Utmost International Isle of Man Limited

TERMS & CONDITIONS

These are the terms of use and important information that apply to your use of this website (the "Site"), please read them carefully. Persons using this Site must accept these Terms of Use when they first register to use this Site and on each occasion these Terms of Use are amended, updated, modified or replaced from time to time.

General:

• This Site is a service provided by Utmost International Isle of Man Limited. Utmost International Isle of Man Limited is a company limited by shares. Registered in the Isle of Man under number 024916C. Registered office: King Edward Bay House, King Edward Road, Onchan, Isle of Man, IM99 1NU, British Isles. Licensed by the Isle of Man Financial Services Authority. A member of the Association of International Life Offices. A member of the Manx Insurance Association (MIA).
• The information on this Site is provided for information purposes only and none of the information constitutes an offer to contract.

Definitions:

i) "Utmost" (including "we" or "us") means Utmost International Isle of Man Limited.

ii) "Utmost Group" means Utmost, its subsidiaries, their ultimate holding company or any subsidiary thereof.

iii) "Utmost Wealth Solutions" is a business name used by a number of Utmost companies.

iv) "Client" means a private customer, a retail customer or a retail client.

v) "Intermediary" means a person or entity which has terms of business with Utmost, directly authorised by or registered with the UK Financial Conduct Authority or other acceptable regulatory authority with appropriate permissions to act as agent to private and/or retail Customers.

vi) "You" or "yourself" or "your" means the user of this Site being either a client or an intermediary as appropriate.

Availability:

i) We will endeavour to ensure that the Site is accessible for 24 hours a day. However, we will not be liable if, for any reason, the Site is unavailable at any time or for any period.

ii) To the fullest extent permitted by applicable law we will not be liable for any loss or damage arising in contract, tort or otherwise if the Site becomes unavailable or is suspended for any reason.

INFORMATION

• Utmost is licensed by the Isle of Man Financial Services Authority.
• Full product details are contained in the relevant product guide, key features document and policy documentation, copies of which can be obtained via an intermediary or directly from us. A decision to invest should not be made on the basis of this Site alone. If there is any conflict between the details given on this Site and the relevant literature applicable to any products offered or insurance contract written by us then, the product literature and policy documentation will be regarded as the authoritative documents.
• The tax efficiency of bonds may change and their tax treatment depends on the investor's circumstances.
• The information contained on this Site does not constitute investment advice, legal advice or tax advice and investors are strongly advised to obtain their own professional advice.
• The information and features of this Site do not constitute any form of advice or recommendation by us and are not intended to be relied upon by users in making (or refraining to make) any specific investment decisions.
• Information contained on this Site is provided for information purposes only and we will use all reasonable endeavours to ensure that it is accurate at the date of publication.
• Due to the nature of the internet, there may be circumstances in which errors or omissions in the information may occur which are beyond our reasonable control. For example unauthorised access by a third party. Consequently, Utmost will not be liable for loss or damages arising whether for loss of income or revenue, profits, anticipated savings or, in contract, tort or otherwise, directly or indirectly from the use of or reliance upon any information contained on the Site, unless the accuracy of the information has been checked with us before reliance is placed upon it.
• Valuations shown on the Site are the latest bid values (mid market for shares if applicable). We have and take no account of any surrender charges that may be incurred when surrendering the investment. It is assumed that all premiums due have been paid.
• Please remember that the value of unit-linked funds can go down as well as up. There is no guarantee of the ultimate value of any investment (except where stated) or how much 'income' it can provide. The word 'income' refers to the regular payments of capital.
• Past performance is not a guide to future performance.
• Taking into account market fluctuations, currency fluctuations and initial charges, investors may not get back as much as they have invested.

SECURITY AND AUTHORITY

• We will take all reasonable steps to ensure that personal information is disclosed only to those specified by you or as otherwise set out in these Terms of Use. However, the internet is an open system and we cannot and do not guarantee that the personal information you have entered will not be intercepted by others and decrypted.
• If you should choose to use a digital certificate to identify yourself to the Site (after registering it with the Site) then the responsibility for the security and management of that certificate is entirely with you. Utmost accepts no responsibility in managing the certificate nor can we be held responsible should the security of the digital certificate be compromised.
• Utmost accepts no responsibility for transactions carried out using your ID and password provided to or chosen by you in connection with the use of this Site and/or digital certificate, whether or not the transaction is made by you or someone else using your ID and password and/or digital certificate. You are responsible for protecting and securing your ID and password and/or digital certificate from unauthorised use. If you believe there has been a breach of security you should contact us immediately.
• You authorise Utmost to act upon all instructions received in respect of your account via the Site when your ID and password are used and which appear to Utmost to have been issued by you. Instructions given by you for a joint account are binding on all other joint account holders.

