The Custody Agent has entered into an agreement with IBIE whereby the Custody Agent has arranged for IBIE to provide safe custody, administration and other associated services for clients. The Custody Agent entered the agreement as your agent and so there is a direct relationship between you and IBIE. Upon entering into the IBIE Client Agreement, by signing the declaration, you are legally bound by the Custody Terms and become a client of IBIE in relation to the services provided under those Terms. IBIE will be responsible for complying with the regulatory requirements relating to the Custody Terms and will treat you as a retail client giving you the highest level of regulatory protection available. The Custody Agent will retain regulatory responsibility for all other aspects of the services provided to you including the provision of execution of any trades carried out on your behalf.

IBIE is authorised and regulated by the Central Bank of Ireland (CBI). IBIE Firm Reference Number is CBI00423427. You can find more detailed information on IBIE regulatory status on the CBI Register which is accessible at https://registers.centralbank.ie/FirmSearchPage.aspx.

IBIE may send you statements and email communication. All communications will be in English.

As your Custodian IBIE is obligated to provide you with a periodic Custody Statement of the investments and money that they hold for you. IBIE will provide this at least once a month, accessible via your online portal.

The Custody Agent charges you a fee which incorporates the services provided by IBIE. All fees from the Custody Agent and IBIE can be found in the appendix of your ACM Europe Limited Client Agreement.

If IBIE fail and cannot return your money or assets, you may be eligible to claim compensation under The Investor Compensation Company (“ICCL”) depending on your individual circumstances. The current coverage limit is:
• 90% of the loss up to €20,000
• Maximum payout: €20,000
Full details of the arrangements under the ICCL are available on their website at www.investorcompensation.ie.

In the event that you owe a debt to IBIE in relation to services IBIE has provided under the Custody Terms, IBIE may use any of the money held for you to pay off or reduce that debt.

Contractual Settlement is a tool that facilitates cash and liquidity management for the investor. For sales, IBIE will move cash into your Account and move the securities out of your Account on the day you are meant to settle your transactions, regardless of what may have actually happened with the broker or fund manager. We will do the opposite for purchases.

This process insulates you from the securities settlement process and simplifies the money movement processes. In rare cases, these postings may need to be reversed because of an unusual market event. If that did occur your broker will be notified by IBIE.

IBIE is responsible for the holding the Assets within your account in safe custody. Your Assets are held in the name of Interactive Brokers Ireland (Nominee) Limited on behalf of you as a user of the platform and having appointed the Custody Agent as your Agent. In some cases, positions are custodied through Interactive Brokers LLC, the US affiliate.

Interactive Brokers Ireland (Nominee) Limited is used to assist in ensuring all Customer Assets are segregated from the assets of IBIE. Interactive Brokers Ireland (Nominee) Limited is a Nominee Company which is used by IBIE as it has no material liabilities and is a separate entity from IBIE. Therefore, your assets would not be available to an administrator or liquidator of IBIE, or its parent company, in the event that bankruptcy proceedings against IBIE should ever occur.

IBIE may use a number of third party custodians (also known as sub-custodians) to administer and hold some of your Assets.

IBIE will be responsible for exercising reasonable care and due diligence in the initial selection and on-going monitoring of the sub-custodians but will not be responsible for any acts, omissions or failure of the sub-custodians.

In certain circumstances, IBIE may select a sub- custodian outside of Ireland where deemed prudent to do so. In such circumstances, it is important to note that such sub-custodians will be subject to a different legal and regulatory regime from that of Ireland and the rights and protections afforded to you under the ICCL rules may not be available to you. For example, there may be different practices for the separate identification of your assets which may result in them being subject to third party claims in the event of the failure of the sub-custodian.

All custody accounts are operated in accordance with the applicable Ireland rules. Under these rules, IBIE is required, amongst other things, to make adequate arrangements to safeguard your ownership rights and to prevent the use of your Assets for IBIE’s own account.

In the event that IBIE is unable to meet any of its liabilities, compensation may be available to you under The Investor Compensation Company (“ICCL”). The current compensation limit in relation to investment business is €20,000 per eligible claimant. Full details of the arrangements under the ICCL are available as outlined above.

Please find the IBIE policy here.