BROCHURE

STELLAR AIM IHT ISA

BROCHURE

ISA

This Document (“Document”) has been issued by Stellar Asset Management Limited (“Stellar”), which is authorised and regulated by the Financial

Conduct Authority (“FCA”) and whose registered office is at 1 Conduit Street, London W1S 2XA. This Document is dated 5 January 2015.

This Document is only being communicated by Stellar to FCA authorised persons. The communication of this Document by such an FCA

authorised person is only permitted where the FCA authorised person has entered into an agreement with Stellar and is satisfied that this is a

suitable and appropriate opportunity for their clients. This Document is not for general distribution.

This Document is issued solely for the purpose of seeking investment in the discretionary portfolio investment management service described in

this Document which is to be managed by Pilling & Co LP (“Pilling”) and known as Stellar AIM IHT ISA. Stellar AIM IHT ISA, which is not a separate

legal entity, has been created to facilitate investment by investors into companies quoted on AIM.

This Document is provided to you on a confidential basis. You may not copy, reproduce, or further distribute this Document or any of its content

to any other person at any time, nor discuss with any other person the proposal in this Document without the prior written consent of Stellar.

An investment in Stellar AIM IHT ISA may expose an investor to a significant risk of losing all of the money invested. There are significant other

risks associated with an investment in Stellar AIM IHT ISA which are set out on page 17.

This Document should not be communicated outside of the United Kingdom without Stellar’s prior consent. Significantly, the tax treatment for

investors who are based outside of the United Kingdom will differ from that set out in this Document and they may not receive the reliefs available

to United Kingdom investors.

Any individual who is in any doubt about investing in AIM companies through Stellar AIM IHT ISA should consult an FCA authorised person or an

appropriately qualified tax adviser.

The information contained in this Document makes reference to the current laws concerning Inheritance Tax relief (“Relief ”) and income and

capital gains tax relief through investments made within an ISA. These levels and bases of relief may be subject to change. The tax reliefs referred

to in this Document are those currently available to certain persons and their value depends on individual circumstances.

Past performance is not necessarily a guide to future performance and may not necessarily be repeated. You should be aware that the value of shares

of companies quoted on AIM and the income from them may go down as well as up and you may not get back the amount you originally invested.

Stellar has taken all reasonable care to ensure that all the facts stated in this Document are true and accurate in all material respects and that

there are no other material facts, or opinions, which have been omitted, which would make any part of this promotion misleading. However, where

information has been obtained from third party sources, Stellar cannot accept responsibility for the completeness or accuracy of that information

and potential investors must form their own opinion as to the reliance they place on that information.

You will need and be expected to make your own independent assessment of an investment in Stellar AIM IHT ISA and to rely on your own

judgement (or that of your independent financial adviser) in respect of any investments you may make through Stellar AIM IHT ISA and the legal,

regulatory, tax and investment consequences and risks of so doing.

If you submit an Application Form to Pilling, the Investment Manager, your application will be processed immediately. If you decide to cancel your application

subsequently the fees and charges described in this document may change the amount you receive back as will any adverse market movements.

The Investment Manager reserves the right to modify its investment strategy for applications at the annual ISA limit (currently £15,000) and it is

likely that the portfolio will not be as diversified.

IMPORTANT NOTICE

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Stellar AIM IHT ISA is

Income tax free

Capital gains tax free

Inheritance tax free after two years

CONTENTS

Key Benefits 5

The Investment Strategy 5

Structure 6

AIM 7

The Investment Manager 8

Track Record 10

The Sponsor 10

Case Study 11

Optional Life Assurance Policy 12

Life Assurance Payout 12

Withdrawing Money 14

How To Apply 14

Fees And Expenses 15

Adviser Charging 15

Other Information 16

Risk Factors 17

✶ 03

Dear Investor

Since our inception in 2008 we have launched a number of products that mitigate Inheritance Tax (IHT).

Our products are designed to be easy to understand with all fees and charges clearly set out. Our

IHT products offer clients complete control over the capital and we are the only provider to offer a

comprehensive, but optional, insurance policy to cover any loss in value should the initial investment

have fallen in value at the date of death. See page 12 for further details.