LIABILITY

• The Site also contains hypertext links to other websites. The responsibility for those sites is that of the parties who are identified as providing those sites and we accept no responsibility for them or their use or the content of any other site.
• Utmost cannot warrant that this Site is free of viruses or technical defects of any description and will not be responsible for any technical problems arising from the use of this Site.
• Utmost reserves the right to change the content, presentation, user facilities and availability of any part of the Site at our sole discretion.
• If you are an intermediary you agree to:
• Accept responsibility for ensuring that the documents produced by you for use by clients and/or Utmost are accurate and complete.
• Not use any hypertext links or documents on the Site so as to mislead a client or Utmost in any way about the content of the Site or a particular document. The intermediary agrees to indemnify Utmost for any loss arising as a result of the misuse of any hypertext links.
• Accept responsibility for any damages (including, without limitation, damages for loss of business or loss of profits) arising in contract, tort or otherwise from your inability to use or incorrect use of any material on this Site.
• Fully indemnify Utmost for any losses, claims, costs or expenses suffered by the Utmost Group as a result of the intermediaries' breach of this liability clause.

EMAIL

• Utmost will not pass on your email address to any third party, unless required to do so by law or regulation, or in order to deliver a service to you: for example, if you decide to use our webchat service then your email address will be sent to a third party Intercom, Inc as detailed below.
• Occasionally we will email you to keep you up to date with new developments on the Site. In every email we send we will include instructions on how to unsubscribe so that you will not receive future emails. You may change your email address at any time and this can be updated on the Site.

WEBCHAT

Our webchat service uses a third party Intercom, Inc 'Intercom' as a medium for communicating through our website. If you choose to use webchat, Intercom collects your name, email address and website URLS to enable your use of this service. We will provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom and use Intercom to collect data for analytics purposes. As a data processor acting on our behalf, Intercom analyses your use of our website and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. The first time you use webchat you will be asked to indicate that you are happy for this information to be collected.

• You can read our cookie policy here.
• You can read our Privacy Notice here.
• For more information on Intercom's use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy.
• For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy.
• Intercom's services are governed by Intercom's terms of use which can be found at https://www.intercom.com/terms-and-policies#terms.

The following Terms of Use apply to your use of Utmost's webchat service.

By using the webchat service you are deemed to have accepted these webchat Terms of Use. We reserve the right to change these Terms of Use from time to time at our sole discretion and will publish the updated terms here.

USING WEBCHAT

Webchat enables an automated chatbot to interact with Utmost clients and intermediaries through the Utmost website. Based on the text you input the service will provide information that most closely matches your query. We will only provide general information on our Isle of Man based products and services.

You can also use our webchat service to live chat with our Customer Support team in the Isle of Man. Please be aware that we cannot provide you with financial advice, deal with questions about products from other Utmost Group providers or act upon an instruction from you regarding your Policy with us through webchat. We will let you know if we cannot deal with your request through webchat.

We will endeavour to make the webchat service available to you between 9-5 Monday to Friday, UK time, (excluding UK public holidays) but no assurance or warranty is given for the availability or reliability of the webchat service.

In using the webchat feature on this site you agree:

• Not to send or communicate to us any sensitive personal information, for example information such as medical and health information, racial or ethnic origins, religious beliefs, sexual orientation or criminal convictions.
• Not to use the webchat in any way that could harm any computer network or system or impair anyone else's use thereof.
• Not to send any offensive, inflammatory, defamatory, fraudulent or otherwise unlawful information.

In addition you acknowledge that:

• Your chat session will be recorded and stored. We will store transcripts (copies of the messages you leave or any conversations you have with us). Please see our data privacy notice for further details on how we use and store your personal data.
• Utmost can terminate your use of webchat if it reasonably believes that you have breached these Terms of Use.

