Scheme Particulars

ARBSSP – V2.0 Page 2 of 14

1. Definition and Interpretation The following words and expressions shall have the corresponding meanings wherever appropriate.

“Beneficiary” means any person, trust or charity, nominated by the Member or any person who ICML in their sole and

absolute discretion deems eligible to receive Death Benefits;

“Benefit or Benefits” means Retirement Benefits, Early Retirement Benefits and Death Benefits referred to in Rules 3,

4 and 5 of the Scheme Document;

“Connected Person” has the meaning given to it under Retirement Scheme Law;

"Flexi-Access Drawdown" means the flexibility of the Member being able to take unlimited regular and/or ad-hoc

lump sum income payments from the Intended Retirement Age as required;

"HMRC" means Her Majesty's Revenue and Customs, a government department that administers and collects taxes

within the UK;

“ICML” refers to Integrated-Capabilities (Malta) Ltd, a subsidiary of I-Cap Group Ltd, that is regulated and licensed by

the Regulator to provide fiduciary services, trustee services and to act as administrator to private foundations and

retirement schemes licensed by the Regulator;

“Intended Retirement Age” means an age the Member chooses to commence taking Retirement Benefits from the

Scheme provided that this falls within the Normal Retirement Age;

"Investment Adviser" means a professional entity appointed by the Member and approved by ICML as suitably

licensed, authorised and regulated in accordance with Retirement Scheme Law, to advise the Member on the choice

of investments within the Member’s Pension Fund;

"Investment Manager" means a professional entity appointed by the Member and approved by ICML to be suitably

licensed, authorised and regulated in accordance with Retirement Scheme Law, to manage the investments within the

Member’s Pension Fund;

“Investment Platform” means a professionally managed account used to consolidate a series of investments under

one roof;

“Investment Portfolio” refers to either an Investment Platform or a Life Assurance Bond;

“Life Annuity” means an insurance contract provided by an insurer which has been approved by ICML and where the

insurer makes payments at fixed intervals while the person insured is alive;

“Life Assurance Bond” means an insurance policy provided used for the purpose of investing a premium and where

the insurer will thereafter pay a sum of money to the policyholder upon death of the insured person;

“Managed Portfolio Service” means a pre-defined collective investment strategy which is actively managed by an

Investment Manager to cater for a specified risk profile and investment objective;

“Member or Membership” means any applicant accepted by ICML to join the Scheme;

“Normal Retirement Age” means an age between 50 and 75 years of age, as established by Retirement Scheme Law,

provided that if the Member’s Pension Fund originates from a transferred UK Registered Pension(s), the Normal

Retirement Age shall not be less than 55 years of age or any other minimum retirement age applicable to ROPS in

terms of UK Law;

“Pension Fund” means the net value at any time, as determined by ICML, of the distinct individual segregated account

of the Member to which are allocated assets and liabilities distinct from other assets and liabilities allocated to other

Member’s individual segregated accounts in the Scheme;

ARBSSP – V2.0 Page 3 of 14

“Permanent Invalidity” means physical or mental deterioration which prevents the Member from following normal

occupation or which seriously impairs the earning capacity and is accepted by ICML upon receipt of

suitable medical evidence;

“Professional Member” means a suitably qualified and experienced Member in accordance with Retirement Scheme

Law and approved by ICML to directly manage investments within their own Pension Fund without the need to appoint

an Investment Adviser and/or Investment Manager.

“Programmed Withdrawals” means a series of fixed or variable, periodic payments to the Member which shall be

based on publicly available annuity or drawdown rates and which follow sound and prudent actuarial principles;

“Regulator” means the Malta Financial Services Authority;

“Retirement Scheme Law” means the Retirement Pensions Act as replaced or amended, including, for the avoidance

of doubt, any regulation, rule, directive, guidance or requirement issued under it from time to time;

"ROPS" means a Recognised Overseas Pension Scheme that is recognised by HMRC and able to receive transfers of

UK Registered Pensions;

"Scheme" means the Azure Retirement Benefit Scheme which was established as a perpetual trust by the Scheme

Document on 19th June 2018;

“Scheme Document” means the written instrument establishing the Scheme;

“UK Registered Pension” means any pension scheme or arrangement registered with HMRC, as defined under the UK

Finance Act 2004.

2. General Information

This document has been produced for general guidance purposes in accordance with Retirement Scheme Law. The

receipt of this document after the date hereof, should not be relied upon as implying that such statements remain

correct since Retirement Scheme Law may be subject to changes.

