Jarvis Terms

Pension Jar Limited, trading style Pension Jar, is a company registered in England and Wales under company number 14344139 with registered office at 80 Cheapside, London, EC2V 6EE Jarvis® is a trading style of Pension Jar Limited (FCA Registration: 984773) an Appointed Representative of P1 Investment Services Limited, which is authorised and regulated by the Financial Conduct Authority (FCA Registration: 752005). P1 Investment Services Limited is registered in England and Wales. Number: 12431555. Registered office: C/O Prydis Senate Court, Southernhay Gardens, Exeter, Devon, England, EX1 1NT.

Pension Jar will offer full access to its Jarvis® proposition via its Self Invested Pension Plan (SIPP), an algorithm designed as a dynamic framework for users to unlock paths to financial freedom.

Jarvis does not provide pensions, investment, financial, legal, or taxation advice or any recommendations in relation to the Jarvis SIPP (as defined below). Nothing in these terms & conditions or any other documents or communications with Us (written or oral) should be taken to constitute pensions, investment, financial, legal, or taxation advice.

Your Jarvis SIPP is a vehicle through which You can consolidate your existing qualifying pension arrangements. We are in the process of building our drawdown function which will be soon part of our pension proposition. In the interim, Your Jarvis SIPP is not a vehicle through which You can access Your pension savings (e.g. in the form of drawdown, taking a lump sum or drawing a regular pension). When You wish to access Your pension, You will need to transfer Your benefits to a suitable arrangement which meets Your requirements.

Any investments provided through the Jarvis SIPP can go down in value as well as up and Jarvis is not liable for any losses You incur (including but not limited to any taxation liabilities).

These Terms & Conditions together with the other documents specified in clause 1 below create a legally binding agreement between You and Us. Please read these documents and the relevant SIPP fact sheets and disclosure documents carefully and ensure that you understand them. For your own benefit and protection, You should consider taking independent financial, investment and/or legal advice. If You do not agree with any of the terms set out in the aforementioned documents, You should not use Our Services.


“SECCL Custody” – Seccl Technology Limited is a company registered in England and Wales at 20 Manvers St, Bath, BA1 1JW (Number: 10237930). Seccl Custody Limited, a wholly owned subsidiary of Seccl Technology Limited, is registered in England and Wales (Number: 10430958), and authorised and regulated by the Financial Conduct Authority (Firm Reference Number: 793200) or such other provider as We may nominate from time to time.

“Agreement” – the three documents comprising Jarvis Terms & Conditions, Fees Guide and the Jarvis SIPP Terms and Conditions.

“Annual Fee” – this is comprised of a Platform Fee and Fund Charge. The annual Jarvis Platform Fee is 0.75% for the first £75,000 of assets, reducing to 0.35% thereafter and our current Vanguard and Legal & General fund range has an annual charge of 0.20% to 0.22% of the total assets in Your Jarvis SIPP. This charge is subject to change. We will notify You sufficiently in advance of any change.

“App” – the Jarvis mobile application which You download onto Your iOS/Android smartphone. “Assets” – any Investments or cash held in Your Jarvis SIPP.

“Business Day”- any day which a bank in the UK would normally be open for business but not including a Saturday, Sunday or any public holiday.

“Cash” – to include funds paid as electronic payment but not physical cash and notes.

“Client” – “You”, “Your” and “Yourself.”

“Client Reference” – the unique reference given to You when you open a Jarvis account.

“Collective Investment scheme” – a Unit trust, OEIC or recognised scheme as defined in the FCA rules.

“Contribution” – any Cash payment into Your Jarvis SIPP.

“Corporate Action” – any actions such as takeover, rights issues, mergers and conversion that would have an effect on Your Jarvis SIPP.

“Custodian” – SECCL Custody Limited and/or such other FCA registered custodian as We may appoint from time to time.

“Custody Terms”: means the terms outlined in Schedule 1.

“ETI” – Exchange Traded Instruments.

“FCA” – The Financial Conduct Authority at 12 Endeavour Square, London E20 1JN.

“FCA Rules” – The Rules and guidance given to the UK financial services industry as amended from time to time.

“Fees Guide” – the document entitled “Fee Guide” as amended from time to time, also available in Our App.

“Fees” – the Annual Fee and any other fees applicable (see the Fees Guide). “Finance Act” – is The Finance Act 2004 as amended and enacted from time to time.

“Force Majeure” – means any circumstance not within a Party’s reasonable control including, without limitation:

  1. acts of God, flood, drought, earthquake or other natural disaster;
  2. epidemic or pandemic;
  3. nuclear, chemical or biological contamination or sonic boom;
  4. nuclear, chemical or biological contamination or sonic boom; or
  5. interruption or failure of utility services.

“FSMA” – The Financial Services and Markets Act 2000, as amended and enacted from time to time.

“Fund” – the Fund into which the assets transferred from Your Qualifying Pension Arrangements are invested, together with any Contributions paid by You.

“Fund Provider” – the manager or distributor of Your Fund. “SCL” – the Scheme Administrator and the Scheme Trustee

“HMRC” – Her Majesty’s Revenue and Customs.

“Investment” – a bond, share or other financial product also including units in funds or as otherwise stated.

“Key Facts” – the description in the Regulatory Requirements which sets out the high level aims and particular features of Your Jarvis SIPP, as amended from time to time.

“Key Information Document” – as described in the PRIIPs regulation (Regulation (EU) No 1286/2014 of the European Parliament and of the Council).

“Key Investor Information Document” – is the Key investment information document or equivalent document for a fund.

“Natural Person Identifier” – Your UK National Insurance Number.

“Nominee” – means a firm appointed by Us in whose name investments made under Your Jarvis SIPP will be registered.

“Normal Minimum Pension Age” – is as defined in the Finance Act (currently age 55, increasing to age 57 on April 2028 and subject to further legislative and/or regulatory change)

“OEIC” – means an open ended investment company.

“SmartSearch” – SmartCredit Limited is authorised and regulated by the Financial Conduct Authority (FCA FRN 986139), who conduct identity verification services on behalf of Jarvis.

“Order” – are the instructions received to execute a purchases, transfers, sales or any such other transactions, confirmed by You, in a Permitted Investment for Your Jarvis SIPP.

“Parties” – to include all or any of the Parties to this Agreement, that work either on Our behalf or Your behalf as Your agent.

“Partner(s)” – SCL Custody Limited or any other such firms as we may appoint in respect of Your Jarvis SIPP either on Our behalf or Your behalf as Your agent.

“Permitted Investments” – this is the range of investments for which You can place an order through Your Jarvis SIPP.

“Jarvis” –Jarvis is the trading name of Pension Jar Limited, a company registered in England and Wales under company number 14344139 with registered office at 80 Cheapside, London, EC2V 6EE, authorised and regulated by the Financial Conduct Authority (FCA Registration: 984773). “We”, “Us”, “Our” and “Ourselves”.

“Jarvis SIPP” – a SIPP account and the entitlements you have under the Jarvis SIPP and from which Your benefits are provided.

“Jarvis SIPP Benefits” – what may be paid to You or Your assigns through Your Jarvis SIPP.

“Personal Representatives” – a person who has obtained probate, confirmation or letters of administration on Your death (or such individuals who We are reasonably satisfied are legitimate persons for Us to take instruction from in relation to Your estate; this if no person has applied for probate, confirmations or letters of administration).

“PRIIP” – a packaged retail and insurance-based investment product including certain regulated investments Schemes, structured investment products, alternative investment funds that are not exempt Collective Investment Schemes (as defined in FSMA) and debt securities as amended and enacted from time to time.

“Privacy Policy” – Our policy which is available to view online and covers Your personal data rights and confidentiality as amended from time to time.

“Qualifying Pension Arrangements” – Your defined contribution occupational and personal pension arrangement that are registered with HMRC which are eligible to be transferred to you Jarvis SIPP Account.

“Reclaim Period” – 30 days.

“Registered Pension Scheme” – A registered Pension Scheme under the Finance Act.

“Regulatory Requirements” – any obligation that We or any other relevant person has to comply with under any law or regulation which is relevant to the content of this agreement as amended and enacted from time to time, in particular the Finance Act and FSMA.

“The Jarvis SIPP” – a Registered Pension Scheme established by Master Trust Deed and Rules dated 26 January 2021 as amended from time to time known as the SCL Personal Pension Plan.

“SIPP Administrator” – Seccl Custody Limited or such other SIPP administrator as We may appoint from time to time.

“SIPP Trustee” – Digital Pension Trustees Limited or such other SIPP trustee as We may appoint from time to time. “Jarvis SIPP Terms and Conditions” – Schedule 2 entitled “Jarvis SIPP Terms”, available in this document and Our App as amended from time to time.

“Security Details” – passwords, security, security questions and answers and personal identification numbers and account numbers.

“SIPP Account” – Your Self-Invested Personal Pension account or any other arrangement which is under a Registered Pension Scheme.

“Services” – the services We and Our Partners provide to You under the Agreement. “Taxation of Pensions Act” – the Taxation of Pensions Act 2014 Act as amended, re-enacted or replaced from time to time.

