Northwind Fiduciary Limited

Do not structure arrangements or refrain from action to evade TCB Code responsibilities or their legal consequences.

Discharge undertaken responsibilities with due skill, care and diligence.

Exercise powers and discretions only for a proper purpose and evidence every decision in writing.

Avoid conflicts of interest where possible; where they arise, record and address them by disclosure, information barriers, declining to act, or otherwise.

Delegate duties or powers only to appropriate persons and only for a proper purpose, with monitoring and due diligence.

Implement procedures for detailed, periodic reviews of all trust and company services provided to customers.

Maintain a regulatory span of control of at least three appropriately skilled and experienced individuals where the firm controls TCB assets.

Subject corporate governance arrangements to regular review, including periodic self- or external assessment of board effectiveness.

Operate robust arrangements covering documented policies, a Compliance Officer, complaints handling, supervision of employees, authorisation controls on assets, and decision authorisation by appropriately experienced persons.

Maintain and periodically test business resumption, disaster recovery and contingency arrangements.

Comply with all relevant AML/CFT/CPF legislation, guidance and the JFSC AML/CFT/CPF Handbook.

Comply with the current JFSC outsourcing policy, including notification requirements.

Where customer money is held, perform an annual independent review of controls preventing loss, misuse or misappropriation of customer money.

Ensure all directors, partners, senior managers and employees are fit and proper for their roles on appointment and on an ongoing basis.

Maintain at all times the JFSC competency thresholds: 75% of Category A TCB employees suitably qualified, and 75% of Category A and B combined suitably qualified.

Ensure Category A/B TCB employees complete at least 25 hours CPD per year and Category C employees at least 15 hours, of which no more than five may be relevant reading.

Senior management must approve a compliance policy, establish a permanent compliance function, assess compliance-risk management at least annually, and appoint a skilled Compliance Officer.

Appoint a Jersey-based Compliance Officer employed by the firm (or a group company) with appropriate qualifications, status and authority.

Operate an effective complaints-handling system: central register, transparent customer information, fair handling, written acknowledgement within five business days.

Notify the JFSC promptly in writing when a complaint is unresolved after three months, a complaint pattern emerges, or a complaint triggers a PII claim.

Retain business records for the longer of any statutory period, the AML/CFT/CPF Handbook period, or ten years for governance and Code-related records.

Disclose JFSC regulated status on all stationery and advertising material.

Communicate with customers in a way that is adequate, fair and not misleading.

Agree and document the basis for fees and charges before taking an appointment, and disclose all fees, commissions and third-party payments openly.

Provide each customer with a written services confirmation and a contract or agreement setting out the general and specific terms of the services.

Maintain at least £25,000 paid-up share capital (or evidenced net assets), a £25,000 minimum net-assets position, and an ANLA surplus of at least 110% of the Expenditure Requirement.

Perform the ANLA calculation at least quarterly, increasing to monthly (or as the JFSC determines) if ANLA falls below 130% of the Expenditure Requirement or a material adverse event occurs.

Immediately notify the JFSC in writing if ANLA falls below 130% or 110% of the Expenditure Requirement, or where the Second Schedule may misrepresent the firm's resources.

Maintain adequate PII cover (extended to fidelity guarantee and D&O) at all times, commensurate with business activities.

Maintain PII indemnity (per claim and aggregate) of at least the greater of 3× relevant fees and commissions, 30× the largest customer's fees, or £5 million.