It is not intended for the Scheme Particulars to be relied upon as constituting legal, tax or investment advice and

should not be used as a substitute to professional advice or used in formulating any decision without first seeking

such advice.

Tax treatment depends on the circumstances of each person and no warranty regarding the appropriateness of joining

the Scheme is being given. Professional advice should be taken from a suitably qualified and licensed independent

financial adviser both on the appropriateness of joining the Scheme and the implications of the payment of Benefits

in your country of tax residence.

Careful attention to detail was taken to ensure the content of the Scheme Particulars is accurate however ICML will

not accept any responsibility or liability whatsoever for any loss or damage arising from the reliance on the information

contained within this document.

The full details of the Scheme are set out in the Scheme Document therefore the Scheme Particulars should be read

in conjunction with the Scheme Document. A copy of the Scheme Document may be provided to you by ICML upon

request.

ICML or any of its associated companies are not licensed to offer legal, tax or investment advice or recommendations

to the suitability of the Scheme.

ARBSSP – V2.0 Page 4 of 14

3. Principal Parties Trustee

Integrated-Capabilities (Malta) Ltd of 45/13, Strait Street, Valletta, Malta

Administrator

Integrated-Capabilities (Malta) Ltd of 45/13, Strait Street, Valletta, Malta

Auditor

ZD Assurance Ltd of 230 Second Floor, Eucharistic Congress Road, Mosta, Malta

Legal Adviser

GANADO Advocates of 59, Strait Street, Valletta, Malta

Banker

Royal Bank of Scotland International of Royal Bank House, 2 Victoria Street, Douglas, Isle of Man

4. Structure and Purpose The Scheme is registered with the Regulator as a defined contribution, personal retirement scheme in terms of

Retirement Scheme Law and is recognised exclusively as a member-directed Scheme which means that its Members

may direct the investments within their Pension Fund based on one or more of the following options:

➢ Appoint an Investment Adviser to advise on the choice of investments; and/or

➢ Appoint an Investment Manager to manage the investments; or

➢ Qualify as a Professional Member to personally manage the investments.

The purpose of the Scheme is to offer a flexible and tax-efficient solution for retirement planning which provides

Benefits to its Members and Beneficiaries according to the following options:

➢ Retirement Benefits to Members during retirement;

➢ Early Retirement Benefits to Members on the grounds of Permanent Invalidity;

➢ Death Benefits to Beneficiaries after the death of a Member.

In addition to being registered in Malta, ICML also notified HMRC that the Scheme meets the requirements to

operate as a ROPS.

5. Trustee and Administratorp ICML is appointed to perform trustee and administrative duties in connection with the overall operation, management

and ordinary day-to-day administration functions of the Scheme, in accordance with the Scheme Document and

Retirement Scheme Law. In performing its duties, ICML acts as the legal owner of the Scheme’s underlying assets and

shall remain committed to act solely in the best interests of the Members and Beneficiaries.

The trustee must always be a company operating in and having an established place of business in Malta and licensed

by the Regulator to act as a retirement scheme administrator.

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6. Membership At the discretion of ICML, Membership to the Scheme shall be open to persons of all nationalities between 18 and 75

years of age. Your Membership will be subject to ICML having first received your completed ‘Member Application’,

evidence and verification of your identity and any other relevant documents in such form as ICML may require.

On being accepted as a Member to the Scheme, ICML will create an individual segregated account on your behalf, to

which are allocated assets distinct from other assets allocated to other individual segregated accounts.

The Standard Terms of Business and the rules set out in the Scheme Document shall govern the relationship between

ICML and the Members.

7. Functionaries Peter Kevin Perry (MBA, ACIS, TEP) - Director

Kevin is the founder of I-Cap Group Ltd and has worked in the fiduciary services industry since 1981. Kevin holds a

Master’s in Business Administration from Durham University, is an associate member of the Institute of Chartered

Secretaries and Administrators and a member of the Society for Trust and Estate Practitioners. He brings pension

trustee experience going back to the mid-nineties and has experience in acting as a trustee of regulated pension

schemes.

Andrew Mackenzie Dawson (FCIS, MCSI) - Director

Andrew has worked in fiduciary services industry since 1986 and is a Fellow of the Chartered Institute of Secretaries

and Administrators. He has comprehensive practical experience in the formation and administration of international

trusts and has considerable experience dealing with the day to day trusteeship to different types of retirement

schemes in the Isle of Man and Malta.