COPYRIGHT AND OTHER INTELLECTUAL PROPERTY RIGHTS

• Utmost owns or is the licensee of the copyright and all other intellectual property rights subsisting in its databases made accessible via the Site and all material on this Site.
• You are not permitted to download, redistribute or extract any information on this Site in whole or in part other than that information relating directly to your portfolio or insurance policy issued by Utmost, or, if you are an intermediary, to your client's portfolios.
• As an intermediary you agree:
• Not to use any documents or related graphics appearing on the Site for any reason other than conducting business with any of the companies in the Utmost Group.
• Not to modify or amend any document or related graphics which are available on the Site in any way other than for the purpose of completing the variable permitted within the particular document, for example the inputting of personal data relating to individual clients.
• Not to reproduce or store any documents or other information contained on the Site in any manner whatsoever, other than the documents produced as a result of conducting business with any of the companies within the Utmost Group and instruments, orders, regulations and Codes of Practices (whether or not having the force of law) which may apply to that business.
• To print the documentation in the form it appears on the Site for the purposes of conducting business with any of the companies within the Utmost Group only and not to part print any information or documents, including the accompanying logos, appearing on the Site.
• Not to use any graphics which appear on the Site separately from the accompanying text.
• That copyright and any other rights in the material available on the Site are owned or licensed by members of the Utmost Group.

APPLICABLE LAW

• The use of this Site is governed by the law of the Isle of Man and the Isle of Man courts shall have exclusive jurisdiction in respect of any dispute. Any waiver of such jurisdiction shall be at the discretion of Utmost. Such discretion to be exercised reasonably.

AMENDMENT OF USE

• Utmost may amend these Terms of Use at any time and such amendment shall apply to your use of this Site after such amendment.

PRIVACY STATEMENT AND COOKIES

• We use the information you give us, about yourself and other people, to provide the products and services you request and to operate and improve the Site. In order to support those products and services and the Site, we transfer information between different entities within the Utmost Group and to appointed data processors, but we do not transfer information to other parties, unless required to do so by law or regulation. Unless specified in the applicable privacy notice (referenced below), we do not carry out marketing using the information or transfer, or sell, your personal information to others for marketing purposes.
• You may choose to use some of the hypertext links to other sites that are set out in this Site. Some of those sites may be restricted and require the completion of further information by you. You are responsible for the accuracy of your personal information.
• Utmost sends cookies to your computer from this Site when you are logged in. The cookies transferred by Utmost are only used for enabling your logged in session to work smoothly and to track your usage of this Site. They store only an internal ID and tracking information and are not used for any other purposes. You may alter the cookies setting in your browser to prevent cookies from being transferred to your computer, but please be aware that if you do this you will not be able to use our secured Site.
• Utmost has a comprehensive Cookies Policy which you may access here.
• More details about how we use your information, your rights over this information and how you can exercise your rights can be found in the Utmost Privacy Notice(s) which you may access here.
• Utmost will endeavour to protect any information that the intermediary inputs into this Site, however the internet is not necessarily a secure system and the privacy of the intermediary and/or its clients cannot be guaranteed. Utmost shall not be liable for any damages resulting from the misuse of personal data supplied by the intermediary on the internet. If you are in any doubt, you should not input any data.

YOUR ACCEPTANCE OF THESE TERMS

• By accessing any part of this Site you shall be deemed to have accepted these terms in full.

PRIVACY STATEMENTS

The EU General Data Protection Regulation (GDPR), introduced on 25 May 2018, sets out how your personal data (information that is personally identifiable such as your name, address or email address) can be used in a lawful manner. GDPR also gives you new rights in relation to your personal data.

Utmost Wealth Solutions is committed to ensuring the security and confidentiality of the information you give us, about yourself and other people, which we use to provide our products and services, including online services. Details about how we use your information, your rights over this information and how you can exercise your rights can be found in the Privacy Notice(s) or Privacy Statement(s) for the group of Utmost companies, which you can access via the following link: https://utmostinternational.com/privacy-statements/

Privacy Notice

This Privacy Notice explains how Utmost Limited and Utmost Trustee Solutions Limited as part of the Utmost Isle of Man Group (together ‘Utmost’ and the ‘Utmost Isle of Man Group’ or ‘us’ and ‘we’ as the context shall permit) hold, control and process your personal data. If you have any questions you can contact us using the details provided at the end of this notice.