“Tax Year” – from the 6th April in any Year.

“Terms” – the document entitled “Jarvis Terms”, (i.e. this document) as amended from time to time (also available in Our App).

“Tools” – the tools in the App which We provide so that You may receive information through them.

“UCITS” – a Scheme structure as an undertaking for a collective investment in transferable securities.

“Unit” – a share or unit in a fund.

  1. Our Agreement with You
    1. Our Agreement with You consists of:
      1. Our Terms;
      2. the SIPP Terms and Conditions;
      3. the Key Features Document; and
      4. the Fees Guide
  1. Overview of Our Service
    1. We provide You with a Self-Invested Personal Pension (SIPP) via Your Jarvis SIPP.
    2. We bring together all the necessary Partners to make the Jarvis SIPP work.
    3. We relay Your communications with the Jarvis SIPP Administrator to You.
    4. We relay your Orders for investment to the Custodian.
    5. We also provide to You, as part of Our Services, details of Your Jarvis SIPP. Such information includes;
      1. the value of Your Jarvis SIPP;
      2. the total value of Your contributions to Your Jarvis SIPP;
      3. the details of the current investments in Your Jarvis SIPP; and
      4. details of any workplace pensions You can locate or We can locate.
  2. Where possible, We will update the information stated in (i) to (iii) above on a daily basis although it may not be possible to always do this due to elements that our beyond Our reasonable control.
    1. We do not provide You with financial advice. Our Services are execution only.
    2. We do not hold Your cash. Your cash is held by the Custodian in their client money account, in line with CASS (see clause 3).
  3. Your Jarvis SIPP
    1. The type of account We offer to You is a SIPP Account, and we offer this to you through Our App;
    2. We provide Tools, through Our App, which enable You to make Your own choices as to how much cash You contribute into Your Jarvis SIPP.
    3. We advise that You speak to a lawyer, accountant or any other qualified financial advisor who specifically deals in SIPPs for such financial advice as You may require.
  4. The Jarvis SIPP
    1. By agreeing to Our Terms, You are also agreeing to the Jarvis SIPP Terms and Conditions – Schedule 2.
    2. When We open a Jarvis SIPP for You, You become a member of the scheme.
    3. The Scheme is registered with HMRC and provides pension benefits for You and death benefits to such of your dependants as may be determined by the Scheme Administrator (note that You may indicate your preferred beneficiaries through signing an expression of wish form which you should review and, if necessary, update from time to time.
    4. The Scheme Administrator is Seccl Custody Limited or any successor that maybe appointed from time to time who is the appointed administrator of The Jarvis SIPP
    5. The Scheme Trustee of the Jarvis SIPP is Digital Pension Trustees Limited.
    6. The Scheme is governed by the Jarvis SIPP Terms and Conditions and such rules may be amended or varied from time to time.
    7. You can view the Jarvis SIPP Terms and Conditions, in Our App (go to Settings, then Documents).
    8. In the future, We may decide to change The Jarvis SIPP to a new Registered Pension Scheme. You authorise and instruct Us to instruct Our Partners and You also authorise and instruct Our Partners to give effect to Our instructions, to transfer the contributions and Investments held in Your Jarvis SIPP to the new registered pension Scheme. We will provide You with details of any new Registered Pension Scheme and the transfer process ahead of any such move. Jarvis will send an informational only notice to users in the event of a bill transfer
  5. The Custodian
    1. Jarvis and the Scheme Administrator have appointed the Custodian.
      1. By agreeing to Our Terms, You are also agreeing to the Custody Terms (included in this document – Schedule 1).
      2. The Custodian will provide:
        1. custody of Your Cash;
        2. client monies and asset reconciliation in accordance with the Client Asset Sourcebook (“CASS”); and
        3. a cash payment service, asset price and information.
  1. Pension Locator Service
    1. When You sign up to Jarvis, We ask you to provide information about Yourself (such as Your name and date of birth). We use this information to locate Your pension arrangements on Your behalf in order to determine which are Qualifying Pension Arrangements (the “Pension Finding Service”).
    2. By signing up to Jarvis, you authorise Jarvis to:
      1. perform a “soft” credit check in order to ascertain key information, such as Your former names and addresses and other information to assist Us with locating Your Qualifying Pension Arrangements;
      2. search for Your pension arrangements which are in existence at the date on which You sign up to Our Terms and to transfer Qualifying Pension Arrangements to Your Jarvis SIPP. We may (but are not obligated to) transfer other Qualifying Pension Arrangements to Your Jarvis SIPP after this date if You instruct Us to;
      3. search for and transfer Qualifying Pension Arrangements with Jarvis’ supported pension providers. This includes but is not limited to: Aegon SE, SCL Personal Pension, Aviva, Creative Pension Trust, Clerical Medical, Fidelity, Hargreaves Lansdown, Legal & General, Moneybox, NEST, NOW Pension, Pensionbee, People’s Pension, Phoenix, Prudential, Reassure, Royal London, Scottish Friendly, Scottish Widows, Smart Pension, Standard Life, and True Potential;
      4. communicate with the providers and/or trustees of Your existing pensions in your place to obtain relevant information from about Your pensions. Additionally, by signing up to Jarvis, You grant Pension Jar Limited power of attorney for the sole purpose of locating Your pensions and transferring Qualifying Pension Arrangements to Your Jarvis SIPP; and
      5. communicate with Your previous employers to obtain relevant information about Your pensions. You authorise Jarvis to share Your personal information with your previous employer in order to assist with the pensions search.
    3. To locate Your pensions, Jarvis will communicate on Your behalf with the providers and/or trustees of Your existing pensions arrangements. To communicate with the pension providers, Jarvis may use one or multiple methods of communication, including but not limited to those listed below:
      1. Letters of Authority (LOA): This will be a standard LOA which contains an electronic or physical (wet ink) copy of your signature. You authorise and agree to Jarvis generating and using a wet ink copy of Your signature on Your behalf;
      2. activating/registering Your online pension account with Your pension provider;
      3. emails;
      4. phone calls; and
      5. physical post.
    4. By authorising Us to search for Your pension arrangements and agreeing to use Our Pension Locator Service to do so, You agree to allow Us to use Your personal information (including but not limited to Your personal data and any approved form of Your signature that You provide us) to identify You to Your existing pension providers and to any other person or organisation who may be able to assist Us in locating Your pension arrangements, if they so request.
    5. In order to locate Your pension arrangements, We will use a standard letter of authority which You agree to sign. This will confirm to the pension provider or any other person or organisation who may be able to assist Us in locating Your pension arrangement Your authority for Us to act on Your behalf if they so request.
    6. You agree to cooperate with Us to complete the necessary requirements in order to transfer Your Qualifying Pension Arrangements to Your Jarvis SIPP mandated by the Your existing pension providers. This may include (but is not limited to) signing consent forms and providing confirmation that You are happy for the transfers to proceed.
    7. We do not promise that We will be able to locate and/or transfer any or all of Your pension arrangement. Also, we are unable to guarantee the accuracy of information from third parties provided in relation to Your existing pension arrangements. We do not accept liability for any default or mistakes by any third party who has provided Us information about Your pensions or resulting mistakes or inaccuracies.
    8. In order to comply with Regulatory Requirements, We will restrict our answers to questions from third parties for the purposes of Our Pension Locator Service to information that You have provided to Us. We are not able to advise You on Your investment decisions, the suitability of transferring Your pension arrangements or whether You should proceed with Jarvis. We recommend that You seek advice from an independent financial advisor in relation to Your pension arrangements and any related regulatory, legal, tax or investment matters.
  2. Consolidating Your Qualifying Pension Arrangements
    1. When We have located Your Qualifying Pension Arrangements, We will contact the pension providers and advise them that You wish to transfer Your pension benefits to Your Jarvis SIPP.
    2. If We do not receive a response from the relevant provider, We will contact them again. You understand that We cannot compel any provider to communicate with Us and that any delays in the correspondence process will delay the investment of monies into Your Jarvis SIPP.
    3. We shall not be liable for any delays in the transfer process.
    4. Before the Qualifying Pension Arrangement provider can transfer Your benefits into Your Jarvis SIPP Account, You may need to provide Us or them with additional information and You agree to provide this.
    5. You are responsible for paying any and all exit fees connected with the transfer of benefits from Your Qualifying Pension Arrangements to Your Jarvis SIPP.
    6. You are responsible for being aware of any non-standard features associated with Your Qualifying Pension Arrangements, including but not limited to, protected retirement ages, defined benefit underpins, life assurance benefits, guaranteed benefits and guaranteed annuity rates. You are aware that any such benefits will be lost if Your benefits are transferred to your Jarvis SIPP Account.
    7. We will transfer ALL the accrued pension benefits from Your Qualifying Pension Arrangements that We are able to locate into Your Jarvis SIPP Account without further recourse to You except that We will not transfer accrued benefits in a Qualifying Pension Plan to Your Jarvis SIPP if You or Your employer are actively making contributions into the Qualifying Pension Plan.
    8. If You or Your employer are not actively making contributions into the Qualifying Pension Plan, but the Provider of the Qualifying Pension Plan has not received notice that the plan is paid-up/will not receive further contributions, You instruct Jarvis to request that the provider updates their records to show that the Qualifying Pension Plan is paid-up and that You are a deferred rather than an active member.
  3. The Services We Do Not Provide
    1. We do not:
      1. give any advice on any pension arrangement or financial matter, whatsoever, to You.
      2. Hold any cash deposits, however the Jarvis SIPP Administrator does hold client money.
  4. Opening Your Jarvis SIPP
    1. It is entirely Your decision to open a Jarvis SIPP, You must decide as to its suitability for Your circumstances.
    2. The following shall apply in relation to Personal information and identity verification:
      1. You will be asked to provide certain personal information, and this information will be dealt with under and in accordance with Our Privacy Policy;
      2. You authorise Us to conduct checks to verify your identity and to confirm that You have never been involved in any fraudulent activities;
      3. identity verification checks will be conducted by a third-party, SmartSearch, who will have access to Your identity verification documents (for example, a photocopy of Your driving licence);
      4. P1-Investment Management will also have access to Your identity verification documents;
      5. We decide at Our absolute discretion on Your eligibility to open a Jarvis SIPP; and