In recent years we have found that one of the biggest problems clients face is the significant sums

committed to ISAs over many years have, in later life, become a problem as they form part of their

estate for IHT purposes.

Stellar AIM IHT ISA offers the opportunity to invest in a portfolio of shares of companies quoted on

AIM which will be held within an ISA which means that an investment will be Inheritance Tax free,

Income Tax free and Capital Gains Tax free, making it one of the most tax effective investment

opportunities available in the market

We have joined forces with Pilling, an experienced investment manager with a track record of

investing in AIM and smaller companies. To minimise the risk associated with an investment in equities,

the life assurance policy can also be put in place for each Investor which will cover any loss in value

of the portfolio.

Yours sincerely Jonathan GainChief Executive of Stellar Asset Management

04 ✶

KEY BENEFITSThere are a number of ways in which an IHT liability can be mitigated but with Stellar AIM IHT ISA an Investor has the following advantages.

ControlThe investment is made in your name, through your nominee, and you have access to your assets at all times. The principal drawback of using trust planning or gifts is that access to the capital is lost.

TimelyOnce Stellar AIM IHT ISA has been held by an Investor for two years, its

value will be exempt from IHT, unlike some more traditional methods of IHT planning such as trusts or gifts.

Comprehensive tax benefitsAn AIM portfolio invested through an ISA wrapper not only offers relief from IHT (“Relief”) but retains existing ISA income tax and CGT advantages. All income is received with no further liability to income tax and any capital growth will be free of capital gains tax. There will be no requirement to declare your Stellar AIM IHT ISA investment on your tax return.

Fund ManagementStellar AIM IHT ISA is managed by a manager with proven investment management expertise and an excellent track record.

The principal risks associated with this investment are set out on page 17.

THE INVESTMENT STRATEGY

There are almost 1,100 companies listed on AIM, as at October 2014 with a combined worth of £72 billion. The companies themselves range in size from a few hundred thousands of pounds to over £1 billion. In many cases research coverage is thin and information about companies can be patchy. For this reason it is important to have a specialist choosing and managing any AIM portfolio for Business Relief purposes.

We believe the higher risk associated with of AIM makes it essential to have a broad spread of companies that have been researched and are then

monitored. Over the last decade Pilling has created a core universe of companies from which it selects the stocks for its AIM portfolios. These companies are regularly appraised and others are added or removed when appropriate opportunities arise or as circumstances change.

When selecting an AIM company, Pilling focuses on capital preservation whilst seeking to mitigate investment risk wherever possible. It intends to invest in a broad spread of companies selected using the following principal criteria;

• balance sheet strength;• market valuation and liquidity;• ability to pay dividends;• uncomplicated business model that is likely to survive changing fashions;• management equity commitment; and• quality of shareholder base.

Investment into AIM companies offers opportunities to those who understand the market. The AIM market is not covered by as many analysts as the FTSE 100 or 250 companies and therefore, for those who research and specialise in this market, there is an opportunity to identify attractive Investee Companies ahead of other investors.

For each Investor, Pilling will construct a diversified portfolio of AIM securities, all of which are capable of being held within an ISA and which qualify for Business Relief and therefore will be exempt from IHT two years after the investment date. In normal market conditions, investments will be made within four weeks of the initial investment and will be spread across approximately 20 companies.

Pilling will have full discretion to make investment decisions within the portfolio without prior approval from Investors. These decisions will be made in line with the above investment strategy. Investors retain full beneficial ownership of their portfolio; if an Investor needs access to their funds, Pilling can sell part, or all, of their portfolio and remit the proceeds at any time.

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STRUCTURE

Stellar AIM IHT ISA is not a separate legal entity but comprises a discretionary portfolio investment management service operated by Pilling, which prospective investors will enter into on the basis of the Investment Management Agreement.

Stellar AIM IHT ISA is designed to facilitate investment into companies quoted on AIM which are capable of being held within an ISA and qualify for the purposes of Business Relief.