Robert Arthur Cannell (TEP, Cert PFS, Cert CII (MP), MCSI) - Director

Robert has worked in the fiduciary services industry since 1987 including several years with the Isle of Man income tax

office. He is a member of the Society for Trust and Estate Practitioners the Chartered Insurance Institute, the Personal

Finance Society and the Society of Mortgage Professionals and holds a few other finance related qualifications

including financial planning, investment administration, company and trust administration and pensions.

Catherine Baxter (ACIS) - Director

Catherine is an associate member of the Institute of Chartered Secretaries and Administrators. She has a wealth of

experience in the offshore industry in the Isle of Man and Malta which has also included dealing with the day to day

administration and trusteeship of retirement schemes in Malta, ensuring their compliance with local regulations.

Nicolai Xuereb (TEP BA LL.M. (Lond.) LL.D) - Director

Nicolai graduated as a lawyer from the University of Malta and in 2007 and was awarded a Master’s in Banking and

Finance from University College London. He is also a member of the Society for Trust & Estate Practitioners and has

extensive experience in the formation and administration of trusts and foundations.

Karl Formosa (B.com Hons, DipFA, CSI) - Operations Manager

Karl graduated from the University of Malta and has worked in the Maltese financial services industry since 2005. He

is also a member of the Institute of Financial Services and the Malta Association of Compliance Officers. Karl has

accumulated significant experience working in a senior management capacity with various retirement scheme

administrators and holds several other finance related qualifications including financial planning, investment

administration and pensions.

ARBSSP – V2.0 Page 6 of 14

8. Contributions A Pension Fund may be built up directly by you, your employer or any other person on your behalf, by paying monetary

contributions to the Scheme prior to your retirement. There will be no limit on the value of monetary contributions,

and these may be made either as an ad-hoc contribution or regular contributions. Monetary contributions are not

eligible for a tax credit unless you are a Maltese tax resident.

At the discretion of ICML, you may also contribute by transferring to the Scheme, investments or commercial property

currently held in your name, if such assets conform with the Scheme’s Investment Policy. Upon transfer, these will be

held as an investment within the Scheme. We recommend that you seek professional advice from a suitably qualified

and licensed independent financial adviser before considering a transfer of investments or commercial property to

the Scheme.

9. Transferrable Pensions The Scheme can accept transfers from any eligible pension arrangement you established, even those where you are

already drawing benefits, provided that domestic laws permit such transfers. Transfers of pension arrangements are

usually in the form of a monetary payment but can also be a direct transfer of assets, commonly known as ‘in-specie’

transfers. ICML will consider accepting ‘in-specie’ transfers if such assets conform to the Scheme’s Investment Policy.

Should your circumstances change and if it is in your best interest, you can transfer your Pension Fund out of the

Scheme to any other eligible pension arrangement at any time.

HMRC has been notified that the Scheme meets the conditions to be a ROPS and the Scheme is publicly listed on the

HMRC ROPS list, so a UK Registered Pension is eligible for transfer to the Scheme without incurring an unauthorised

payment and scheme sanction charge. However basic state pensions, annuities or defined benefit schemes in

payment are not eligible for transfer.

ICML does not give advice on whether to transfer and you should seek professional advice from a suitably qualified

and licensed independent financial adviser before arranging such transfers.

10. UK Overseas Transfer Charge On 9th March 2017, UK legislation introduced an ‘Overseas Transfer Charge’ (the “Charge”), which arises on UK

Registered Pension transfers to a ROPS, unless the transfer is excluded from the Charge. The principles of the Charge

rules are as follows:

➢ The Charge will not apply when your UK Registered Pension is transferred to the Scheme and you are a tax

resident in a European Economic Area (“EEA”) country. Otherwise the Charge will apply at a rate of 25% of the

transfer value;

➢ Upon transferring your UK Registered Pension to the Scheme your tax residence will be monitored for a period

of 5 years after the original transfer; and

➢ If the Charge was originally applied to a transfer and during the 5-year period you become an EEA tax resident,

the charge that was previously applied can be reclaimed; or

➢ If the Charge was not originally applied to a transfer because it met the conditions to be exempt, and during the

5-year period you become a non-EEA tax resident, the Charge will be due.