      6. We are under no obligation to explain Our reasons for refusing Your application to open a Jarvis SIPP.
    3. When We arrange to open Your Jarvis SIPP for You, You acknowledge and agree that You are subject to the Agreement and You and Your Jarvis SIPP will be subject to them. You also acknowledge and agree that:
      1. this document (Terms) and the documents and policies it refers to as amended from time to time;
      2. the Agreement supersedes all previous arrangements and agreements (if any) relating to the matters with which it deals;
      3. the Agreement represents the entire understanding and contains the whole agreement between Us and You and supersedes and replaces any prior written or oral agreements, representations or understanding between Us and You. You confirm that you have not entered into this Agreement on the basis of any statement or representation that is not expressly incorporated into the Agreement. Nothing in the Agreement excludes liability for fraud;
      4. You must read and agree to be bound by the Agreement; in opening a Jarvis SIPP it is deemed that You have done so; and
      5. if at any time You do not agree with the Agreement, You must not either open a Jarvis SIPP or You must no longer continue with Your Jarvis SIPP.
    4. You may not open a Jarvis SIPP jointly with any other person.
    5. You may not open a Jarvis SIPP for any person under the age of 18, whether or not You are their parent or guardian.
    6. You must be the age of 18 or over to open a Jarvis SIPP.
    7. You must complete the application process via the Jarvis app.
    8. You must answer all questions truthfully and honestly.
    9. You must only present truthful and honest facts when filling in required details on the questionnaire and:
      1. if We or the Jarvis SIPP Administrators find, at any time, Your application was dishonest, We and They reserve the right to close Your Jarvis SIPP without notice to You; and
      2. if, on application, You do not meet all of the requirements of Jarvis You will not be able to open a Jarvis SIPP. We are the final arbitrators of this and there is no right of appeal.
      3. You must at the time of application to open a Jarvis SIPP be:
        1. solely resident in the UK for Tax purposes; and
        2. have a permanent address in the UK.
      4. You may not open an account if You are a citizen of the USA or You are opening an account on behalf of such a person.
      5. We cannot open a Jarvis SIPP for any person who has dual tax residency.
      6. If You are resident in the UK for tax purposes but later stop being so You may, at Our sole discretion, continue to hold open Your Jarvis SIPP but no further contributions or transfers can be made.
      7. We may, at Our sole discretion, request evidence of Your identity and Tax residency.
  5. The Management of Your Pension Plan
    1. Your responsibilities in this area are as follows:
      1. You must ensure that at all times You comply with all applicable laws and regulations; and
      2. You must at all times account for and pay to HMRC (UK) any relevant taxes related to Your pension.
    2. Once Your Jarvis SIPP is open, We may contact You:
      1. from time to time about Your Jarvis SIPP, Your contributions or other aspects of Our Service;
      2. by phone through the number You provided;
      3. through any other platform with which You use to access Our Service;
      4. by writing to You at the address You provided; or
      5. through Your Email address which You provided.
    3. It is Your responsibility to give Us instructions that are clear, accurate, complete and unambiguous;
    4. This is how We operate Your Jarvis SIPP:
      1. We will only make any payments as instructed to do so into an account which is in the name of the Jarvis SIPP holder and in the UK;
      2. We instruct Our partners on Your behalf. We acknowledge and agree that We will only take instructions from You; and
      3. You provide us with the details and documentation referred to in clause 7 (Pension Location Service) and authorise us to create and enter into documents and agreements on your behalf in order to facilitate the transfer of the funds from Your Qualifying Pension Arrangements into Your Jarvis SIPP.
    5. We may refuse or delay such instruction in the following circumstances:
      1. If such instructions would breach FCA rules or any other regulations to which We adhere;
      2. If We are unable to verify Your personal details or identity;
      3. If You have given instructions and We have requested any documentation which has not been provided or is incomplete; or
      4. You give instructions which are ambiguous or unclear in any way.
      5. We will not be held liable for any losses that You incur in Your Jarvis SIPP.
  6. Delay Period
    1. When You request a pension transfer from an Authorised Pension Arrangement or We transfer funds from an Authorised Pension Arrangement to Your Jarvis SIPP, there may be a delay period before the transfer completes.
    2. The Delay Period may last up to 180 days.
    3. We do not accept any liability for losses incurred by You (whether direct or indirect and howsoever occasioned) arising as a result of any Delay Period.
  7. The Security of Your Jarvis SIPP
    1. We will provide You with Security Details with which to access Your Jarvis SIPP. These and only these must be used when wishing to gain access to it or giving Us instructions.
    2. In relation to Your Security Details and Your use of them, You agree that:
      1. You must not disclose them to any other person;
      2. You will not be asked for Your password over the phone or email, do not disclose it in that way;
      3. if You instruct Us using Your Security Details, which We will authenticate, We will act upon those instructions and will not be held responsible for those actions unless You had, prior to the instructions, informed Us sufficiently in advance of a breach of Your Security Details; and
      4. if You suspect that any of Your Security Details or access details have been disclosed or obtained by any unauthorised person in any way You must:
        1. change Your Security Details immediately; and
        2. inform Us immediately.
      5. We will act on any instructions from You which are in accordance with Our stated Terms and, in Our reasonable opinion, appear to be valid at the time of receipt. We have no duty to make any further enquires.
  8. Contributions to Your Jarvis SIPP
    1. You will be able to make Contributions (excluding in-specie transfers) to Your Jarvis SIPP. This capability may be added in the future. The following rules apply to future contributions.
    2. In making any Contribution, on a regular or single basis, to Your Jarvis SIPP through the App, You must at all times observe the rules which are applicable to registered pension schemes and the rules We set out which show Our partners’ terms. Our Key Feature Documents sets out Our current provisions for how to make any Contributions and/or transfer payments into Your Jarvis SIPP.
    3. Your Contribution is automatically transferred to Your Jarvis SIPP and used to buy more units of Your Fund.
    4. If You become ineligible for Your Jarvis SIPP, no further Contributions or transfers will be added to Your Fund once the ineligibility applies.
    5. We reserve the right to decline to accept from You any Contribution or transfer entirely at Our discretion. We do not need to give a reason for this, but it could be because it does not comply with the requirements of the Scheme Rules or the Finance Act or is not a Permitted Investment.
    6. We may, without Your authority, refund any Contribution or transfer made in error to Your Jarvis SIPP, in whole or in part, subject to restrictions imposed by Regulatory Requirements.
  9. Transferring into Your Jarvis SIPP
    1. You may only transfer to Your Jarvis SIPP, Permitted Investments available through Your Jarvis SIPP, from a pension scheme which is an Authorised Pension Arrangement. All other transfers or contributions must be cash.
    2. If You transfer Units which are a class that is able to distribute income once transferred, We will require further instruction from You on how to deal with that income. Note that we do not currently have the functionality to auto-invest income.
    3. Following a transfer of any investments, there may be a delay whilst our current provider processes the transaction, We are not responsible for any delay in these circumstances and do not accept any liability for losses incurred by You (whether direct or indirect and howsoever occasioned) arising as a result of any delay.
    4. We will use Our reasonable efforts to facilitate such transfer.
  10. Transferring out of Your Jarvis SIPP
    1. Transfer outs can be done by contacting Us via email on support@pensionjar.com.
    2. We or our Partners may refuse to process a transfer request in circumstances where We or Our Partners conclude that that there is a red flag present for the purposes of The Occupational and Personal Pension Schemes (Conditions for Transfer) Regulations 2021 indicating elevated risk of pensions fraud and We have not received sufficient information from You to determine on the balance of probabilities that such risk does not exist.
    3. Once all transactions have been enacted and settled We will:
      1. forward any and all Assets from Your Jarvis SIPP to another pension scheme as instructed provided We are able to do so under the Regulatory Requirements, subject to 16.3 above;
      2. ensure that We have deducted any sums which are due to Us including from other accounts with Us, should there be insufficient cash to do so We will sell investments to enable full payment of any sums due to Us, this prior to forwarding assets; and
      3. Our services are stopped or suspended We can hold any proceeds or sell any assets in Your Jarvis SIPP until We receive Your instructions.
    4. We will have no further liability toward You or Your Jarvis SIPP once the transfer of Your Assets have taken place. Such closure will not affect any legal rights or obligations that may have already arisen.
    5. Once the transfer out process is complete, the value of the Assets in Your Jarvis SIPP will be zero.
  11. Your Fund
    1. Your Fund for Your Jarvis SIPP is, by default, the Vanguard LifeStrategy® 60% Equity Fund or such other default fund as we may nominate from time to time. Where a new default fund is nominated, We will give you at least 30 days’ notice prior to transferring your benefits. This notice will include details of the new default fund, including its charging structure, together with details as to how the fund is invested.
    2. In the future, if You contribute money, or transfer cash into Your Jarvis SIPP (via Our App) this constitutes a one-off or recurring Order to purchase a number of units (proportional to your Order and dependent on the prevailing price of Your Fund) of your Fund, less applicable fees/levies.
    3. The contribution will be applied to Your Fund, subject to Your contribution being properly set-up, at the next available dealing date.
    4. When Your instructions are received an Order will be placed as soon as it is practical in Your Fund.
    5. If any contribution or transfer is received of an unexpected nature or We have reason to be concerned about its authenticity, We will not place such order until We have contacted You and You confirm to Us such order. If no confirmation is received from You within 15 Business Days Our Independent Custodian may be required to return the cash to You without placing the Order.
    6. If You instruct Us to move Your Fund to another Permitted Investment (this is called a switch), this will involve the sale of units in Your current Fund and the purchase of units in your new Fund, this sale and purchase normally takes place at the end of the working day following Your instructions to Us. During this period Your money may not be invested in either Fund.
    7. If our Custodian holds cash on Your behalf at any time, interest will currently be payable. Should this change and interest no longer becomes payable, we reserve the right to update the Terms to retain this interest without any user consent. You expressly consent to this.
  12. Permitted Investments