Upon acceptance of a completed and signed Application Form by the Investment Manager, Investors’ monies will be held in a bank account pending investment, with each Investor’s investment clearly and separately identified.

The shares in which Investors’ monies are invested will be bought by, subscribed for, issued to and held by the Investment Manager, acting as nominee for each investor.

Upon the death of the Investor the securities are included in the deceased’s estate for probate purposes and revalued as at the date of death. However, if the securities were held for two years or more then 100% Business Relief is available, which should mean that no IHT will be payable on the market value of the securities at the time of death.

If the Investor dies within two years of investment then the portfolio will not benefit from Business Relief and the assets will be liable to IHT as part of their estate. However, if the Investor has a surviving spouse, the assets may be transferred without triggering an IHT liability and without the requirement of a new two year qualifying period

WHY CONSIDER A TAX EFFICIENT IHT PORTFOLIO?

The rise of house prices in recent years has taken an increasing number of people over the IHT exempt threshold of £325,000. The need for IHT planning is, therefore, becoming an important consideration for a growing number of people particularly since this exempt threshold is being held at current levels until 2018.

The 1986 Finance Act amended the provisions relating to Business Relief, effectively meaning that the value of any qualifying investment would be disregarded for IHT purposes if it had been held for at least two years at the date of death.

There is also a ‘replacement property provision’ within the Business Relief legislation which allows for the ability to ‘replace’ qualifying assets from any disposal proceeds without the two year period being restarted.

The ‘qualifying’ rules broadly mean that most AIM quoted and unquoted securities could potentially qualify for Business Relief.

The major restrictions are as follows:• the class of security must be ‘unquoted’ (which for taxation purposes includes securities quoted on AIM); and

• the underlying business assets must be employed in an on-going qualifying trade. This effectively excludes businesses which trade in securities, land or buildings, or are involved in investment activities.

Relief will only be available on the amount invested in AIM qualifying companies and will be net of the fees and charges shown on page 15.

The Individual Savings Account (Amendment No. 3) Regulations 2013 also amended the types of investments that can be held within an ISA to include shares of companies quoted on AIM.

From 28 April 2014 Stamp Duty and the Stamp Duty Reserve Tax (SDRT) will no longer be chargable on transactions in securities admitted to trading on AIM.

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Reasons why clients invest in Stellar AIM IHT ISA

Insurance against loss in value

AIM IHT ISA

ISA

100% IHT exemption after only 2 years

Complete control and full access to your capital

Income tax and capital gains tax benefits

INSURANCEINHERITANCE

TAX CAPITALTAX

Some familiar AIM companies

Sources: London Stock Exchange and most recent published reports and accounts

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AIM

AIM was launched in June 1995 by the London Stock Exchange plc, as the Alternative Investment Market, and provides relatively small, growing and occasionally new companies with a relatively inexpensive and flexible method of gaining a stock market quotation. In fact, a number of previously fully listed companies have moved to AIM to take advantage of the market’s attractions.

There are now around 1,100 companies quoted on AIM with a total market value of over £72 billion: the average size of an AIM company is approximately

£65 million. Although a quotation on AIM was once seen as one step on the way to a full listing, AIM has in fact become the market of choice for many dynamic and successful enterprises.

Familiar names of companies quoted on AIM are ASOS, Majestic Wines, Songbird Estates (owners of Canary Wharf), Mulberry and Prezzo. Some companies such as Domino’s Pizza have since moved on to the Official List.

M&CSaatchi Media 207.5m 162m 10.4m 1,708 London

Majestic Wine

Wine Retail 242.7m 278m 23.8m 994

Watford, Herts

Youngs & Co Public Houses 439.9m 211m 26.6m 3,357

Wandsworth, London

ChurchillChina

Householdgoods 60.8m 43m 2.8m 535 Stoke-on-Trent

BUSINESS PROFIT EMPLOYEES HEAD OFFICE

TURNOVER

£SECTOR

MARKETCAPITALISATION

THE INVESTMENT MANAGER

Pilling is a privately owned and managed stockbroking partnership that traces its roots back to the latter years of the cotton boom in Manchester when it was one of the richest cities in the world. Times may have changed but Pilling clients still enjoy the benefits of being able to speak directly to the professional and friendly people who manage their investments and administer their accounts.