ARBSSP – V2.0 Page 7 of 14

11. Paying Benefits ICML will request you to provide your Intended Retirement Age when applying for Membership to the Scheme so that

ICML has an indication of when you plan to commence drawing Retirement Benefits.

You may elect to commence drawing Benefits by completing the ‘Retirement Benefit Form’. Benefits may be paid to

you or a Beneficiary quarterly, semi-annually or annually, in any preferred currency and to a bank account in any

jurisdiction if this is acceptable by the Scheme’s Bankers.

The Scheme can offer Benefits in the form of Retirement Benefits, Early Retirement Benefits and Death Benefits.

12. Retirement Benefits To the extent that your Pension Fund originates from a transferred UK Registered Pension(s), Retirement Benefit

options shall be consistent with pension income rules provided for under UK legislation, therefore depending on the

source of your Pension Fund, you may elect to draw Retirement Benefits in the following forms once you reach your

Intended Retirement Age:

Pension Commencement Lump Sum (“PCLS”)

Up to 25% of your Pension Fund may be drawn as an ad-hoc PCLS payment or a series of PCLS payments, payable to

you within a twelve-month period. Thereafter no further PCLS will be available.

Entitlement to a PCLS only applies if you have not yet commenced drawing income payments from your Pension Fund

or your Pension Fund originated from a pension arrangement which had not yet paid retirement benefits to you.

Income Payments

Your Pension Fund which is not paid as PCLS shall be used either towards Programmed Withdrawals, to purchase a

Life Annuity or a combination of both, however if your Pension Fund originates from a transferred UK Registered

Pension(s), your remaining Pension Fund can be used to provide Flexi-Access Drawdown, meaning income can be set

at any level required and adjusted according to your circumstances.

Early Retirement Benefits

After obtaining enough medical evidence, ICML may exercise its discretion to immediately pay Early Retirement

Benefits to you prior to attaining Normal Retirement Age on the grounds of Permanent Invalidity. Early Retirement

Benefits may be paid by the same means permitted under the Retirement Benefit rules.

13. Death Benefits You may nominate Beneficiaries when joining the Scheme by completing the ‘Beneficiary Nominations’ section within

the ‘Member Application’. This document will be used to provide guidance to ICML on who you would like to benefit in

the event of your death. The nominations are not legally binding on ICML and they may be altered at any time.

You can nominate a relative or someone unrelated as a Beneficiary and Benefits do not need to be left to just one

person, meaning you can split them in whatever proportion you wish, so each of your nominated Beneficiaries may

receive a share of your Pension Fund. If it is your wish, you may also nominate a charity or trust as a Beneficiary.

Upon your death, ICML shall use its discretion to distribute your Pension Fund according to your wishes. If you are not

survived by any of your nominated Beneficiaries or other dependents, ICML may consider distributing your Pension

Fund to your estate.

ARBSSP – V2.0 Page 8 of 14

14. Taxation of Benefits PCLS payments and Death Benefits are not taxable at source under Maltese legislation so tax will only be paid, if any,

in you or your Beneficiaries country of tax residence.

Subject to an effective Double Taxation Agreement between Malta and your country of tax residence, Income

Payments are also not taxable under Maltese legislation so you will only pay tax, if any, in your country of tax residence.

Where there is no suitable Double Taxation Agreement there will be a withholding tax of up to 35% on Income

Payments.

ICML shall deduct any amount due for taxation from the Benefits payable and shall pay all taxation due by the Scheme

to the relevant authority, prior to making the Benefit payment.

15. Professional Member Status Obtaining a Professional Member status means that it’s possible for you to manage the investments within your

Pension Fund without the need to appoint an Investment Adviser and/or an Investment Manager. To consider such

status, ICML will be required to assess your level of expertise, experience and knowledge to be satisfied that you can

make your own investment decisions and of understanding the risks involved. In the course of the assessment and in

line with Retirement Scheme Law, ICML will also need to ensure that as a minimum you satisfy any two of the following:

➢ You work or have worked in the financial services sector for at least three years in the last ten years, in a

professional position, which requires knowledge of the transactions envisaged;

➢ The size of your Pension Fund exceeds EUR 500 000 or currency equivalent;

➢ You carried out transactions, in significant size, on the relevant market at an average frequency of 10 per quarter

over the previous four quarters.

Should you qualify as a Professional Member, you are still expected to invest your Pension Fund in accordance with

the Scheme’s Investment Policy and ICML shall retain ultimate control to ensure your Pension Fund remains in line

with the objective of the Scheme.

