value of the assets, along with any cash balance, at the reporting date less the value of its liabilities. The Product Provider may, from time to time, adopt such valuation rules as they in their opinion consider appropriate.

15. Termination

15.1 These terms and conditions of business, as amended will continue to apply until the provision of the Compound Pension is terminated. All charges or fees due up to the date of termination must be paid. Termination shall be without prejudice to the completion of transactions already initiated by, or with, the Product Provider on behalf of your Compound Pension.

15.2 If the Product Provider terminates or suspends your Compound Pension, they reserve the right to encash all investments and hold the proceeds in cash pending receipt of instructions from you to transfer your Compound Pension to another Registered Pension Scheme.

16. Complaints and Compensation

16.1 We are responsible for handling any complaints relating to the Compound App or to the services provided by us relating to your Compound Pension.

16.2 If you wish to make a complaint in relation to your Compound Pension or the services provided by Quai Investment Services Limited, then please contact us by email at complaints@compound.co.uk Please include your name and Compound Pension account number.

16.3 We will forward complaints in relation to the administration and operation of your Compound Pension to the Product Provider. Once they have received a complaint, they will immediately carry out an investigation in line with their complaints handling policy and will provide a written response to you. Details of our and the Product Providers complaint handling process are available on request.

16.4 If you are unhappy with the response and you wish to take the matter further you can refer it, without giving up any other rights you may have, to one of the following:

‍

The Pensions Ombudsman
10 South Colonnade
Canary Wharf
E14 4PU
Telephone: 0800 917 4487
Email: enquiries@pensions-ombudsman.org.uk
Website: https://www.pension-ombudsman.org.uk/

‍

Financial Ombudsman Service
Exchange Tower
London
E14 9SR
Telephone: 0800 023 4567
Email: complaint.info@financial-ombudsman.org.uk
Website: https://www.financial-ombudsman.org.uk

16.5 The Product Provider participates in the Financial Services Compensation Scheme (FSCS) which pays compensation for financial loss only to eligible claimants when an authorised firm is in default and will carry out an investigation to establish whether or not this is the case. The scheme provides protection if an authorised investment firm is unable to pay claims made against it. The amount of compensation depends on the basis of your claim. The current maximum level of compensation for investments is £85,000 per person per firm. Compensation levels are subject to change and for up-to-date details please refer to www.fscs.org.uk

16.6 If your investment underperforms or loses value because of market movements, this is not covered by the FSCS. Your capital is at risk when investing in securities.

16.7 Further information about compensation arrangements including eligibility, rules and compensation limits is available from the Financial Services Compensation Scheme website at www.fscs.org.uk

17. General

17.1 These terms shall be deemed to have been made in England and shall be governed by and construed in all respects in accordance with the laws of England. The parties (Compound, Quai Investment Services Limited and you) agree to submit to the non-exclusive jurisdiction of the Courts of England and Wales.

17.2 If any of the terms included in these terms and conditions is held by any Competent Authority to be unenforceable or invalid in whole or in part, the validity of the other provisions of these Terms and the remainder of the term in question shall be affected by such invalidity.

‍

Compound Digital Limited is registered in England No 14077672 with the Registered Office at Unit 501, Metropolitan Wharf Building, 70 Wapping Wall, London, E1W 3SS and trading as Compound. Compound is an appointed representative of RiskSave Technologies Limited (authorised and regulated by the Financial Conduct Authority – Firm Reference Number 775330). The Registered Office for RiskSave Technologies Limited is 70 White Lion Street, London, N1 9PP.

Quai Investment Services Limited is authorised and regulated by the Financial Conduct Authority – Firm Reference Number 922590, Registered in England No 9919243. The Registered Office for Quai Investment Services Limited is Unit 16, Tesla Court, Innovation Way, Peterborough, PE2 6FL.

V1 November 2025

‍

Appendix One – Privacy Statement

Quai Investment Services Limited (Quai) will be known as the Data Controller of the personal information you provide to us. The company registration number for Quai is ZB125709 and the registered address is: Unit 16, Tesla Court, Innovation Way, Peterborough, PE2 6FL.

Quai is committed to protecting and respecting your privacy. Our Privacy Statements is to let you know:

How and why, we collect personal information.
What we do with it.
When and why, we share it with other organisations.
How long we keep it for; and
The rights and choices you have with regards to your personal information.
‍

Contact Us

If you have any questions about how we have handled your personal information or wish to raise a complaint about how we have handled your personal information, you can contact our Data Protection Officer at compliance@quaifmc.com

If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). For further information about the ICO and their complaints procedure see: https://ico.org.uk/concerns/

‍

How we collect personal data

You, your financial adviser, or your employer may give us information about you by completing application forms (paper versions or online services) or by contacting us by phone, email or letter.

The personal information we gather may include, but is not exclusive to:

Your name
Address
Date of birth
National Insurance Number
Gender
Email address
Telephone number
Bank account details
Medical information (in certain limited circumstances)
Any further information required as part of a product application.
‍

Why we need it and what we do with it.