    1. The current Permitted Investments are set out in Our App and in the Schedule of Allowable Investments.
    2. If the Permitted Investments alter within Your Jarvis SIPP at any time, and We may alter them, this may require Us to sell the Investments which have been removed, or if We are permitted by Regulatory Requirements make a transfer or withdrawal.
    3. We will notify You via Our App of the changes and Your options if this affects Your Jarvis SIPP.
    4. What We need from You to be able to place an order:
      1. Forename;
      2. Surname;
      3. Date of Birth;
      4. Nationality; and
      5. Natural Person Identifier.
      6. These details will be held by Us to enable Us to meet Our regulatory obligations.
    5. Your Assets as held in Your Jarvis SIPP may contain their own charges (such as initial charges, ongoing charges, dilution levies). These charges are all contained in our Annual Fee.
    6. We and Our Jarvis SIPP Administrator may, from time to time, make use of an independent stockbroker whilst dealing with Your Jarvis SIPP.
    7. Whilst Your investments are held in Your Jarvis SIPP they may not be used as any form of security for a loan.
  13. The Fees for Your Jarvis SIPP
    1. Please see Our Fee Guide for more detail on Our Fees.
    2. The Annual Fee is comprised of a Platform Fee and Fund Charge. The annual Jarvis Platform Fee is 0.75% for the first £75,000 of assets, reducing to 0.35% thereafter and our current Vanguard and Legal & General fund range has an annual charge of 0.20% to 0.22% of the total assets in Your Jarvis SIPP. This charge is subject to change. We will notify You sufficiently in advance of any change.
      1. If We cease trading, there may be a Fee for transferring out Your pension to another Registered Pension Scheme.
      2. There are no other regular ongoing fees related to Your Jarvis SIPP.
  14. Withdrawals From Your Jarvis SIPP
    1. We will be introducing a drawdown functionality in the future, and You will be notified of this addition via the Jarvis app. In the interim, if You wish to withdraw, draw benefits or to purchase a lifetime annuity, You will need to Transfer Out your Jarvis SIPP to another pension provider that offers those facilities. Partial Transfers Out will not be accepted.
    2. You can require us by written notice to Transfer Out Your Jarvis SIPP to another provider at any time, subject to the applicable legislation and HMRC regulations. You may instruct us to Transfer Out as cash. This will be done as soon as reasonably practicable.
  15. Closing Your Jarvis SIPP
    1. Your Jarvis SIPP can be closed only in the following ways:
      1. You request to transfer the monies in Your Jarvis SIPP to another Registered Pension Scheme;
      2. You write to us within 30 calendar days of opening your Jarvis SIPP, requesting to close your Jarvis SIPP (“Right of termination”);
      3. Closure by Us: when Your Jarvis SIPP contains zero value and We notify You of Our intention to close;
      4. The exercise of any other option permitted under the Regulatory Requirements; or
      5. Upon death.
    2. Closure by You:
      1. You may tell us that You want to close Your Jarvis SIPP, by giving written notice. We will process all outstanding orders and payments due on Your Jarvis SIPP as soon as reasonably practicable and transfer any remaining Assets in Your Jarvis SIPP to another Registered Pension Scheme.
      2. Up to the completion of Your instructions to close or other such instructions Our charges will continue to apply. To complete the closure You will need to give Us instruction through the App.
    3. Closure by Us: We may immediately suspend or close Your Jarvis SIPP and end this agreement between Us by giving You written notice if:
      1. for a period of six (6) months there are no assets in Your Jarvis SIPP;
      2. You do not provide Us with evidence, which We are satisfied with, of Your identity and thus We are unable to complete Our anti-money laundering checks;
      3. You are in material breach of these Terms;
      4. We are obliged to by law or cannot meet Our regulatory obligations;
      5. sums due under these Terms remain unpaid;
      6. Your behaviour is deemed, by Us as abusive or unreasonable;
      7. We are unable to contact You after using reasonable efforts;
      8. We are unable to ascertain by reasonable effort who is the owner of the assets in Your Jarvis SIPP is;
      9. You are using Your Jarvis SIPP for illegal purposes or for market timing, to provide business services to another person or any other such similar activities; or
      10. You have or did give Us false or inaccurate information, but for which We would not have opened any Jarvis SIPP or because of which We are no longer able to provide Our Services to You.
    4. The effect of closure, when the closure notice is served is as follows:
      1. You must settle all sums due and payable no matter what circumstances they become so;
      2. We will execute any current authorised instructions but will not accept any new instructions;
      3. once all outstanding transactions have been settled We will deduct from Your Jarvis SIPP balance any sums that are due to Us from you including any sums that You owe Us in relation to any other accounts that You hold with Us (we may sell any investments within Your Jarvis Pension to meet any Charges due to Us if there is not enough Cash in Your Jarvis Pension);
      4. We will then forward any Assets in the Jarvis SIPP to such other registered pension scheme account or accounts in Your name, or as You direct consistent with the options available under the current Regulatory Requirements (unless We are prevented from doing so by any Regulatory Requirements); and
      5. We will have no further liability to You once any Assets remaining in Your Jarvis Pension have been transferred.
    5. Dormant Jarvis SIPPs will be treated as paid-up and will be held by Us until We receive further instructions from You or Your personal representatives. In certain circumstances unclaimed Investments may be realised and the Assets transferred to a charity of Our choice. We will maintain records of these events.
  16. Transferring Your Jarvis SIPP
    1. In the future, Jarvis may transfer Your Jarvis SIPP to some other registered pension scheme consistent with the options available under the current Regulatory Requirements (unless We are prevented from doing so by any Regulatory Requirements), and in accordance with Jarvis’ Terms.
    2. Jarvis will give 30 days’ notice of any such transfer.
  17. Dealing and Order Execution
    1. Partner Order Execution Policy: https://seccl.tech/order-execution/
    2. When an Order is placed the price of purchase will be determined at the next valuation point for that fund. This is referenced and calculated to the next working day and a given specific time. Your Jarvis SIPP is updated as soon as reasonably possible but there may be a delay in doing this.
    3. When We receive an order to deal in specific funds and the Order is routed to the appropriate fund manager(s) the Order will be executed by them on the next available dealing date. They may place Your Order along and together with other orders and execute them at the same time.
    4. Should We be unable to process Your order We will inform You through the App.
    5. The time of execution of Your Order will be recorded and will be conclusive (unless it is obvious the time is recorded incorrectly).
    6. We may delay or refuse to transmit Your Order to respective fund manager under the following circumstances:
      1. extreme market conditions exist and Our Partners or Us have suspended taking trades;
      2. Your Order does not meet the minimum investments criteria for the units that You want or the Order does not meet the criteria current on Our App;
      3. We or Our Partners do not believe that You have the legal right to/authority to deal in the investments;
      4. We or Our Partners feel that the proposed transaction may constitute market timing/abuse or are concerned that such an Order may cause a breach of Regulatory Requirements; or
      5. We or Our Partners believe that the placement of the Order could give rise to a fraudulent transaction, in suspecting that the Order was not placed by someone We have agreed may operate Your Jarvis SIPP.
    7. Confirmation of Orders:
      1. upon execution of an Order, a contract note will provide the details of the sum debited/credited to Your Jarvis SIPP;
      2. Your contract note will be available to view at Your request; and
      3. We will update Our system after We receive price confirmation from the fund provider or upon receipt of the contract note, which should be no later than the first business day after the execution of the Order.
      4. Once an Order is transmitted You are unable to cancel that Order;
      5. The following will apply in relation to order settlements:
        1. We will delay the settlement of any Order until any prior sale or purchase has been settled, if necessary, this subject to any settlement delay being beyond Our control;
        2. We will debit Your Jarvis SIPP on the trade date (not the settlement date) for any purchase, therefore cash funds must be available on that date;
        3. when Assets are traded in ETIs, Our Custodian will operate, normally, on a delivery versus payment (DVP) settlement process;
        4. settlement of Clients Assets will accord with market best practice; and
        5. all Clients’ money will be reconciled on a Business Day basis and Assets externally according to their type and registration.
  18. Events and Your Rights over Your Investments
    1. Should You hold investments to which voting rights are attached, we do not currently offer voting options on corporate actions. The default option will apply.
    2. Due to the way in which Your investments are held under Your Jarvis SIPP, with a Nominee or third party custodian, You may not receive the same options or treatments in respect of Corporate Action (or other events) as You would if the Investment where held in a separately designated Account. With a nominee company or custodian in certified form 21 You will not be entitled to any shareholder perks or company privileges as if You would be if you were the registered owner of the Investment.
    3. If any of Your Investments are subject to a take-over, conversions or other offer, unless there is a facility to register fractional share or unit holdings, such offer will be rounded down to the nearest whole unit as set out in these Terms.
    4. You will not be able to benefit from any ancillary rights that may be available to direct shareholders in investments for example commercial discounts, nor will We become involved in any shareholder interest groups or the like.
    5. Your Assets will be valued daily and the value will be visible on the dashboard of the Jarvis App.
    6. Class Actions; if We are made aware of any class actions or group litigation in respect of any of Your investments We will not;
      1. be responsible nor participate in any such action or litigation; or
      2. inform You or obtain any instruction from You in relation to this.
    7. The following shall apply in relation to Reporting:
      1. in abiding with Regulatory Requirements We provide pension statements and illustrations online;
      2. any concern You may have on any matter concerning Your Jarvis SIPP must be reported to Us within six (6) months, otherwise We may not be able to take any corrective action; and
      3. You should monitor carefully any reports We send to You and inform us of any error or omission in any contract note, if You do not receive in a timely manner any confirmation of a Trade that You are expecting or if there have been any unexpected transaction shown all in respect of Your Jarvis SIPP.
    8. We will provide You with the necessary notes, reports and notifications in relation to Your trade in order to comply with Regulatory Requirements. If requested We will arrange for paper copy statements, reports or ad hoc valuations but there may be a charge for this service, see Our Fees Guide.
  19. Conflicts of Interest
    1. Jarvis is committed to maintaining the highest professional standards and, therefore, We endeavour to identify, consider and manage potential conflicts of interest to ensure that We treat all of Our customers fairly and in accordance with FCA Rules and principles.