16. Investment Policy ICML seeks to ensure that you are aware of the nature of your selected investments and the risks associated with

them and unless you classify as a Professional Member, ICML requires you to appoint an Investment Adviser to advise

and/or an Investment Manager to manage the investments within your Pension Fund.

To enable ICML to assess the appropriateness of your selected investments, you are requested to provide your

Intended Retirement Age and your attitude towards risk when applying to join the Scheme. It is important that you

ensure ICML remains informed of any changes to this information so that ICML may consider them when assessing

new investment proposals.

Your appointed Investment Adviser and/or Investment Manager should carry out investment reviews and risk

assessments with you on a regular basis to make certain that the chosen investments remain in line with the Scheme’s

Investment Policy and that the chosen investments continue to meet your retirement objectives and attitude towards

risk.

The Investment Policy of the Scheme will be kept up-to-date and shall be reviewed at least every three years or as

necessity dictates.

ARBSSP – V2.0 Page 9 of 14

Investment Objective

ICML’s investment objective is to accumulate a Pension Fund from which to provide you with Benefits at your Intended

Retirement Age. Investments made on your behalf must always maintain your best interests , specifically this means

that your Pension Fund should:

➢ be invested in a prudent manner, in accordance with your attitude towards risk;

➢ be adequately diversified to avoid accumulation of risk within your Pension Fund; and

➢ have sufficient liquidity at any point in time.

Notwithstanding that it is your responsibility, in conjunction with your appointed Investment Adviser and/or

Investment Manager, to ensure the objectives set out above are met, where ICML is not satisfied that any proposed

investment meets these objectives, it may disallow such investment proposals.

The formulation of any investment strategy shall always take consideration of the need to have enough liquid funds

to pay Benefits and any investment restrictions in accordance with Retirement Scheme Law.

Investment Options

The Scheme can hold a wide range of investments, including the purchase of commercial property. Your selected

investments may be held as direct investments or consolidated via a variety of permitted Life Assurance Bonds or

Investment Platforms, which offer access to an extensive range of assets that will enable you to build a bespoke

solution in any major currency.

You should not propose ICML to consider your selected investments without first being made fully aware of all the

initial and ongoing costs associated with the investments, these could include charges related to advice, the

Investment Portfolio and the chosen underlying investments. In case of any doubt you are to contact your Investment

Adviser and/or Investment Manager in the first instance or ICML.

Investment Guidelines

ICML maintains a published set of Investment Guidelines as set out below, which you and your Investment Adviser

and/or Investment Manager are required to adhere to. ICML may alter the Investment Guidelines from time to time,

however when it does so, it may not seek to alter your existing investment strategy retrospectively. The current

Investment Guidelines require that:

➢ Unless you classify as a Professional Member, your Pension Fund may only be allocated to investments which

ICML considers suitable for retail investors;

➢ Where applicable, your Pension Fund should be allocated to investments which are managed by appropriately

licensed and regulated investment companies;

➢ Up to 75% of your Pension Fund may be allocated to investments with a liquidity profile greater than 6 months;

and

➢ Up to 30% of your Pension Fund may be allocated to structured notes and not more than 20% of your Pension

Fund may be allocated to any one structured note. ICML shall only consider structured notes issued by reputable

institutions.

The above restrictions are intended to solely act as a guideline, the overall size of your Pension Fund and over exposure

to any single sector or region may also be considered.

ICML recognises that each Member’s circumstance is different and where you wish to allocate investments outside of

the Investment Guidelines, you should seek prior approval from ICML and support the proposal with a comprehensive

explanation.

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Investment Restrictions

There are certain investments which ICML will not approve in accordance with Retirement Scheme Law. These include:

➢ assets that have a limited life and loses value over its life;

➢ assets that are not traded in regulated markets;

➢ residential property of a Member or a Connected Person;

➢ high value movable property such as antiques, works of art, jewellery and other luxury items;

➢ private funds or equity where a Member or a Connected Person holds an interest;

➢ loans to Members or any Connected Person; and

➢ derivative products other than structured notes.

The above list is not exhaustive and ICML retains the right to review and decline certain investment proposals if they

are deemed inappropriate.

Investment Instructions

You have a right to timely and fair execution of your selected investment however the responsibility to execute your

selected investments should not be inhibited by the assessment of any unreasonable costs or charges.