We use your personal information in the following ways:

To provide you with any services and/or information you request from us. This also includes carrying out any obligations specified in any contracts between us.
To comply with our legal and regulatory obligations, co-operate with the court service, our regulators and law enforcement agencies and to prevent and detect crime.
If we learn of your insolvency or bankruptcy (or any insolvency proceedings), we’ll transfer your details to the Official Receiver or appointed insolvency practitioner(s).
To check instructions you’ve given us or to resolve disputes including to establish, exercise or defend our legal rights.
To confirm your identity and address, this includes using automated decisions when we carry out financial crime checks.

We will not collect personal information from you that we do not need in order to provide the services we have agreed to provide to you.

We keep the personal information we collect from you, your employer, and other third parties, where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

We hold personal information securely and limit access to those who need to see it.

The personal information we collect may be transferred to and stored at a destination outside the UK. This could be to another company within the Quai group of companies or to external service providers working on our behalf.

Where any such processing takes place, appropriate controls, such as adoption of agreements containing the appropriate standard clauses, will be put in place to ensure that the personal information is protected in the same standard as if it were in the UK.

‍

How long we keep it.

In most circumstances we will retain personal information for the lifetime of a plan or product or for up to seven years after the end of the relationship with us. This is to ensure we comply with our record keeping obligations, as set out by the Financial Conduct Authority (FCA) and other regulatory and legislative requirements.

Certain circumstances dictate that we retain some specific information for longer, i.e., pension transfer information, HMRC tax records etc.

Our retention obligations are reviewed on a regular basis to ensure that we do not keep personal information longer than we are legally obliged to.

When we have no ongoing legitimate business need to hold your personal information, we will either delete it or anonymise it. If we can’t do this, we will securely store your personal information, only use it for a purpose we’ve already communicated to you and isolate it from any further processing until archives are deleted.

‍

What are your data protection rights?

Under data protection law, you have rights including:

Your right of access – you have the right to ask us for copies of your personal information.
Your right to rectification – you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – you have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – you have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your right to access. If you make a request, we have one month to respond to you.

If you wish to make a request, please contact us at:

Data Protection Officer
Quai Investment Services Limited
Unit 16
Tesla Court
Innovation Way
Peterborough
PE2 6FL

‍

How to complain

If you have any concern about our use of your personal information, you can make a complaint to us at the above address. You can also complain to the ICO if you are unhappy with how we have used your data.

The ICOs address is:
Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline Number: 0303 123 1113
ICO Website: https://www.ico.org.uk