WHAT IS PERSONAL DATA?

1. Personal data is information that relates to a living individual who can be identified from that data. This identification can be from the information alone or in conjunction with any other information in our possession, or that is likely to come into the possession of those processing the information.

HOW YOUR INFORMATION WILL BE USED

2. Being transparent and providing accessible information about how Utmost hold, control and process personal data is governed by the European Union General Data Protection Regulation (GDPR) and the Isle of Man regulations applied under the Data Protection Act 2018 (together the Data Protection Regulations).
3. As a financial services organisation we hold, control and process your personal data to enable us to provide you with our products and related services. We also hold, control and process your data to allow us to comply with our obligations under the laws and regulations of the Isle of Man and the United Kingdom (UK) in relation to the prevention of crime and terrorist financing and to enable information exchange between taxation authorities. In addition, if you are resident in the UK, we will process your personal data to comply with UK taxation law.  This personal data will include details such as your name, address and date of birth and may include information as to your place of birth and National Insurance number.
4. Subject to changes in the Data Protection Regulations, where you provide us with personal data about an individual who is under 16 years of age, it is your responsibility to advise us when that individual attains 16 years, as we may be required under the Data Protection Regulations to tell them that we hold their personal data.
5. In the context of the Data Protection Regulations, we will process your personal data under the following legal bases:
   1. To enter into or perform a contract (in the case of Utmost Limited a contract for an insurance bond and in the case of Utmost Trustee Solutions Limited, should they be appointed as a trustee, a trust client agreement),
   2. To comply with the legal requirements of an European Economic Area (EEA) Member State or the Isle of Man, and
   3. To fulfil the legitimate interests of Utmost.
6. When we are processing your personal data in order to fulfil our legitimate interests, our legitimate interests are:
   1. To comply with the laws of the Isle of Man in relation to anti-money laundering and countering the financing of terrorism requirements, which require us to be satisfied that we have suitably identified our customers and understand the nature of their affairs.
   2. To disclose personal information to the Isle of Man Treasury in order to meet international taxation reporting standards.
      These are requirements of Isle of Man law and are equivalent to requirements within the laws of EEA Member States.
 
7. Where you have applied for one of our products that require underwriting services such as the Estate Planning Bond or the Discounted Gift Trust, we will process information about your health.  This information will be supplied by you in an application form and also by your General Practitioner (GP) when you have authorised your GP to do so. We process this information so that the value of the gift placed into trust can be calculated.  We then keep this health data so that in the future we can respond to any enquiry from HM Revenue & Customs (HMRC) as to how the gift value has been calculated.
8. If you do not provide us with the necessary personal data, Utmost will not be able to enter into and/or administer the contract that you have with us.

INFORMATION PROVIDED BY OTHER SOURCES

9. Not all personal data we hold about you will have been provided directly by you.  Where your personal data has been provided to us by another party, this is likely to have been in one of the following circumstances:
   1. You have been named as a life assured for an insurance bond.
   2. You are a director, signatory or shareholder of a corporate applicant for an insurance bond.
   3. You are the beneficiary of a trust that holds an insurance bond.
   4. You have witnessed a signature upon a form or deed.
In these instances, we will have asked for information such as your name, address and date of birth.


10. Where we are processing personal data that has been provided by another party, the data is most likely to have been obtained from:
    1. The settlor and/or trustees of a trust of which you are a beneficiary.
    2. The director, signatory or shareholder of a corporate applicant.
    3. Your GP in relation to health information.
    4. Publically accessible media sources.

SHARING INFORMATION

11. We will transfer personal data to:
    1. Associated Isle of Man companies within the Utmost Isle of Man Group, including Utmost Services Limited, which supplies our computer systems and Utmost Trustee Solutions Limited where it has been appointed as a trustee in connection with an insurance bond provided by Utmost Limited.
    2. If applying for a product which is underwritten, our appointed underwriter who will receive your health information.
    3. The Isle of Man Government and regulatory agencies when required to by law or regulation.
    4. Your nominated advisers, such as your Independent Financial Adviser.
    5. If you are resident in the UK, HMRC when required by UK taxation law or regulation.
In order to fulfil our legitimate contractual obligations to you, we may also from time to time be required to share your information with other third parties. In compliance with the Data Protection Regulations, we will only transfer your information to third parties where they provide an adequate level of data protection.