      1. Nature of a conflict of interest:
        1. In essence, a conflict of interest is a situation in which Jarvis (or any of its personnel) finds itself in a position where its own interests conflict with the duties and obligations owed to its customers or, a situation in which Jarvis’ duty to one customer conflicts with its duty to another. For the purposes of identifying the types of conflict and potential conflicts that arise which may entail a material risk of damage to the interests of a customer, We must take into account whether Jarvis or its directors, employees or contractors (“Jarvis Personnel”) or any other person linked by control to Jarvis:
          1. is likely to make a financial gain, or avoid a financial loss, at the expense of a customer;
          2. has an interest in the outcome of a service provided to a customer or transaction carried out on behalf of a customer, which is distinct from the customer’s interest in that outcome;
          3. has an incentive to favour the interest of another customer or group of customers over the interests of the customer;
          4. carries on the same business as a customer; or
          5. receives or will receive from a person other than a customer an inducement in relation to a service provided to the customer, in the form of remuneration, goods or services.
      2. Conflict Situations:
        1. We have identified a number of situations which may give rise to a potential conflict of interest. These situations include, but are not limited to, the following:
          1. We receive gifts, entertainment or other monetary and non-monetary benefits from Our service providers or business partners (for example, the fund managers of the Funds We make available to customers through the app), which could give rise to a conflict with respect to the duties that We owe to our customers;
          2. Jarvis personnel who have outside commitments (e.g. directorships or other outside business interests) may be influenced to act in a manner that conflicts with the interests of Jarvis or its customers; and iv) where Jarvis personnel invest for their own account in certain investments which are retained as investments for customer accounts.
      3. Conflict Avoidance: We seek to organise our business in such a way as to avoid conflicts of interest arising.
      4. Conflict Management:
        1. For conflicts of interest which are unavoidable, We have put in place procedures which are designed to ensure that the management of any conflict takes place in such a way that Jarvis (and its personnel) are not advantaged and that no customer is disadvantaged. All of Our employees are provided with training in these procedures and the standards of conduct expected of them. Jarvis’ Board of Directors remains responsible for ensuring that such procedures are appropriate and that employees act accordingly. Specifically, We have put in place the following procedures to assist in Our identification and management of conflicts of interest:
          1. Conflicts Log: We maintain a list of all potential conflicts of interest identified. With respect to each conflict, the log details the measure put in place to monitor and manage the conflict of interest;
          2. Gifts & Entertainment Policy: We ensure that all Jarvis personnel are subject to appropriate restrictions and monetary limits for any gifts or entertainment received;
          3. Personal Account Dealing Policy: We ensure that all Jarvis personnel pre-clear and report any personal trading activity which may conflict with the interests of Our customers;
          4. Pre-approval process for all Outside Business Interests: We ensure that Our personnel’s external commitments do not conflict with the interests of Jarvis or its customers;
          5. Protection of information: We maintain appropriate safeguards to protect sensitive or confidential information which could give rise to conflicts of interest. These measures are designed to prevent unauthorised access, inappropriate use, or inappropriate dissemination of such information. Details of these arrangements are described in Our Privacy Policy.
          6. Separation of functions: where our internal functions might give rise to conflicts of interest, We put in place arrangements to separate such functions and ensure that separate management and reporting lines are established.
      5. Conflicts Disclosure
        1. If We are not reasonably confident that we are able to manage a particular conflict to adequately protect the interest of a customer, the general nature and/or source of conflicts of interest will be clearly disclosed before We undertake any business.
  20. Dividends and Income
    1. Upon receipt of any dividend or income in respect of Your Jarvis SIPP it will be retained in Your Jarvis SIPP.
    2. Allocation of any income to Your Jarvis SIPP will take place within 10 days.
    3. Should the income be in another currency We will convert it to sterling and allocate it to You Jarvis SIPP.
    4. Any income received after closure of Your Jarvis SIPP will be sent to Your new registered pension scheme, and should Your new pension provider not accept the income it will be donated to a charity of Our choice.
  21. Communication Between Us and You
    1. Methods of Communication:
      1. Our Service is provided exclusively through Our App.
      2. However We may also contact You by telephone, email or post, using Your most recent details.
      3. It is Your responsibility to ensure that all of Your details are kept current and up to date.
    2. Risks of online communication:
      1. We take all reasonable commercial measures to ensure that the security of Our Services and systems are not compromised.
      2. We cannot and We do not offer any warranty or guarantee as to the security of the online Services We offer or that it will be free from any technical failure, corruption, error, delay, misuse, fraudulent use or accessed by any unauthorised person;
      3. should any such errors take place outside of Our reasonable control, We will not be liable for any losses caused.
      4. We recommend that You use anti-virus software on your electronic communication device (computer or other device) to access Our Services.
    3. You are entirely responsible for ensuring that Your working facilities enable You to communicate with Us appropriately.
    4. From time to time Our services may be unavailable, this maybe to upgrade or maintain Our Services or if Our App is subject to any disruption for any reason, for example disruption of telephone networks.
    5. We will send You any notices via in-App notifications, email or SMS text messages, for example if We make any material changes to Our Agreement.
    6. Such notices or any correspondence will be deemed to be received the same day as such notice was sent; and
    7. Should Our communications to You fail, We will attempt to telephone you. If this fails, we will attempt to contact you via post at your nominated UK address.
    8. Should all Our communications to You fail, We will make no further effort to contact You at such addresses that have failed.
    9. We may, at Our sole discretion, record or monitor conversations, email or any other communications between Us to comply with any applicable Regulatory Requirements, to record Your instructions and for training or research purposes. Such records will be kept in line with Our Privacy Policy and if necessary for regulatory purposes.
    10. If instructed by You We will send copies of communications to Your agent, attorney, delegate, employer or any other such Third Parties in compliance with Your instructions.
  22. Power of Attorney and Personal Representatives (Death Benefits)
    1. We automatically suspend Our relationship with You if You become incapacitated. We will give written notice to You before we suspend Our relationship with You and We will require written proof of Your legal incapacity.
    2. Until such power is revoked We will continue to administer Your Jarvis SIPP in accordance with their instructions or Your death.
    3. We should be informed of Your death as soon as practicable and provided with all of the documents We require to give Us authority to deal with Your affairs. Until receipt We will be unable to accept any instruction from them.
    4. Your personal representatives will be bound by the terms of Your Jarvis SIPP and the Agreement in particular the fees payable.
    5. Provided that prior to Your death You have given Us Your wishes and appropriate directions (this is a service available to You at any time after You open Your Jarvis SIPP) about what You, upon Your death, would like to do with Your Jarvis SIPP We will:
      1. Notify the Jarvis SIPPs Trustee and Administrators, who will, at their discretion, take into account of Your wishes and directions and will abide by the Partners Terms and Regulatory Requirements; and
      2. value the Investments in Your Jarvis SIPP (using, in death, the “quarter up” valuation, as set out in the Regulatory Requirements – this being the difference between the lowest price available plus a quarter of the difference between the lowest and highest price available for any investment at the end of the day).
    6. If We do not hold Your wishes or directions form after Your death The Jarvis SIPP Trustee will make a payment of death benefits from Your Jarvis SIPP after consideration of any circumstance made know to Us and to the extent permitted under the Partners Terms and Scheme Rules, the Finance Act and the Taxation of Pension Act.
    7. Should there be unvested Assets in Your Jarvis SIPP on Your death, We will implement Your instructions to provide pension benefits to any person nominated by You.
    8. With reference to any annuity Purchased by You prior to Your death, the terms of the annuity and the annuity provider will determine the provisions made.
    9. We will, if there is a lack of formal instruction, take account of any expression of wish received from You, before paying death benefits to one or more persons. This in accordance with the Jarvis SIPP Terms and Conditions, Scheme rules and the Finance Act.
    10. We may subject to the Jarvis SIPP Terms and Conditions and the Scheme rules, take instruction from Your Personal Representatives or any other person entitled to benefit from Your Jarvis SIPP to defer buying an annuity or paying other death benefits or starting an Income Withdrawal. We will make all agreements and decisions with relevant beneficiaries, prior to disinvestment taking place.
  23. Our Terms
    1. These terms are the Terms under which You will be governed by Us in regard to Your Jarvis SIPP and how it is provided to You.
    2. In the event of any inconsistencies or differences between the Jarvis Terms, Fees Guide and the Jarvis SIPP Terms and Conditions, We shall decide all questions or matters of doubt, so far as the law permits and Our decision will be conclusive. There will be no right of appeal.
    3. We also refer to other documents within these Terms and they may also be updated or changed from time to time, the current version of them is available on Our App.
    4. The Fees that You will have to pay to use Our Services and those of Our Jarvis SIPP Administrator are set out in our Fees Guide, We recommend You read them carefully and ensure that at all times there is sufficient funds in Your Jarvis SIPP to ensure payment of them.
    5. Within Our Terms We explain the Service We provide and explain what We need You to do to make our Service work for You.
    6. From time to time We may vary our Terms and the varied Terms shall be binding on You.
    7. We may transfer Our obligations and rights under these Terms to another organisation, We will inform You in writing if this happens and will ensure that the transfer does not affect Your rights under this Agreement.
  24. Changes to Our Terms
    1. If We make any material changes to Our Terms they will be notified to You in writing, via your Jarvis app, email, or via SMS, thirty days (30) days prior to the new Terms being valid.
