1. Introduction

These Terms of Business set out the general terms under which OBCM Wealth Management will provide services to you, and the respective duties and responsibilities of both the firm and you in relation to such

services. In this document, “we” and “us” refer to OBCM Wealth Management. Please ensure that you read these terms thoroughly and, if you have any queries, we would be happy to clarify them. If any material changes are made to these terms, we will notify you.

2. Authorisation with the Central Bank of Ireland

OBCM Wealth Management is regulated by the Central Bank of Ireland as an Investment Intermediary authorised under the Investment Intermediaries Act 1995 and as an Insurance Intermediary registered under the European Union (Insurance Distribution) Regulations 2018. Copies of our regulatory authorisations are available on request. The Central Bank of Ireland holds registers of regulated firms. To verify our credentials you can contact the Central Bank of Ireland on 0818 681 681 or (01) 224 5800, or visit their website at www.centralbank.ie .

3. Codes of Conduct

OBCM Wealth Management is subject to the Consumer Protection Code, Minimum Competency Code and Fitness & Probity Standards which offer protection to consumers. These Codes can be found on the Central Bank’s website www.centralbank.ie

4. Our Services

Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life & pensions insurance and investment products. A full list of insurers and product producers with which we deal is available on request.

5. Fair and Personal Analysis

“Fair and personal analysis” means we provide advice based on an analysis of a sufficiently large number of insurance contracts and product producers available in the market to enable us to make a recommendation, in accordance with professional criteria, as to which contract adequately meets your needs.

A full list of the insurers and product providers we deal with is available on request.

6. Remuneration

We are remunerated by the fees and commission payments we receive from financial institutions.

Directors:

James O’Brien FCA AITI QFA • Patrick MacSweeny FCA QFA • Timothy O’Brien CPA

O’Brien Coffey MacSweeny Limited, Registered in Ireland,

Company No. 505389

Registered Office: Allman House, Tralee Road, Killarney, Co. Kerry Investment Intermediary Services and Insurance-Based Investment Products (IBIPs)

We are remunerated by commission for our investment intermediary services and the advice we provide on our insurance-based investment products.

Annual management charges

We charge an initial fee for selecting and arranging investment solutions, which is paid by commission and other payments from product providers on the completion of business. We also charge an on-going fee (Annual Management Charge [AMC]) for monitoring your financial products, completing suitability assessments and meeting you to review your portfolio on a regular basis. These fees are deducted from the fund at source.

Additional Fees

In certain circumstances, it may be necessary to charge a fee for services provided. Where fees are chargeable or where you choose to pay in full for our service, we will notify you in writing in advance. Where it is not possible to provide the exact amount, we will provide you with the scale of fees to be charged and the method of calculation. Additional fees may be payable for complex cases or to reflect specialist skills or urgency. Our scale of fees for such cases ranges from a minimum of €200 per hour to a maximum of €400 per hour. We will notify you in advance regarding the fees to be charged. A summary of the details of all fee and commission arrangements paid or provided to us is available on our website.

Clawback

If we receive commission and this is subsequently clawed back by the provider due to early encashment, transfer, or cancellation, we reserve the right to charge you a fee equal to the clawed-back amount.

Sustainability

We take due care so that our internal remuneration policy with respect to investment or insurance advice on insurance-based investment products (‘IBIPs’) promotes sound and effective risk management in relation to sustainability risks and does not encourage excessive risk‐taking with respect to sustainability risks.

7. Understanding Your Policies

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 policy and 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; particularly in relation to PHI and serious illness policies.

Specifically on the subject of permanent health insurance policies we will explain to you; a) the meaning of disability as defined in the policy; b) the benefits available under the policy; c) the general exclusions that apply to the policy; and d) the reductions applied to the benefit where there are disability payments from other sources.For a serious illness policy, we will explain clearly to you the restrictions, conditions and general exclusions that attach to that policy.

8. Sustainability Factors – Investment/IBIPs/Pension Advice

In accordance with the Sustainable Finance Disclosure Regulation (‘SFDR’), we inform you that when providing advice on insurance-based investment products/Investments, we do not assess, in addition to relevant financial risks, relevant sustainability risks as far as this information is available in relation to the products proposed/advised on. This means that we do not assess environmental, social or governance events/conditions that, if they occur, could have a material negative impact on the value of the investment.

9. Considering Principal Adverse Impacts on sustainability factors in the advice

When providing advice on insurance-based investment products (‘IBIPs’) or investment advice we do not consider the impacts of our advice that result in negative effects on sustainability factors (namely environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters),because the area is undergoing change and as the issue progresses, we will review our position. We will review this approach on an annual basis in January of each year.

10. Ongoing Suitability

Investments

Ongoing suitability assessments form part of the service to clients. On an annual basis the firm will issue a client report outlining changes in the services or instruments involved and/or the circumstances of the client.

Insurance based Investment Products

We will provide periodic assessments of the suitability of the insurance-based investment productwhich we have recommended to you.

Regular Reviews

It is in your best interests that you review, on a regular basis, the products which we have arranged for you. As your circumstances change, your needs will change. You must advise us of those changes and request a review of the relevant policy so that we can ensure that you are provided with up to date advice and products best suited to your needs. Failure to contact us in relation to changes in your circum-stances, may result in you having insufficient insurance cover and/or inappropriate investments.

11. Your duty of disclosure

This section applies to consumer duties and rights arising out of the Consumer Insurance Contracts Act 2019. Commercial (that is, non-consumer) clients have no duties and rights under this Act, and therefore the following section does not apply to them.) When you are completing the documentation required for new business and contract renewals, you have a duty to disclose information as specified in the Consumer

Insurance Contracts Act (Section 14 (1) – (5)), as follows:

You are required to answer all questions posed by us or the insurer honestly and with reasonablecare, in line with what is expected of the average consumer. The “average consumer” is defined by Directive No. 2005/29/EC of the European Parliament and of the Council of 11 May 2005 as reasonably well informed and reasonably observant and circumspect, taking into account social, cultural and linguistic factors.