12. Your personal data will be held, controlled and processed by us in the Isle of Man, which is not a member of the EEA.  The Isle of Man has been recognised by the European Commission as having adequate data protection legislation.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

13. To meet our legal and business requirements your personal data will be stored, and accessible, in our business systems for a period of up to seven years following the date on which all connected business relationships have ended. After this period, your personal data will be archived and placed beyond the use of the business, with access restricted to legitimate legal or business requirements. Examples of such requirements include, but are not limited to, legal actions, fund corrections and regulatory changes.

HOW TO UPDATE THE INFORMATION WE HOLD ABOUT YOU

14. It is important that the information we hold about you is accurate and up to date. Please let us know if your information changes, or if the information we hold about you is incorrect. You can ask our Customer Services team to update or correct your information.
If we have disclosed your personal information to another entity as described in paragraph 11, we will also let them know about the changes unless it is very difficult or not possible for us to do so.



YOUR RIGHTS

15. Under the Data Protection Regulations you have certain rights over your personal data. These rights are as follows:
    1. You have the right to request from us access to your personal data through a ‘subject access request’.
    2. You have the right to obtain from us the rectification of any inaccurate personal data we hold about you.
    3. You have the right to erasure of your personal data, unless we have a legal obligation to process your personal information.
    4. You have the right to seek the restriction of the processing of your personal data in certain circumstances.
    5. You have the right to object to its processing. We shall no longer process the data unless there are compelling legitimate grounds for the processing.
    6. You have the right of portability in relation to your personal data. This means you can request we provide you with the personal data we hold about you in a structured, commonly used and machine readable format.
    7. You have the right not to be subject to decisions based solely on automated processing. We do not carry out any automated processing which may lead to an automated decision based on your personal data.
In order to exercise any of the above rights, please write to or email Utmost’s Data Protection Officer at the details provided below.


16. If you believe we have not complied with the requirements of the Data Protection Regulations you have the right to make a complaint about our data processing to a supervisory authority, for example, the Information Commissioner’s Office in the UK or the Information Commissioner in the Isle of Man. Their contact details are as follows:
Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
UK
SK9 5AF

Telephone: +44 (0)1625 545700 or +44 (0)303 123 1113

Isle of Man Information Commissioner
Head Office
PO Box 69
Douglas
Isle of Man
IM99 1EQ

Telephone: +44 (0)1624 693260

IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER

17. Your personal data is held,controlled and processed by Isle of Man companies in the Utmost Isle of Man Group.  Specifically these companies are:
    1. Utmost Limited, which provides insurance bonds, and
    2. Utmost Trustee Solutions Limited, where it has been appointed as a trustee in connection with an insurance bond provided by Utmost Limited.
      The registered address of each company listed in section 17 (a) to (b) is Royalty House, Walpole Avenue, Douglas, Isle of Man, IM1 2SL.


18. If you wish to exercise any rights, have any queries as to how your data is processed, concerns or complaints, you can contact  our Data Protection Officer by emailing: dpo@utmostwealth.com.

As the Isle of Man is not an EEA Member State, our EEA Appointed Representative in the United Kingdom is an establishment of Utmost Services Limited based at Saddlers House, 5th Floor, 44 Gutter Lane, London EC2V 6BR.

INTERMEDIARY PRIVACY NOTICE

This Privacy Notice explains how Utmost Limited and Utmost Trustee Solutions Limited as part of the Utmost Isle of Man Group (together ‘Utmost’ and the ‘Utmost Isle of Man Group’ or ‘our’, ‘us’ and ‘we’ as the context shall permit) hold, control and process your personal data. If you have any questions you can contact us using the details provided at the end of this notice.

WHAT IS PERSONAL DATA?

1. Personal data is information that relates to a living individual who can be identified from that data. This identification can be from the information alone or in conjunction with any other information in our possession, or that is likely to come into the possession, of those processing the information.