    2. We will however without prior written notice change Our Terms of this Agreement if We have a valid reason, We consider such valid reasons to be:
      1. in response to changes in Regulatory Requirements;
      2. to include new systems and processes or changes in the way Our business operates or any restructuring of the Services We provide to You;
      3. any changes to or affecting any third party with whom We engage with whilst providing Our Services to You;
      4. to remedy any errors; or
      5. to reflect legitimate costs increases.
  25. Compensation and Complaints
    1. The FSCS was set up to assist private individuals and smaller business and charities (in certain circumstances). Your Jarvis SIPP is covered by the Financial Services Compensation Scheme (FSCS) up to £85,000 and under certain and particular circumstances You may be entitled to receive compensation if We or Our Partners are unable to meet Our obligations to private individual Clients, such as if We cease to trade or become insolvent.
    2. The FSCS does not protect against volatile or difficult markets and will not protect you from the risk that You receive back less than you paid in. Also please note that compensation in overseas jurisdictions may differ from those in the UK.
    3. Dependent upon the circumstances of the claim You may be entitled to receive compensation through the compensation scheme held by the FSCS. This also depends on the business and the circumstances of the claim but most types of investment businesses are covered. The amount of compensation is currently capped at £85,000.00 for any one claimant. Compensation limits also are reliant upon Your total holdings with an organisation and in relations each category of claim. Compensation and therefore each limit includes all investments or all cash that You hold across Your accounts with one organisation, these limits, dependent upon Your claims may also apply to each of Our Partners separately. Please see https://www.fscs.org.uk for further information.
    4. Should You wish to make a complaint about Us or Our Partners, You can contact Us through the normal way You communicate with Us. Further information about Our complaints procedure is available for You to read in Our Complaints Handling procedure and in the Jarvis Pension Key Features Document which is available through Our App.
    5. If We do not resolve Your complaint, and We make every reasonable effort to do so, or within eight weeks to Your satisfaction You may refer Your complaint to:- The Financial Ombudsman Service, Exchange Tower, London, E14 9SR Tel: 08000234567 or the Pension Ombudsman, 11, Belgrave Road, London SW1V 1RB Tel: 02076302200 or view further information on https://www.pensions-ombudsman.org.uk/
  26. Liability
    1. We are not liable for any losses You suffer, unless:
      1. We have failed in Our duty of care, skill and due diligence in selecting or retaining a bank, pension provider, settlement agent or custodian;
      2. gross fraud or gross negligence;
      3. if We materially breach the rules of the FCA or Regulatory Requirements; or
      4. if We fail to transmit Your instructions through Our Service and Your Assets become inadequately protected.
    2. We will not be responsible for any losses in any circumstances that You suffer because:
      1. of any machine, software malfunction or error in transmission;
      2. of Your operating error, or Your inability to in whole or part communicate with Us;
      3. the information You have provided to us is unclear, inaccurate, ambiguous or We have acted in good faith on instructions that appear to be valid and given in accordance with Your stated procedures;
      4. We are unable to execute or transmit any instruction due to a breakdown in communication between Us and an execution venue or Our systems are unavailable (unless this arises as a result of any negligence on Our part);
      5. of any circumstances which are outside of Our reasonable control, this to include but not limited to delays in relaying Your orders, the value of Your assets go down or changes in market conditions (including market fluctuations). If We are unable to perform Our obligations due to circumstances beyond Our reasonable control, We will in so much as it is within Our reasonable ability to do so, take steps to minimise the effect of the event on Our clients; or
      6. of any delay due to verifying Your instruction.
    3. We are not liable or responsible for the Insolvency, default or any other failure by a third party, settlement agent, bank, clearing agent depository or settlement system or any person or participant in any one of them. Neither are We responsible or liable for any Fund Provider’s agent with whom We may have placed, or caused to be placed, an order You gave Us.
    4. You acknowledge and agree that Your Jarvis SIPP and all of Your contributions to it are held by, and managed by the Custodian.
    5. Jarvis shall have no such liability in the event that You suffer any loss or damage as a result of their failure to administer or properly protect Your pension.
    6. Any issues or disputes with the Custodian are subject to their Terms not Ours.
    7. Your liability to Us will be for any Fees reasonable and properly incurred under our Agreement, or for an error on Your part.
    8. We do not restrict any liability or exclude any liability in circumstances where lawfully liability cannot be excluded, for example causing death or personal injury by Our negligence or in relation to any liability We may have to You under the regulatory system.
  27. General Risk of Investing
    1. The value of Your investments can go down as well as up and Your capital is at risk, You may get back less that the amount You originally invested.
    2. You should read the relevant Jarvis SIPP Key Features Document, Key Investment Information Document (KIID), Key Information Document (KID), fund prospectus or PRIIP and the Fees Guide. Please also make note of the below information about the risks of investing but this list is not exhaustive:
      1. past performance is no guarantee of any future performance;
      2. derivatives may be used by a fund to protect against currency, credit and interest rate movements and for investment purposes therefore a fund which invests in derivatives is at risk of losses because of the failure of the counter-parties to complete transactions;
      3. investments in foreign, emerging markets or markets in less developed countries involve different risks from the UK market, for example but not exclusively, they may have less supervision or regulatory control;
      4. investments which are denominated in a currency other than sterling will be subject to currency fluctuations and may rise or fall in line with those fluctuations;
      5. when tax rules or laws change it could affect Your investments as they take no account of personal circumstances.
      6. Please take account of all of the information, and read the recommended information contained in it as this information could influence Your decisions.
  28. The Transfer of Your Rights and Obligations
    1. You may not, without Our prior written consent, transfer or assign Your obligations or rights under this Agreement to anyone else.
    2. We may transfer or delegate all or part of Our rights and obligations under this Agreement with You to a third party, while We do not need Your consent to do this We will ensure We receive undertakings from that third party (“Transferee Firm”) that Your Jarvis SIPP will be treated in the same way as it was before the transfer.
    3. We will also take reasonable care to ensure that the third party, should We delegate Our obligations to them, will competently perform the obligations delegated to them.
  29. Tax Matters
    1. Should any taxes or duties be included in Our Fees We will tell You. If they are detailed separately You may have to pay them. When You make a personal contribution to Your Jarvis SIPP You may be entitled to tax relief on that contribution in accordance with the Finance Act.
    2. If We have to pay a tax liability on Your behalf We may recover the costs from You. If You provide to Us with the necessary information We will arrange for Tax relief at the basic rate of income tax on Your behalf. Higher tax rate payers must make their own arrangements.
    3. You are liable for any and all other taxes that are personal to You in respect of Your Jarvis SIPP, and any Assets and transactions through Your Jarvis SIPP. Your Tax liabilities depend upon Your own circumstances and are liable to change. You are responsible for making sure that all of Your contributions into Your Jarvis SIPP are within the allowable limits set by the HMRC at the time of payment.
    4. We will be unable to process and will stop acting on Your instructions until all taxes, duties and third party Fees, which are applicable to You are paid by You.
    5. We have obligations under UK legislation, agreements and tax treaties (with worldwide jurisdictions) and European Union Tax rules which require us to provide certain information, and We will, without notice to You, provide such information as We are obliged to do.
  30. Third Party Rights
    1. In the event that We are declared bankrupt, these Terms are between You and Us and, in this situation and in general, no other person shall have any rights under it, therefore The Contract (Rights of Third Parties) Act 1999 does not apply.
  31. Severability
    1. If any Court of competent jurisdiction finds that any provision of this Agreement (or part of any provision and including any Schedule) is invalid, illegal or unenforceable, that provision (or part of any provision) will be, to the extent required, deemed to be deleted and the validity and enforceability of the other provisions of this Agreement will not be affected.
  32. Waiver
    1. Unless otherwise agreed, no delay, act or omission by a Party in exercising any right or remedy will be deemed a waiver of that or any other right or remedy.
  33. Regulatory Compliance
    1. We undertake to and confirm, that at all times We will comply with the Regulatory Requirements as they apply to Us operating Our Service in the UK.
  34. Confidentiality
    1. We undertake that at all times Your personal data will be dealt with compliance with Our Privacy Policy which is available to view through Our App.
  35. Entire Agreement
    1. This Agreement and any Schedules, Privacy Policy and Our Application Terms of Use contains the whole Agreement between the Parties relating to its subject matter and supersedes all prior discussions, arrangements or agreements that might have taken place about this Agreement.
    2. Please read these terms carefully before You use the Service, make sure You understand them before applying for a Jarvis SIPP. When You decide to apply for a Jarvis SIPP You will be subject to these Terms, if You do not agree or accept them do not make an application.
  36. Force Majeure
    1. If any Party to this Agreement is prevented from performing all or substantially all of its obligations under this Agreement by a Force Majeure Event for a continuous period of thirty (30) days or more any Party shall be entitled to terminate this Agreement immediately by giving written notice to that effect to the other Party(s).
    2. All Parties to this Agreement acknowledge and agree that they will notify the other Parties of or the potential of a Force Majeure Event as soon as possible.
  37. Data Protection
    1. All Parties including Your Custodian will have access to Your data to enable them to perform their duties to You. All Parties are classed as joint data controllers and all have independent Privacy Policies which explains how Your data is handled, used, shared with and stored please read these policies, which are available upon request from those Parties.
    2. Your Custodian will only use Your data for regulatory purposes and will not share it or use it for marketing purposes.
  38. Governing Law and Jurisdiction
    1. This Agreement and the Terms (including any schedule) contained in it are Governed by and interpreted according to the Laws of England and Wales, and all disputes arising under this Agreement (including non-contractual disputes or claims) shall be subject to the exclusive jurisdiction of the English and Welsh Courts.