Past winners of Investors Chronicle awards in several categories, the firm has also been a pioneer of investment products designed to help clients achieve their goals. From PEPs in the 1980s through to more recent developments like CTFs and JISAs, Pilling has a proud history of supporting individual investors’ needs, of all sizes.

The investment management team at Pilling control client assets in excess of £250 million and formulate the firm’s wider investment policies.

Pursuant to the Investment Management Agreement, the Investment Manager will be appointed to manage each Investor’s Portfolio.

The Investment Manager is authorised and regulated by the FCA.

THE INVESTMENT TEAM

Terry Applegate joined Pilling in 2002 after working in corporate finance with WH Ireland. A member of the investment team since 2004, he takes joint responsibility for the work involved in selecting stocks for Pilling’s investment strategies aided by his strong relationships with the equity analyst community.

Alistair Hodgson has been an investment manager at Pilling since graduating from their dealing room in 1998. Prior to working for Pilling he trained in aspects of financial advice with what was then Refuge Assurance plc. A chartered wealth manager, he now manages bespoke portfolios for the firm’s larger clients and consults on the construction of model portfolios for a wider audience.

Nigel Moore, chartered wealth manager, began his career in the industry at Brewin Dolphin which he left to join Pilling’s dealing team in 1998. Having passed his securities institute diploma exams, Nigel was promoted to the investment management department in 2000 to focus on building up the firm’s advisory and discretionary portfolio service. He now manages over £50 million in client assets and has a prominent role in the equity and fund selection process and helps formulate the asset allocation strategy within the department.

Mike Tattersall has been one of Pilling’s investment managers since 1995. An economics graduate of London University, he provides the team with their macro-economic guidance as well as having decades of experience in asset allocation and stock selection. He devised Pilling’s original portfolio for Business Relief and oversees its universe of selected AIM companies for investment, a concept he created in 2003.

Sally Greenwood originally worked for Pilling from 2001-2006, initially as a dealer, before qualifying as an investment manager. In 2006 she moved to Barclays Wealth & Investment Management as a private banker, where she spent over seven years working with high net worth individuals to assess their overall wealth and helping to identify the most tax efficient way of achieving their long term financial goals. She has now re-joined the investment team as a wealth manager to focus on managing discretionary portfolios

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✶ 09

A proven track record

TRACK RECORD

The investment team at Pilling has managed AIM portfolios for private clients since 2008; this has used an identical strategy to that which will be adopted for Stellar AIM IHT ISA. The performance summary to 5 October2014 is shown below.

An investment of £50,000 (made in October 2009) into their AIM portfolio would now be worth £87,300. This is a total return of 75%. The returns significantly outperform a comparative investment in either the FTSE AIM All-Share Index or the FTSE 100 Index which would only be valued at £58,500 and £64,950 respectively.

The returns from these comparative investments are further diluted by the effects of IHT as can be seen from the case study on the following page.

THE SPONSOR

Stellar Asset Management Limited is the sponsor of the Stellar AIM IHT ISA and was established in 2007.

Its directors have been responsible for the creation and management of a wide range of investment opportunities for the retail investment market. The directors were employed by Close Brothers Investment Limited for a combined total of almost 40 years and launched many investment products.

A number of these investment opportunities were structured to mitigate investors’ taxation liabilities and the directors have experience in promoting opportunities such as that proposed in this Document. They have also acted as marketing adviser to companies which have sought and achieved stock exchange listings.

Stellar offers a range of tax efficient investment opportunities including Stellar Succession and Stellar AIM IHT Portfolios which have also been designed to utilise Business Relief. Further details on this and all other opportunities provided by Stellar can be found at www.stellar-am.com.

The board of directors of Stellar are Jonathan Gain, Craig Reader, Gordon Pugh and Matthew Steiner.