HOW YOUR INFORMATION WILL BE USED

2. Being transparent and providing accessible information about how Utmost hold, control and process personal data is governed by the European Union General Data Protection Regulation (GDPR) and the Isle of Man regulations applied under the Data Protection Act 2018 (together the Data Protection Regulations).
3. As a financial services organisation we hold, control and process your personal data to enable us to provide your clients with a contract for an insurance bond and you and your client with connected services. We also hold, control and process your data to allow us to comply with our obligations under applicable law and financial regulation and to provide you with information about our products and services which may help you in your client recommendation process. This personal data will include details such as your name, bank account details, address, email address, employer and regulatory authorisation information.
4. In the context of the Data Protection Regulations, we will process your personal data under the following legal bases:
   1. To enter into or perform a contract (this will be your Terms of Business Statement & Application Form for Intermediaries or other agreement (Terms of Business Contract) with Utmost Limited),
   2. To comply with the legal requirements of a European Economic Area (EEA) Member State or the Isle of Man, and
   3. Where this is necessary for the purposes of our legitimate interests or that of a third party, except where such interests are overridden by the interests of the data subject.
5. When we are processing your personal data in order to fulfill Utmost’s legitimate interests, these legitimate interests are:
   1. To comply with applicable law and financial regulation.
   2. To ensure network and information security.
   3. To disclose personal information to regulatory authorities where we are required to do so by applicable law or regulation.
   4. For marketing and communication purposes to keep you informed of product, service and industry-related technical developments, which may help you in your client recommendation process. In these circumstances we may contact you through mediums such as post, email communication and live telephone calls. You may object to the processing of your personal data in this way at any time, by contacting us using the details listed in paragraph 14 or by speaking with your Utmost contact.
6. If you do not provide the necessary personal data, Utmost may not be able to provide your client with a contract for an insurance bond and you and your client with connected services.

INFORMATION PROVIDED BY OTHER SOURCES

7. Not all personal data we hold about you will have been provided directly by you. Where your personal data has been provided to us by another party, this is likely to have been as a result of a client recommendation; by way of a third party introduction; by your employer identifying you as their employee; or where you are a director or signatory of an Intermediary that has entered into a Terms of Business Contract with Utmost Limited. In these circumstances, we will have asked for information such as your name, address and where relevant your personalised contact details such as email address and telephone number.

SHARING INFORMATION

8. We will transfer personal data to:
   1. Associated Isle of Man companies within the Utmost Isle of Man Group, including Utmost Services Limited, which supplies our computer systems.
   2. Regulatory authorities where we are required to do so by applicable law or financial regulation.
   3. Where you provide your consent to do so, third parties for the purposes of providing a business reference in circumstances where you are establishing a relationship with that third party.
   4. Third parties for marketing and communication purposes in order to fulfill our legitimate business interests.
   5. Third party data processors, in circumstances such as where investment or adviser charge payments are facilitated via an insurance bond.
In compliance with the Data Protection Regulations, we will only transfer your information to third parties where they provide an adequate level of data protection.


9. Your personal data will be held, controlled and processed by us in the Isle of Man, which is not a member of the EEA. The Isle of Man has been recognised by the European Commission as having adequate data protection legislation.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

10. To meet our legal and business requirements your personal data will be stored, and accessible, in our business systems for a period of up to seven years following the date on which all connected business relationships have ended. After this period, your personal data will be archived and placed beyond the use of the business, with access restricted to legitimate legal or business requirements. Examples of such requirements include, but are not limited to, legal actions, fund corrections and regulatory changes.

HOW TO UPDATE THE INFORMATION WE HOLD ABOUT YOU

11. It is important that the information we hold about you is accurate and up to date. Please let us know if your information changes, or if the information we hold about you is incorrect. You can ask our Customer Services team to update and correct your information.
If we have disclosed your personal information to another entity as described in paragraph 8, we will also let them know about the changes unless it is very difficult or not possible for us to do so.