‍

Term	Definition
Annual Allowance	The maximum amount of pension savings you can make in a tax year, without incurring a tax charge.
Application	The application you complete and submit for a Compound Pension made available via the Compound App or, in relation to your Workplace Pension, your Employer.
Authorised Representative	A firm that carries on regulated activities under the responsibility of a directly authorised Principal Firm.
Available Cash	The cleared monies held In your Compound Pension adjusted for any unsettled buy or sell Orders or cash allocated for pending buy Orders.
Available Investment	Any investment shown as currently being held in your Compound Pension adjusted for any unsettled transactions.
Beneficiary	The person(s) that will receive the Benefit paid out from your pension account. They may, or may not, also be a Dependant.
Benefit	An actual or prospective entitlement to any benefit under the scheme (including any part of the pension and any payment by way of pension).
Business Day(s)	Any Monday, Tuesday, Wednesday, Thursday, or Friday, which is not a Bank Holiday in England.
Compound App	The Compound application, as updated from time to time, through which you receive information from, and can pass information to, the Product Provider about your Compound Pension.
Compound website	www.compoundapp.co.uk
Crystallise(d) / Crystallisation	To use a part or all of a pension fund to provide retirement income or death benefits. It also occurs when you transfer a pension fund to a recognised overseas pension scheme.
Dependant	Means: A person who was married to or in a registered civil partnership with you at the time of your death; or A person who was married to or in a registered civil partnership with you at the time you first become entitled to a pension; or Your natural/adopted child provided he/she (i) is under the age of 18 (or 23 if in full time education) or (ii) was in the opinion of the Scheme Trustee, dependent upon you at the date of your death because of mental or physical impairment; or A person who falls into neither of the above categories and who at the date of your death was, in the opinion of the Scheme Trustee, (i) financially dependent on you (ii) in a financial relationship of mutual dependence with you, or (iii) dependent on you because of mental or physical impairment.
Execution Only	You have decided to open a Compound Pension and selected the investments available to you without receiving any financial advice from us or the Product Provider.
FCA	The Financial Conduct Authority.
Finance Act	The Finance Act 2004 and associated regulation as amended from time to time and any statutory re-enactment or modification of it.
Flexi-access Drawdown	Income drawdown with no maximum or minimum income limit. You can access your pension savings whilst keeping the rest invested.
HMRC	His Majesty Revenue and Customs.
Income	To provide you with a pension income from your Compound Pension other than by a purchase of an annuity.
In-specie	In relation to a Transfer In or a Transfer Out, a transfer in the form of investments without converting them to cash.
Lump Sum Allowance	A limit on how much tax-free cash you can take from your pension, whether via a Pension Commencement Lump Sum (PCLS) or the 25% tax free portion of an Uncrystallised Fund Pension Lump Sum (UFPLS). This will be set at £268,275.
Lump Sum and Death Benefit Allowance	The total limit on tax-free withdrawals from your pension, along with any Serious Ill Health Lump Sums and Deceased payments where they are paid tax free. This will be set at £1,073,100.
Member	A person admitted as a Member of the Compound Pension and who has not ceased to be a Member.
Minimum Pension Age	The age at which the regulations permit you to take Benefits from your Compound Pension.
Money Purchase Annual Allowance	The maximum amount of pension savings you can make in a year, without incurring a tax charge, after having flexibly accessed your pension benefits.
Order	An instruction received by the Product Provider from you, via Compound, to buy or sell investments within your Compound Pension.
Pension Commencement Lump Sum	The lump sum of money you can withdraw from a pension as a tax-free amount.
PEP	An individual who is or has been entrusted with prominent public function, other than as a middle-ranking or more junior official. This includes, but is not limited to: Heads of state or government, ministers, and members of parliament, Members of the judiciary, senior officials of central banks, ambassadors, and senior officers in the armed forces; and Members of the administrative, management or supervisory bodies of state-owned enterprises. A PEP also includes the immediate family members and known close associates of such individuals.
Permitted Investments	The investments that are made available to you from time to time for investment via the Compound App.
Power of Attorney	A document that gives an individual the authority to act for another person in legal or financial matters.
Principal Firm	A company that is directly authorised by the FCA to carry out regulated activities and who appoints an Appointed Representative to conduct some or all of those activities on its behalf. The Principal Firm assumes full regulatory responsibility for the activities of the Appointed Representative.
Qualifying Pension Arrangement(s)	Your occupational or defined contribution pension arrangement that is registered with HMRC and which are eligible to be transferred to your Compound Pension.
Registered Pension Scheme	A scheme which is registered under Chapter 2 of Part 4 of the Finance Act.
Regulatory Requirements	Means: Any obligation that the Product Provider, or where relevant, another person, has to comply with under any law of regulation (including any tax legislation, rules or guidance made by an applicable regulatory body including the FCA), or as a result of a decision by a court, ombudsman, or similar body; or Any obligation under any industry guidance or codes of practice which the Product Provider or, where relevant, another person, follows; or Any other legal or regulatory requirement which is effective in the United Kingdom and to which the Product Provider must give effect in operating the Compound Pension.
Retail Client	Defined as a client who is not a professional client or an eligible counterparty, by the FCA Handbook of rules and guidance, as published from time to time.
Scheme	The Compound Pension
Scheme Administrator	Quai Investment Services Limited. Quai Investment Services Limited has appointed Quai Administration Services Limited to provide administration support in connection with the Scheme. However, Quai Investment Services Limited is responsible for executing the required functions of a Scheme Administrator of the Scheme.
Scheme Rules	The Trust Deed and Rules (as amended from time to time) which govern the Scheme.
Scheme Trustee	Quai Trustees Limited.
Security Details	The personalised information (such as password, security questions and answers, personal identification numbers and account numbers) or the ‘Magic Link’ secure authentication email or text message that Compound send you that apply to your Compound Pension.
Serious Ill Health	A tax-free lump sum payment of uncrystallised benefits that can be made, at the Scheme Trustees discretion, where a person has a life expectancy of less than one year.
Tax Year	6th April to the following 5th April.
Terms	These Terms and Conditions and any amendments from time to time.
Transfer In	Any transfer in of cash or assets to your Compound Pension from another registered pension scheme.
Transfer Out	The full or partial transfer of your Compound Pension to another registered pension scheme, in cash or assets.
Trust Deed and Rules	A legal document that establishes and governs the Scheme and was entered into by the Scheme Administrator and the Scheme Trustee on 1st March 2024, as amended from time to time.
UK Anti-Money Laundering and Counter-Terrorist Financing regulations	Means all applicable UK laws, regulations and regulatory guidance relating to the prevention of money laundering, terrorist financing, and financial sanctions, as amended from time to time. This includes, without limitation: The Money Laundering, Terrorist Financing and Transfer of Funds (Information on Payer) Regulations 2017 The Proceeds of Crime Act 2000, The Terrorism Act 2000, and. Any rules, guidance, or requirements issued by the Financial Conduct Authority (FCA), HM Treasury, or other competent authorities in connection with these laws. These regulations require firms to verify customer identity and residence, assess and monitor financial crime risk, screen against sanctions and politically exposed person (PEP) lists, and report suspicious activity to the appropriate authorities.
Uncrystallised Fund	A lump sum, of which 25% is paid tax-free and the remaining 75% is taxed at your marginal rate of income tax and paid directly from your Uncrystallised Fund.
Uncrystallised Fund Pension Lump Sum	A lump sum, of which a proportion is taxed at the basic income rate, paid directly from your Uncrystallised Fund, as defined by the Taxation of Pensions Act 2014.
Website	The Compound website.

‍