TIME PERIOD TIME PERIOD TIME PERIOD TIME PERIOD

2.4% 48.8% 74.6% 76.7% ISA Pilling AIM IHT portfolios

1.1% 27.9% 29.9% 31.1%FTSE 100

-5.5% 7.3% 17.0% 21.3%

FTSE 100FTSE AIM All-Share

1.4% 27.8% 32.1% 38.2%FTSE 100

FTSE All-Share

FTSE 100

Performance 1 year Performance 3 years Performance 5 years Performance 6 years

Investors should note that past performance is not a reliable indicator of future performance and Investors should not rely upon past performance when considering whether or not to invest in Stellar AIM IHT Portfolios. Please visit www.stellar-am.com for performance updates.

Source: Pilling & Co LP

PERFORMANCE AS AT 5 OCTOBER 2014

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Case StudyIf a client had invested £300,000 in Stellar | AIM IHT ISA in October 2011 then the value of her investment compared to holding cash or an investment in FTSE 100 Index is very favourable. The effect of this outperformance is multiplied significantly when IHT is taken into account, as can be seen from the table below.

*Interest at 0.5% per annum earned monthly. Sources: Pilling & Co and Yahoo Finance. Investors should note that past performance is not a reliable indicator of future performance and Investors should not rely upon past performance whenconsidering whether or not to invest in Stellar AIM IHT ISA

INHERITANCETAX

INHERITANCETAX

INHERITANCETAX

VALUE £182,720

VALUE £230,220

VALUE £446,400

AFTER 3 YEARS AFTER 3 YEARS AFTER 3 YEARS

VALUE £304,533* VALUE £383,700 VALUE £446,400

FTSE 100 £300,000

CASH £300,000

AIM IHT ISA£300,000

ISA

✶ 11

OPTIONAL LIFE ASSURANCE POLICY

A life assurance policy is available to cover any loss should the initial investment have fallen in value as at the time of death. Any increase in the value of the portfolio remains for the Investor’s benefit whilst any decrease in the initial investment may be covered by the life assurance policy subject to the terms and conditions of the policy. An annual fee of 2.50% applies for this standard policy. This fee will be reviewed every two years; the next such review is in June 2015.

The maximum amount that can be paid out by the life assurance policy is £250,000 unless additional cover has been specifically arranged.

The optional downside life assurance policy is available on standard terms if the following conditions are met.

• The Investor is under 80 years old.• The Investor is not currently receiving treatment for any symptoms, illnesses or injuries.• The Investor has not previously been advised to undergo any medical treatment or are awaiting any medical treatment.• The Investor has never had a proposal for Life, Critical Illness, Disability or Private Medical Insurance declined, postponed, withdrawn or accepted on special terms.• The Investor has not resided outside the European Union (EU) for longer than three months in a calendar year or travel frequently outside the EU.

On standard terms the policy will cease when the Investor reaches their 85th birthday (or on the second life in respect of joint policies). Cover can be extended beyond an Investors’ 85th birthday but it will be based on an updated health disclosure and may result in changes to the annual fee. Investors may, at their discretion, cancel the insurance policy at any time.

If an Investor does not meet these criteria, insurance may still be available and a questionnaire will need to be completed. This is available upon request from Stellar.

Please be careful when answering these questions as a detailed current and historical medical report will be requested by the underwriters after any claim against the policy. Any incorrect information may invalidate the policy.

The protection cover by means of a life assurance policy is available through Pendulum Financial Management (“Pendulum”) which is regulated by the Financial Conduct Authority under reference 527714.

The life assurance policy is provided by a UK registered insurance company with 75% of the risk underwritten by GenRE, a subsidiary of Berkshire Hathaway.

The majority shareholder of the UK insurance company is The Mediterranean and Gulf Co-Operative Insurance and Re-Insurance Company which provides a range of insurance and reinsurance products. It had net assets in excess of £206 million as at 31 December 2013.

The above is a brief summary only of the standard terms and conditions of the policy that can be arranged by Pendulum. An Investor should read the policy terms and conditions in full before determining whether or not to take out any insurance in respect of their investment. The Policy Document is available upon request.

All Investors who wish to obtain a policy should carefully consider the terms of the policy and obtain independent advice.