Custody Terms

    1. Under the Terms, you consent to Jarvis Limited appointing Seccl Custody Limited (“SCL“) as the Custodian to provide:
    2. the custody services more particularly described in this schedule
    3. cash payment services, asset price and information data
    4. client money and asset reconciliation in accordance with the Client Asset Sourcebook (“CASS“) of the FCA Rules
      1. SCL is authorised and regulated by the Financial Conduct Authority of 12 Endeavour Square, London, E20 1JN, registration number 793200, to arrange, safeguard and administer custody of cash and Assets.
      2. SCL is registered in England, registration number 10430958. To contact SCL, write to 20 Manvers Street, Bath, BA1 1JW
      3. Terms not defined in these Custody Terms have the meaning set out in the Terms or the FCA Rules.
    1. The Custodian is authorised to ensure that the custody of your cash and Assets are managed compliantly in accordance with the applicable regulations.
    2. Any deposits or withdrawals of cash or instructions to buy, sell or transfer investments, through the ISP, will be recorded and managed in accordance with CASS. SCL will ensure any investment instructions are placed in accordance with the Terms.
    3. All client cash will be held with an approved Bank or CRD Credit Institution in a designated Client Money statutory trust account. The account is held separately from any monies held by either SCL or the ISP.
    4. Client Assets will be registered to Digital Custody Nominees Limited (“Nominee“) which is a wholly owned subsidiary company of SCL. This arrangement safeguards and segregates your Assets from those of SCL. SCL accepts the same level of responsibility under CASS to you for the Nominee.
    5. Your cash and Assets will be held in a pooled arrangement. This means that SCL will have records that identify your individual ownership and entitlement to Assets. For operational and servicing purposes it is more efficient for SCL to administer your investments on a pooled basis.
    6. SCL will have instances where we need to appoint third-party nominees or sub-custodians to maintain the custody services offered. By agreeing to these Custody Terms, you authorise SCL to do so.
    7. SCL will use reasonable care and due diligence to perform its custodian duties. Your Assets will be held separately to SCL’s Assets, if SCL goes out of business. If any shortfall of Assets arises as a result of SCL’s or a third-party nominee or sub-custodian’s insolvency, these would be shared on a proportionate basis with affected clients.
    8. Where SCL receive income from your investments through dividend payments, fund distributions and Corporate Actions, SCL will reconcile and credit these to your accounts.
    9. As Corporate Action events arise, SCL will inform the ISP where actions are applicable to your Assets.
    10. SCL will facilitate the transfer of cash and Assets in accordance with client instructions and the ISP’s Terms.
    1. Any client deposits or income will be credited to your respective account once identified and reconciled with the date SCL received monies.
    2. SCL will pay any and all interest received on cash held in Client Money accounts. Where interest cannot be distributed due to compound rounding differences, the unallocated interest will be paid to a SCL chosen registered charity.
    1. Settlement of Client Assets will accord with market best practice. Where Assets are traded in Exchange Traded Instruments “ETIs”, SCL will normally operate on a delivery-versus-payment “DVP” settlement process. By agreeing to the Custody Terms, you permit SCL to apply DVP transaction exemption as detailed in the FCA Rules up until any delivery of Assets (purchases) or cash (sales) passes the third Working Day, whereby SCL will follow Client Money and asset reconciliations in accordance with CASS.
    2. For model portfolio and switch orders, SCL will place a buy order after the sell instruction is confirmed by the fund manager or the market. SCL may delay the purchase of ETI orders if the intended settlement date on the sale of a fund, is a day or more longer than that of the ETI order.
    1. SCL will reconcile Client Money and Assets in accordance with CASS.
    2. Client Money will be reconciled on a Business Day basis and Assets will be reconciled externally according to their type and registration.
  6. LIENS
    1. We reserve the right to enforce the right of liens over the Assets under the Terms.
    1. All communication with you will be in English through the online message portal provided by the ISP.
    2. SCL will provide quarterly valuation statements and contract notes, which will detail the buys or sells instructed on your account. It is your responsibility to sign-in and read this information and it is important you notify the ISP promptly of any errors or omissions in respect of the accuracy of these documents.
    1. SCL has its own complaints policy. If you want to complain, please contact the ISP first. If the complaint relates to services provided by SCL, SCL will provide the ISP with all necessary information to resolve the complaint. The ISP may ask SCL to take control or assist on the complaint if necessary.
    2. If you do not think this is appropriate, please contact SCL by email at secclops@seccl.tech or by post to The Compliance Officer, 20 Manvers Street, Bath, BA1 1JW.
    3. If we do not resolve your complaint satisfactorily or fail to resolve it within eight weeks of receiving your complaint, you can also direct your complaint to the Financial Ombudsman Service at:
    4. Exchange Tower, London E14 9SR.
    5. Telephone: 0800 023 4567 or 0300 123 9123;
    6. email: complaint.info@financial-ombudsman.org.uk; and
    7. website: www.financial-ombudsman.org.uk.
    1. The ISP pays SCL for Custody services.
    1. SCL maintain a Conflicts of Interest policy independent of the ISP. It is available by contacting the ISP.
    1. To the extent permissible under applicable law, neither you nor SCL shall be responsible for any loss or damage suffered by the other party by reason of any natural and unavoidable catastrophes that interrupt the expected course of events and restrict you or SCL from fulfilling obligations under these Custody Terms (“Force Majeure Event“). If such loss, damage or failure is, or may occur, due to a Force Majeure Event, each party will use reasonable endeavours to minimise the effects and will notify
    1. In acting as your Custodian SCL, will have access to the data you provide on Application to the ISP service. In the Service Agreement between the ISP and SCL both parties are joint Data Controllers and have independent Privacy Policies which summarise how we will use your personal information and with whom we share it.
    2. SCL will use your details for regulatory reporting purposes and will not use or share your information for marketing purposes.
    3. SCL will retain your data and relevant communications for a period of seven years from the date of the account closure in line with the FCA rules.
  13. FSCS
    1. SCL is covered by the Financial Services Compensation Scheme (“FSCS”). If SCL ceases trading and cannot meet your obligations, you may be entitled to compensation from the scheme up to a maximum of £85,000 (or such other value covered from time to time by the FSCS) for investment claims.
    2. Further information about the compensation arrangements is available from the FSCS directly.
    3. Website: www.fscs.co.uk Telephone: 0800 678 1100 / 020 7741 4100.
    4. Address: Financial Services Compensation Scheme, PO Box 300, Mitcheldean, GL17 1DY
    1. To provide custody services, SCL will use the services of third-party service providers.
    2. Examples include the provision of; Data and price feeds of Assets, the execution of trading instructions, clearing and settlement services, banking services, client verification, regulatory reporting, card payment services and the facilitation of automated transfer instructions.
    3. Where services are provided by a third-party, SCL will use reasonable care and due diligence in selecting them and monitoring their performance. Except for clause 2.4, SCL does not guarantee proper performance by the third-party and will not itself be responsible if a third-party provider fails to meet its obligations. This means that should the third-party default or becomes insolvent, you may lose some or all of your Assets and will not necessarily be entitled to compensation from SCL. Including, in circumstances where it is not possible under the relevant national law and the registration under clause 2.6 to identify the Client Assets from the proprietary Assets of the third- party firm.