Where you choose to appoint an Investment Adviser, ICML will require a written request from you and evidence from

your Investment Adviser that you have been provided with an information sheet disclosing all costs and charges

payable under the terms of the selected investments, before executing your investment decision.

If you choose to appoint an Investment Manager, ICML may accept a written request from them, on your behalf

however your Investment Manager may also manage the investments within your Pension Fund on a discretionary

basis, which means that investments may be bought and sold at their discretion and without the need to obtain ICML’s

prior approval.

Should you classify as a Professional Member, ICML may grant you direct access for you to manage the investments

within your Pension Fund on a discretionary basis.

Whilst it remains the responsibility of you and your Investment Adviser and/or Investment Manager to ensure that

any changes to the investments are in line with the latest version of the Investment Guidelines then in force, ICML has

an overriding right to refuse a selected investment, or to disinvest, where it believes that a particular investment

proposal may not be consistent with the Scheme’s Investment Policy or any investment restriction applicable under

Retirement Scheme Law.

Investment Performance

ICML does not impose any criteria against which the Scheme’s investment performance will be benchmarked;

however, ICML will periodically review the Scheme’s underlying assets to monitor performance and manage risk.

Valuation of Investments

As a rule, all the Scheme’s underlying assets shall be valued based on International Financial Reporting Standards,

subject to compliance with any other specific requirements in accordance with Retirement Scheme Law.

ARBSSP – V2.0 Page 11 of 14

17. Risk Factors It is important that you understand and consider the risks arising from your Membership and the impact it may have

on your financial status.

The assessment of risk can be subjective and vary from person to person. It is important for you to understand fully

the level of risk being undertaken; a lack of understanding of tolerance and attitude towards risk could result in

unsuitable choices being made, potentially losing capital value and receiving reduced Benefits.

Risks related to investments

➢ You are expected to receive suitable investment recommendations from your Investment Adviser and/or

Investment Manager and ICML’s responsibility to administer the Scheme does not extend to the provision of any

investment advice. It is limited to ensuring such investments are made in accordance with the Schemes’

Investment Policy and any applicable investment restrictions at Retirement Scheme Law.

➢ The value of investments may go up or down and past performance shall not necessarily be a guide to future

performance.

➢ The chosen Investment Portfolio will give you access to a wide variety of investments which all have specific

objectives and carry varying degrees of risks.

➢ If the overall investments do not match your attitude towards risk, they may not perform as anticipated.

➢ Some investments can take longer to sell than others, and ICML may not be able to redeem them at your desired

time of need. It is important that you obtain a clear understanding of the nature of the chosen investments from

your Financial Adviser.

➢ Where investments are held in a currency different to the one in which the Investment Portfolio is denominated,

there may be additional risks because of exchange rate fluctuations.

➢ External national or global factors can affect the value of investments. They include political, economic and social

factors and the actions of governments and other entities.

➢ Frequent dealing in small amounts may result in higher costs and a reduction in the value of the investments.

General risks

➢ Legislation and taxation may change from time to time and this may affect the amount of Benefits that you or a

Beneficiary may receive.

➢ The importance of the Scheme in terms of reliance on the Benefits it generates will depend on your financial

circumstances.

➢ Depending on your tax residence, any Income drawn may be taxed. If you take high Income Payment within a tax

year, you may end up paying a higher rate of tax than usual.

➢ Large Retirement Benefit payments may not be sustainable throughout your life and your Pension Fund may be

exhausted before your death. Your life span and the investment performance of your Pension Fund are

impossible to predict, and this could result in lower future Retirement Benefit payments than anticipated.

This is not an exhaustive list of the risks you may be exposed to and it is the responsibility of your Financial Adviser to

ensure all the relevant risks are well-known to you.

ARBSSP – V2.0 Page 12 of 14

18. Banking The Scheme shall hold your Pension Fund within the Scheme’s non-interest-bearing account with Royal Bank of

Scotland International until the money is invested, paid out as Benefits or used to pay fees. ICML is listed as the sole

signatory of the account.

19. Annual Reporting Obligations The Scheme’s account period runs from 1st January to 31st December. In compliance with Maltese regulations, ICML

shall provide the Regulator with annual audited financial statements as at the years ending 31st December.

You will be provided with an annual statement which will show the value of your Pension Fund as at the 31st December.

Upon request, bespoke valuation reports of your Pension Fund will also be available at any point in time, free of charge.