LIFE ASSURANCE PAYOUT

Any payout of the life assurance policy may crystallise a further IHT liability. To avoid this, any payout can be written into trust in order to maximise tax efficiency.

Stellar has produced a draft trust document to enable Investors to put in place a trust structure if they so wish. Based on current legislation, by using the trust, any pay out under the terms of the life assurance policy will be channelled directly to your beneficiaries, rather than being paid into your estate, where it may be subject to IHT.

This product is designed primarily to be an IHT tax planning product. In respect of any other taxation which may apply to any portion of any pay out or for advice on the trust structure, you are encouraged to seek professional advice because individual circumstances may vary.

If you wish to take advantage of the trust structure, please tick the box in Section 4 of the Application Form and we will send you the required documentation.

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✶ 13

WITHDRAWING MONEY

You can withdraw monies from Stellar AIM IHT ISA at any time, Withdrawals will usually be satisfied within 10 days of Pilling receiving your withdrawal request.

Where the withdrawal amounts to £30,000 or more, the Investment Manager will use their best efforts to raise the entire amount within the timescale requested (to be at least 10 working days from receipt of the request), but reserve the right, in the Investor’s own interest, to take longer if necessary to ensure the orderly disposal of investments. However, the timescale for any withdrawals or transfers will comply with the ISA Regulations.

Investors should note that liquidity in some companies quoted on AIM may be limited, making it difficult to accommodate sudden large orders for sales or purchases of investments. Money withdrawn from Stellar AIM IHT ISA will come back within your estate for IHT purposes. Money withdrawn from an ISA will also no longer be eligible for the ISA related capital gains and income tax benefits (this does not include transfers from one ISA to another, which continue to receive these tax benefits).

ADVISER CHARGING

An investment in Stellar AIM IHT ISA can facilitate adviser charging and arrangements should be detailed on the appropriate Application Form.

HOW TO APPLY

Please complete and return an Application Form, a copy of which is located in the Application Pack. Please ensure that you satisfy the money laundering requirements (as explained in the accompanying notes of the Application Pack) and enclose the relevant documentation with your application.

The minimum and maximum level of investment in respect of new ISAs is £15,000 (unless we are managing other portfolios on your behalf).

There is no maximum level in respect of ISA transfers.

For investors who opt to take out the life assurance policy, the standard cost only applies to a maximum investment of £250,000.

Please make your cheque payable to “Pilling & Co” and send it together with your application to:

Pilling & CoHenry Pilling HouseBooth StreetManchesterM2 4AF.

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Advised Investment An Investor who applies

and is provided with advice

Non-advised InvestmentAn Investor who applies

through an intermediary who does not provide any advice

Direct InvestmentAn Investor who applies without an intermediary

INVESTOR

NON-ADVISEDINVESTMENT

INITIALCHARGE

4%

ANNUALCHARGE

1.75%

✶ 15

Fees and expensesThe fees and expenses payable will depend on the category of each Investor.

These are set out clearly in this table.

From this annual management fee the Investment Manager will pay an administration fee of up to 0.75% per annum of the value of the portfolio to Stellar. From this fee non-advised commission will be paid.

The annual cost of the life assurance policy is 2.5% of the value of your investment in Stellar AIM IHT ISA, should you decide to take it out.

In addition, there are dealing and administration charges payable to the Investment Manager. Details of these are shown in the Investment ManagementAgreement.

All fees may be subject to VAT.

INVESTOR

ADVISEDINVESTMENT

INITIALCHARGE

1%

ANNUALCHARGE

1.25%

ADVISER

INVESTOR

NON-ADVISEDINVESTMENT

INITIALCHARGE

4%

ANNUALCHARGE

1.75%

ADVISER

Charging agreed with adviser and added to

charges above

2.5% Initial commission0.5% per annum paid from charges above

TransfersStellar AIM IHT ISA has been designed to accept in specie transfers of existing equity portfolios (including ISAs), regardless of size and constitution. This could for example be a portfolio of companies on larger stock exchanges or existing AIM portfolios with a different manager or stockbroker.