YOUR RIGHTS

12. Under the Data Protection Regulations you have certain rights over your personal data. These rights are as follows:
    1. You have the right to request from us access to your personal data through a ‘subject access request’.
    2. You have the right to obtain from us the rectification of any inaccurate personal data we hold about you.
    3. You have the right to erasure of your personal data, unless we have a legal obligation to process your personal information.
    4. You have the right to seek the restriction of the processing of your personal data in certain circumstances.
    5. You have the right to object to its processing. We shall no longer process the data unless there are compelling legitimate grounds for the processing.
    6. You have the right of portability in relation to your personal data. This means you can request we provide you with the personal data we hold about you in a structured, commonly used and machine readable format.
    7. You have the right not to be subject to decisions based solely on automated processing. We do not carry out any automated processing which may lead to an automated decision based on your personal data.
    8. Where we are processing any of your data based upon your consent to do so, you have the right to withdraw this consent at any time.
In order to exercise any of the above rights, please write to or email Utmost’s Data Protection Officer at the details provided below.


13. If you believe we have not complied with the requirements of the Data Protection Regulations you have the right to make a complaint about our data processing to a supervisory authority, for example, the Information Commissioner’s Office in the UK or the Information Commissioner in the Isle of Man. Their contact details are as follows:
Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
UK
SK9 5AF

Telephone: +44 (0)1625 545700 or +44 (0)303 123 1113

Isle of Man Information Commissioner
Head Office
PO Box 69
Douglas
Isle of Man
IM99 1EQ

Telephone: +44 (0)1624 693260

IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER

14. Your personal data is held, controlled and processed by Isle of Man companies in the Utmost Isle of Man Group. Specifically these companies are:
    1. Utmost Limited, which provides insurance bonds, and
    2. Utmost Trustee Solutions Limited, where appointed as a Trustee in connection with an insurance bond issued by Utmost Limited, and
    3. Utmost Services Limited which supplies our computer systems.
The registered address of each company listed in section 14 (a) to (c) is: Royalty House, Walpole Avenue, Douglas, Isle of Man, IM1 2SL.


15. If you wish to exercise any rights, have any queries as to how your data is processed, concerns or complaints, you can contact our Data Protection Officer by emailing: dpo@utmostwealth.com
16. As the Isle of Man is not an EEA Member State, our EEA Appointed Representative in the United Kingdom is an establishment of Utmost Services Limited based at Saddlers House, 5th Floor, 44 Gutter Lane, London, UK, EC2V 6BR.

Cookie Policy

Here is our cookie policy for this website. It describes the types of cookies we use on it, what these cookies do and how you can control the cookies we place on your browser. This website is hosted by Utmost Services Limited ("Utmost Services") on behalf of Utmost International Isle of Man Limited and Utmost PanEurope dac (both companies are referred to herein as "Utmost"). The companies are ultimately responsible for content which relates solely to their company and products. Please see the Terms of Use for more information including company and regulatory information. The cookies are held by Utmost Services on behalf of Utmost.

What are cookies?

Cookies are small text files stored by your browser. They are created when your browser loads our website. Every time you visit our website, the browser you are using e.g. Chrome, Internet Explorer, Firefox, retrieves and sends the file to our server. They help us track information on our systems and identify categories of visitors by using information such as your IP address, domain, browser type and pages visited.

Cookies we use and what are they for

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Utmost Wealth Solutions is the brand used by a number of Utmost companies. Utmost Online is a service provided by Utmost PanEurope dac.

Utmost Services Limited has a UK office at: Saddlers House, 5th Floor, 44 Gutters Lane, London, EC2V 6BR. Registered branch number BR018821.

The following company is registered in Ireland. Utmost PanEurope dac (No 311420) is authorised by the Central Bank of Ireland. Registered office: Navan Business Park, Athlumney, Navan, Co. Meath C15 CCW8, Ireland.

Contact Details

Telephone: 0845 602 9281

Email: info@utmostwealthsolutions.ie

Web: www.utmostinternational.com

Telephone calls may be recorded.

INTRODUCTION

The Utmost Group is committed to working towards the eradication of slavery and human trafficking. We are a global provider of insurance and savings solutions in the UK and Internationally. The Group is owned by its two Founders and funds managed by Oaktree Capital Group LLC. Further details of our ownership structure are available in the Governance section of our Annual Report, available online at www.utmostgroup.com.

As a business that places corporate and social responsibility at the heart of its values, the Utmost Group recognises that respecting human rights is the right thing to do and ensures that appropriate actions are taken to manage risks relating to modern slavery.

This statement sets out the steps taken by the Utmost Group or actions underway during the financial year ended 31 December 2023 and to date, to assist in the detection and prevention of modern slavery across its business operations and supply chains.