20. Tax Reporting Obligations Upon Membership, ICML is required to register you with the Maltese Tax Authority and thereafter ICML will complete

an annual tax return on your behalf and submit directly to the Maltese Inland Revenue Department.

In accordance with HMRC rules, should you transfer a UK Registered Pension(s) to the Scheme, ICML has an obligation

to report to HMRC whenever PCLS is paid, Income Payments commence, Death Benefits are distributed and when

your Pension Fund is transferred out to another eligible pension arrangement. HMRC requires ICML to report the

above payments if you are UK tax resident or where the above payments are made within 10 years from when you

transferred your UK Registered Pension(s) to the Scheme, regardless of where you are resident.

You are responsible for obtaining the necessary tax advice to verify what reporting obligations you may have in respect

of reporting Benefits received from the Scheme to the relevant authorities in your tax residence.

21. Conflicts of Interest Potential conflicts of interest may occur if you are or become employed by or obtain a stake holding with any company

or individual of ICML, service provider or auditor of the Scheme. Every effort is made to avoid conflicts of interest by

investing in assets that have no connection with the Scheme or ICML. However should ICML have a direct or indirect

interest in the result of a decision or in the exercise of the power or discretion, ICML shall arrange for your Pension

Fund to be invested in your best interest and, in the event of any potential conflict of interest in that regard, ICML shall

ensure that investment activity is carried out in you or your Beneficiaries sole interest.

22. Compensation There is no statutory provision for compensation towards Members of the Scheme in the case where the Scheme is

unable to satisfy the liabilities attributable to it and ICML or any of its associated companies shall not be held

responsible for compensation in such an event. The registration of the Scheme is not an endorsement by the

Regulator of the Scheme’s financial performance and the Regulator shall not be liable for the performance or default

of the Scheme.

ARBSSP – V2.0 Page 13 of 14

23. Termination of the Scheme ICML, subject to obtaining the prior written approval from the Regulator, may elect to wind up the Scheme at a certain

date if it determines for any reason that the Scheme should be wound up. On termination, ICML will reserve out of

your Pension Fund such amount for the payment of any outstanding fees and then use the remaining balance to be

transferred to another eligible registered pension arrangement or by any other means permitted by the Regulator.

24. Cost of Membership The Scheme offers you four standard levels of membership which are all structured to be transparent and economical.

Each level of membership offers excellent investment options, flexibility and great value for money and your fee

structure will be determined by your chosen investment strategy and the size of your initial contribution, as follows:

Setup Fees

Membership Level Lite Plus Plus One Pro

Chosen investment strategy Managed

Portfolio Service

Other

Investments

Other

Investments

Commercial

Property

Minimum initial contribution £30,000 £40,000 £120,001 £250,000

Maximum initial contribution No Limit £120,000 No Limit No Limit

Establishment fee £300 £400 £700 £1,200

Annual administration fee £300 £400 £700 £1,200

Exit Fees

Membership Level Lite Plus Plus One Pro

Death claim processing fee £300 £400 £700 £1,200

Standard transfer out fee £300 £400 £700 £1,200

Transfer to a UK Registered Pension Nil Nil Nil Nil

Third party charges such as advisory fees, investment wrapper charges and charges related to your chosen

investments are additional to the Scheme’s standard fees.

Please refer to the ‘Fee Schedule’ for additional information on the charges related to the Scheme, this is accessible

online under the ‘Literature’ section of the Scheme’s website.

25. Get in Touch Should you have any queries regarding the Scheme, please get in touch by using the contact details listed on the back

page of this document, we will be delighted to assist you.

Integrated-Capabilities (Malta) Ltd

Telephone: +356 2247 8888

Fax: +356 2122 6615

Email: info@azurepensions.com

Web: www.azurepensions.com

Mailing Address: 45/15, Strait Street, Valletta, VLT 1434, Malta, EU

Registered Office: 45/13, Strait Street, Valletta, VLT 1434, Malta, EU

Registration number: C 50348

Directors: C Baxter, N Xuereb , P K Perry, R A Cannell, A M Dawson

Integrated-Capabilities (Malta) Ltd is licensed by the Malta Financial Services Authority to act as a trustee, provide fiduciary services

and to act as an Administrator of private foundations in terms of Article 43 of the Trust and Trustees Act; and Retirement Scheme

Administrator to Retirement Schemes registered under the Retirement Pensions Act, 2011, registration pursuant to article 6(1) of the

Retirement Pensions Act 2011.