The portfolio will be reconstituted by Pilling and managed in accordance with the terms described earlier in this Document. The optional insurance policy can also be effected after the transfer.

Service Management Agreement Under the Service Management Agreement, Stellar has agreed to act as sponsor in respect of the promotion and marketing of Stellar AIM IHT ISA to potential investors on behalf of the Investment Manager.

In remuneration for its services under the Service Management Agreement, Stellar will be entitled to a share of the management fees. A summary of the fees payable is set out on page 15.

The Service Management Agreement shall continue until terminated. It may be terminated by either Stellar or the Investment Manager giving three months’ written notice to the other.

Investment Management Agreement The arrangements described in this Document relate to the offering by the Investment Manager of a discretionary portfolio investment management service. This service will be conducted subject to the terms of the Investment Management Agreement.

By applying to invest through Stellar AIM IHT ISA, the Investors appoint Pilling as investment manager to invest on a discretionary basis into the shares of AIM companies selected by the Investment Manager.

Conflicts PolicyThe Investment Manager, in accordance with FCA rules, operates its business in such a way as to minimise the occurrence of conflicts of interest and to enable it to resolve such conflicts where possible. The Investment Manager maintains a written conflicts policy, a summary of which is shown in the Investment Management Agreement.

The Investment Manager’s Best Execution PolicyWhen executing instructions the Investment Manager will take all reasonable steps to obtain the best possible result. Further details of the Investment Manager’s order best execution policy can be found in the Investment Management Agreement.

Administration and ReportingThe Investment Manager has its own in-house administration and support team which provides a comprehensive administration service. Clients are offered a simple and efficient account opening process with only one set of

forms and will receive six-monthly valuations. Contract notes, valuation statements and reports will be available online.

The Investment Manager also provides a probate valuation service and can provide full estate liquidation. Probate valuations can be requested by executors/administrators and are usually produced within 10 working days. Fees are charged at the rate of £10 plus VAT per line of stock.

Income from investments held in an Investor’s portfolio can be reinvested or paid out whichever is the preferred option. Interest is paid on the cash balances held. ComplaintsShould an Investor not be satisfied with the investments made through Stellar AIM IHT ISA, the Investor may complain to the Compliance Officer at the Investment Manager in the first instance.

If an Investor has any complaint about the performance of Stellar, that complaint should be addressed to the Compliance Officer at Stellar. If an Investor has any complaint about the performance of the insurance broker that complaint should be addressed to the Compliance Officer at Pendulum.

If the Investor is still not satisfied with either the Investment Manager’s, Stellar’s or Pendulum’s response, then the Investor may be entitled to pass their complaint to the Financial Ombudsman Service. More information about an Investor’s right to complain to the Financial Ombudsman Service is available at www.fos.org.uk

CompensationIn the event that the Investment Manager is unable to meet its liabilities to an Investor in full for any valid claims in respect of certain types of investment business carried out with or for the Investor, certain types of Investor may be entitled to compensation from the Financial Services Compensation Scheme. Payments under the scheme are limited and subject to maximum payments. The level of compensation currently available under the scheme depends upon the type of business and the circumstances of the claim: most types of investment business are covered for 100% of the first £50,000. Full details of this cover and how to obtain compensation are available to Investors upon request.

More information can also be obtained from the Financial Services Compensation Scheme on 020 7741 4100, at their address: 10th Floor, Beaufort House, 15 St Botolph Street, London, EC3A 7QU or at their website: www.fscs.org.uk

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Other information

✶ 17

APPENDICES

• Investing in smaller cap companies is high risk and may expose an investor to a significant risk of losing their investment.

• Investment through Stellar AIM IHT ISA should not be considered as a short- term investment. Any withdrawals within two years of investment into AIM companies will result in the unavailability of relief in relation to those companies upon the death of the Investor.

• The past performance of investments managed by the Investment Manager should not be regarded as an indication of the performance of future investments made through Stellar AIM IHT ISA.

• It may be difficult to obtain accurate information in order to determine the current value of an Investor’s investment through Stellar AIM IHT ISA.

• AIM companies may be illiquid investments and it may take some time to invest and divest your Portfolio.