Specific questions will be asked. Where you do not provide additional information (after being requested to do so), it can be presumed that the information previously provided remains unchanged.

When your contracts are concluded, completed proposal forms and/or Statements of Fact will be provided to you. These are important documents as they will form the basis of the insurance contract between the insurer and you, the consumer. You must review these documents carefully to ensure the information provided is true and accurate.

An insurer may repudiate liability or limit the amount paid on foot of the contract of insurance, only if it establishes that non-disclosure of material information was an effective cause of the insurer entering into the relevant contract of insurance, and on the terms under which it did.

12. Cancelling of a Contract of Insurance

You may cancel a contract of insurance, by giving notice in writing to the insurer, within 14 working days after the date you were informed that the contract is concluded. This does not affect the notice periods already provided under European Union (Insurance and Reinsurance) Regulations 2015 ( S.I. No. 485 of 2015 ) or the European Communities (Distance Marketing of Consumer Financial Services) Regulations 2004 ( S.I. No. 853 of 2004 ) which is 30 days in respect of life policies, irrespective of whether the sale took place on a non-face to face basis, and 14 days in respect of general policies and only on sales that tookplace on a non-face to face basis (distance sales).

The giving of notice of cancellation by you will have the effect of releasing you from any further obligation arising from the contract of insurance. The insurer cannot impose any costs on you other than the cost of the premium for the period of cover.

This right to cancel does not apply where, in respect of life insurance the contract is for a duration of six months or less, or in respect of general insurance, the duration of the contract is less than one month.

13. Claiming against an insurance contract

You must notify the insurer of the occurrence of an insured event within a reasonable time, or otherwise in accordance with the terms of the contract of insurance. You must cooperate with the insurer in an inves-tigation of insured events, including responding to reasonable requests for information in an honest and reasonably careful manner.

An insurer may refuse a claim made by a consumer under a contract of insurance where there is a change in the risk insured. This includes any change as described in an “alteration of risk” clause where the circumstances, and the associated risks, are no longer the same as those which the insurer has agreed to cover.

Any clause in a contract of insurance that refers to a “material change” will be interpreted as being a change that takes the risk outside what was in the reasonable contemplation of the contracting parties when the contract was concluded. If, after a claim is made, you become aware of information that would either support or prejudice the claim, you are under a duty to disclose it.

If a consumer makes a false or misleading claim in any material respect (and knows it to be false or misleading, or consciously disregards whether it is), the insurer is entitled to refuse to pay and to terminate the contract. Where an insurer becomes aware that a consumer has made a fraudulent claim, they must notify the consumer advising that they are voiding the contract of insurance. It will be treated as being terminated from the date of the submission of the fraudulent claim. The insurer may refuse all liability in respect of. any claim made after the date of the fraudulent act, and the insurer is under no obligation to return any of the premiums paid under the contract.

Under the Consumer Insurance Contracts Act 2019, a court of competent jurisdiction can reduce the pay-out to the consumer where the consumer is in breach of their duties, in proportion to the breach involved.

14. Conflicts of interest

It is the policy of our firm to avoid conflicts of interest in providing services to you. However, where an unavoidable conflict of interest arises, we will advise you of this in writing before providing you with any service. A full copy of our conflicts of interest policy is available on request.

15. Default on payments by clients

We will exercise our legal rights to receive payments due to us from clients (fees and insurance premiums)

for services provided. Without limitation to the generality of the foregoing, the firm will seek reimbursement for all payments made to insurers on behalf of clients where the firm has acted in good faith in renewing a policy of insurance for the client.

Product producers may withdraw benefits or cover in the event of default on payments due under policiesof insurance or other products arranged for you. We would refer you to policy documents or product terms for the details of such provisions.

16. Complaints

Whilst we are happy to receive verbal complaints, it would be preferable that any complaints are made in writing. We will acknowledge your complaint in writing within 5 business days and we will fully investigate it. We shall investigate the complaint as swiftly as possible, and the complainant will receive an update on the complaint at intervals of not greater than 20 business days starting from the date on which thecomplaint is made. On completion of our investigation, we will provide you with a written report of the outcome. If you are still dissatisfied with our handling of or response to your complaint, you are entitled to refer the matter to the Financial Services and Pensions Ombudsman (FSPO). A full copy of our complaint’s procedure is available on request.

17. Data Protection

We are subject to the requirements of the General Data Protection Regulation 2018 and the Irish Data Protection Act 2018.

OBCM Wealth Management is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.

The data will be processed only in ways compatible with the purposes for which it was given and as outlined in our Data Privacy Notice, this will be given to all our clients at the time of data collection. We will ensure that this Privacy Notice is easily accessible. Please refer to our website www.obcmwealth.ie if this medium is not suitable we will ensure you can easily receive a copy by hard copy, or telephonic environment. (pre-recorded).

Please contact us at info@obcm.ie if you have any concerns about your personal data.

18. Compensation Scheme

We are members of the Investor Compensation Scheme operated by the Investor Compensation Company

Ltd. See below for details.

Investor Compensation Scheme

The Investor Compensation Act, 1998 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.The Investor Compensation Company Ltd. (ICCL) was established under the 1998 Act to operate such a compensation scheme and our firm is a member of this scheme.

Compensation may be payable where money or investment instruments owed 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 able 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 which is recognised for the purposes of the Investor

Compensation Act, 1998; or

Compensation of up to €20,000.

Further information is available from the Investor Compensation Company DAC at (01) 244 4485 or

at www.investorcompensation.ie

Updated October 2025