OUR BUSINESS

The Utmost Group is a leading provider of modern, flexible solutions which assist our customers in securing their financial futures. The Group has over 1500 employees predominantly based in the UK, Ireland, the Isle of Man and Guernsey, with a small number of staff working in worldwide operations in locations across Europe, Singapore, Hong Kong, Switzerland and the Dubai International Finance Centre.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING:

We are committed to preventing modern slavery or human trafficking in our supply chains or in any part of our business. The Group is committed to conducting business responsibly and upholding the highest standards of governance throughout our operating businesses. The Group has in place a Group Corporate Governance Manual and Policy Suite framework, which alongside this statement contains relevant policies, such as our Corporate Social Responsibility Policy and Outsourcing Management Policy, which set out the necessary principles to manage and mitigate key risks and safeguard the business and all its stakeholders, including employees, suppliers, and customers.

The Group’s approach to human rights extends beyond our supply chain, to employees and contracted staff and we are committed to paying the national living wage in the UK and its equivalent in the other jurisdictions in which we operate. The system of internal controls implemented by our operating businesses includes:

• Protecting employees and whistleblowers.
• Identifying and assessing potential risk areas in our supply chains.
• Mitigating the risk of slavery and human trafficking occurring in our supply chains.

OUR EMPLOYEES

We follow the principles of good corporate governance and Enterprise Risk Management and do not tolerate any malpractice, whether committed by senior managers, employees, suppliers, or contractors acting on our behalf.

The Group Code of Conduct (“Code”) applies to all directors, officers, and employees, requiring that they adhere to the Code. Our employees are encouraged to report any practices or actions where they believe these to be inappropriate or inconsistent with the Code or that may compromise the ethical standards or integrity of the organisation.

The Group Whistleblowing Policy sets out requirements for reporting inappropriate, unethical, or otherwise activities that are inconsistent with the Code. This policy enables an employee to report any improper conduct or unethical behaviour via line management, senior management, the relevant Chief Risk Officer, Company Secretary, Head of HR or Chair of the Audit Committee. This Policy and the associated Guidance Notes are communicated to all employees at least annually and are easily accessed.

Where employees feel that they cannot raise a concern with these individuals, they may make contact on a confidential basis with the Chairman of the local Audit Committee, after which their report will be investigated and considered by the Non-Executive Directors of the relevant subsidiary company. Employees may also raise their concerns with the Chairman of the Audit, Risk and Compliance Committee of Utmost Group plc or if they deem it necessary, employees may wish to contact the applicable external regulator. At all times during any investigation the whistleblower’s identity will be kept confidential. All employees are reminded annually of their right to raise concerns under the Whistleblowing Policy, and to consult with associated guidance.

OUR SUPPLIERS

It is important to us that our commitment to human rights is shared by our suppliers. The Utmost Group accepts a range of goods and services from suppliers located across the globe, although the majority of suppliers have their operations locally in the Isle of Man, Ireland or Guernsey or the United Kingdom. Goods and services utilised by the Utmost Group and its subsidiaries primarily consist of investment services, catering, cleaning, office furniture and stationery, electrical equipment, IT software, property maintenance and utilities.

As the Utmost Group businesses operate in the financial services sector, the risk of being exposed to modern slavery is considered lower than in other industries. However, we recognise that financial services firms cannot be complacent as to the risks that exist in their supply chains and a risk-based approach is taken to identify any high-risk suppliers and prioritise them for review.

Where we enter or renew a contract with a supplier, we will negotiate terms to include standard contractual obligations seeking to ensure that the supplier confirms they have adequate training and policies in place to comply with the Act and avoid slavery.

OUR ONGOING APPROACH AND NEXT STEPS

There is a commitment throughout the Group to ensure that we respect human rights and continue to act as a responsible business. To achieve this, there is a Group Corporate Social Responsibility Policy in place which ensures that all employees of the Utmost Group are provided with ongoing training to ensure that there is the appropriate level of awareness and consistency across the entire business to detect and ultimately prevent modern slavery from occurring anywhere in our supply chain.

This statement has been approved by the Board of Utmost Group plc and signed on its behalf by the Utmost Group CFO.

Ian Maidens

19 April 2024