• Market makers may not be prepared to deal in all AIM quoted securities.

• Many smaller quoted companies have small management teams and are highly dependent on the skill and commitment of a small number of individuals. The performance of these companies may therefore be adversely affected by the departure or unavailability of certain key personnel.

• Smaller quoted companies are commonly experiencing significant change and carry higher risk than would investment in larger or longer established businesses.

• Force majeure events, which are events beyond the control of any party, including fire, flood, earthquake and other acts of God, terrorist attacks and war may affect a party’s ability to perform its contractual obligations or may lead to the underperformance of an Investee Company.

• The Investment Manager will use its best endeavours to invest in companies quoted on AIM which qualify under the Business Relief legislation. However, the Investment Manager cannot guarantee that all investments will qualify for such relief and therefore accepts no liability in this regard.

• Following the admission of a company to the main market of the London Stock Exchange, Relief for Inheritance Tax purposes will cease.

• The levels and bases of reliefs from taxation may change or such reliefs may be withdrawn. The tax reliefs referred to in this Document are those currently available in accordance with current legislation and their value depends on the individual circumstances of Investors at the point of investment.

• The tax reliefs referred to in this Document may not continue to apply throughout the life of the investment.

• The tax year for which Relief is available may be later than originally envisaged if the timing of investments is delayed.

• The taxation treatment depends on the individual circumstances of that Investor and may change in the future. Investors are recommended to seek independent professional advice regarding the tax implications of any investment through Stellar AIM IHT ISA.

Risk factors

Stellar AIM IHT ISA may not be suitable for all investors. Potential investors are recommended to seek independent financial and tax advice before investing. Please not that neither the Sponsor or the Investment Manager are able to provide you with advice about whether you should invest in this product.

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APPENDIX 1 DEFINITIONS

“THE ACT” Financial Services and Markets Act 2000

“AIM”The market of that name operated by London Stock Exchange plc

“APPLICATION FORM”an application form to invest in Stellar AIM IHT ISA completed by a prospective investor

“APPLICATION PACK” the associated brochure including the Application Form

“BUSINESS RELIEF” OR “BR”relief from Inheritance Tax on certain types of business property

“DOCUMENT” this document relating to Stellar AIM IHT ISA “FCA”The Financial Conduct Authority

“HMRC”HM Revenue & Customs

“IHT” Inheritance Tax

“ISA” An Individual Savings Account which is subject to beneficial tax treatment under the ISA Regulations

“ISA REGULATIONS” The Individual Savings Account Regualtions 1998

“INVESTEE COMPANY” a company quoted on AIM in which the Investment Manager makes an investment on behalf of Investors and Investee Companies shall mean all or any Investee Company

“INVESTMENT MANAGER OR PILLING” Pilling & Co a limited partnership registered in England and Wales under company number LP013734, which is authorised and regulated by the Financial Conduct Authority

“INVESTMENT MANAGEMENT AGREEMENT”the investment management agreement to be entered into between (1) Pilling as the Investment Manager, and (2) each of the Investors, in the form set out in the attachment to this Document pursuant to a valid application in accordance with the terms of this Document

“INVESTOR”a person who completes an Application Form which is accepted by the Investment Manager and who thereby enters into the Investment Management Agreement with the Investment Manager and invests through Stellar AIM IHT ISA in Investee Companies

“OFFICIAL LIST” the official list of the UK Listing Authority

“PORTFOLIO”in respect of an Investor, the investments made by the Investment Manager on the Investors behalf through Stellar AIM IHT ISA which are allocated to him or her and which are registered in the name of the nominee on his or her behalf

“RELIEF” relief from inheritance tax under current legislation

“STELLAR AIM IHT ISA” The Stellar AIM IHT ISA which describes a number of separate discretionary portfolio investment management agreements, each in the form of the Investment Management Agreement

Definitions

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STELLAR ASSET MANAGEMENT LIMITED Kendal House 1 Conduit Street, London W1S 2XAt 020 3195 3500 e info@stellar-am.com www.stellar-am.com

Authorised and Regulated by the Financial Conduct Authority