    1. SCL may terminate the Terms at any time by giving the ISP 30 days’ written notice (subject to applicable law and regulatory requirements). There is no minimum duration of the Terms.
    2. SCL may also terminate the Terms with immediate effect by written notice if required to do so for legal or regulatory reasons or on instructions from the ISP.
    3. In this event, the ISP will instruct SCL where to transfer the Client Assets and Client Money. If the ISP does not do so promptly, or if the ISP no longer represents you, then you will on request give the relevant instruction. The Custodian will transfer Client Assets and Client Money in accordance with the relevant instruction or, if it is unable to obtain instructions, it will transfer them directly to you. The Terms will continue to apply until such transfer of the Client Assets and the Client Money is complete.
    1. If any part of this agreement is declared unenforceable or invalid, the remainder will continue to be valid and enforceable.
    1. We may change these Custody Terms in whole or in part. We can do this for the reasons stated in our change control policy, a version of this is available from the platform provider.
    1. This agreement and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation shall be governed by and construed in accordance with the law of England.
    2. You irrevocably agree that the courts of England shall have exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Custody Terms or its subject matter or formation.
    1. SCL will act with all reasonable skill, care and diligence in acting as your Custodian. SCL will be liable to you for any direct loss that is the result of negligence or failure by SCL to account for Assets in Accounts or through a breach of FCA Rules, unless any such failure is the result of the acts or omissions of you or the ISP.
    2. Nothing in these Custody Terms shall be read as excluding or restricting any liability we may have for death or personal injury
    3. SCL will not be liable for the following:
      1. loss of business, goodwill, opportunity or profit; or
      2. any special, consequential or indirect loss whatsoever.
      3. as a result of us doing (or not doing) anything in reliance upon an instruction given (or which we reasonably believe to have been given) by you;
      4. as a result of your decisions relating to the choice, purchase, retention and sale of any Assets in your Account;
      5. from the default of any bank, fund manager or provider which holds your cash and Assets (except as required under the FCA Rules);
      6. from the performance of any Assets and investments;
      7. from any tax liabilities or charges that are incurred in relation to your Account and/ or the Assets held within it; or
      8. from any instruction sent by you that is not received by us, unless the failed receipt is due to a fault or omission on our part.
    4. You accept and acknowledge that the internet and the telecommunication systems may be subject to interruption or failure through no fault of ours.
    1. The section headings contained in this agreement are for reference purposes only and shall not affect the meaning or interpretation of this agreement.


Jarvis SIPP Terms

The terms and conditions in this schedule apply to the Jarvis SIPP, the pension scheme underlying the Jarvis SIPP is the Seccl Personal Pension Plan. This schedule refers to “the scheme”. This is a personal pension scheme that allows you to save for retirement in a tax effective way with the potential to invest in a range of investments. It is registered with HMRC under tax reference 20005619RK.

The scheme has been established and is governed by a Trust Deed and attaching Rules, “the Trust Deed”. Within the Trust Deed, Seccl Custody Limited established the Scheme within the meaning of Part 4 of the Finance Act 2004 “the Act” and is the Scheme administrator for taxation purposes. Seccl Custody Limited (the “Administration Company”) has appointed Digital Pension Trustees Limited (“the Trustee”), as trustee of the scheme.

Any reference in these terms and conditions to “we”, “us” and “our” are references to the Administration Company and in relation to paragraphs 1.11 and 1.13, the Trustee. References to “you” and “your” are to you, our customer and member of the Scheme.

These terms and conditions, together with your Application form a legally binding agreement between you and us.

Where this document refers to or described a particular tax treatment, you should be aware that tax treatment depends on your individual circumstances and is subject to change in the future.

  1. Our Jarvis SIPP Services
    1. Digital Pension Trustees Limited (the Trustee) owns the cash and investments in your Jarvis SIPP, holding them for your benefit under the Scheme Rules. Seccl Custody Limited has been appointed to hold custody of the cash and investments in accordance with the trust deed and rules. Seccl Custody Limited is responsible for the operation and administration of the Jarvis SIPP. It is also responsible, as Custodian, for the safekeeping and administration of the investments which you acquire in your Jarvis SIPP. Seccl Custody Limited is regulated by the Financial Conduct Authority to carry out these activities.
    2. Our conflicts of interest policy sets out the types of actual or potential conflicts of interest which affect our business and provides details of how these are identified and managed or prevented. You have the right to ask us for further information regarding our conflicts of interest policy.
    3. The FCA Rules require us to classify all investors. The Jarvis SIPP service is provided by us to “retail clients”. Unless we tell you otherwise, we will treat you as a retail client under the FCA Rules. This means you get the highest level of protection available under the FCA Rules.
    4. Our Jarvis SIPP enables you to make investments into a range of different assets, but we do not provide any financial or tax advice, and therefore we will not assess the suitability or appropriateness for you of the investments you choose to hold within your Jarvis SIPP, the scheme itself or any other service we provide.
    5. The investments which we provide access to may be restricted for your Jarvis SIPP. These restrictions will be made after taking into consideration FCA requirements, HMRC rules, legislation and our administrative requirements.
    6. Investment restrictions may be applied for the following valid reasons:
      1. Changes in HMRC rules;
      2. Changes in pensions or other relevant legislation;
      3. Changes in the regulatory regime governing pension assets or reporting requirements;
      4. Changes in investment markets;
      5. Changes in how our business operates.
    7. There is no alternative to the Cash Account within your Jarvis SIPP.
    8. You alone are responsible for deciding whether your Jarvis SIPP and the investments you choose are suitable for you. If you are in any doubt about the suitability or appropriateness of any particular investments, we recommend that you speak with an authorised adviser.
    9. We may delegate our functions in respect of the Jarvis SIPP to third parties in accordance with the Trust Deed. We will be responsible for the actions and omissions of any person to whom a function is delegated. We may also engage agents to help us perform our functions but will not be responsible for any acts and omissions of such persons subject to our duties under the FCA Rules and provided such engagements do not amount to a delegation of our functions.
    10. Our Jarvis SIPP is exclusively an online product for which you will need to complete an Application. We will send all communications and documents to via the Message Hub. We will not generally communicate with you by post. All of our documents and communications with you will be in English. You agree to receive copies of our up-to-date policy summaries (including summaries of our conflicts of interest and order execution policies) via our website.
    11. You can communicate with us about the Jarvis SIPP by email at here provider contact? support@pensionjar.com or the scheme administrator SECCL by telephone on 01225 435200.
    12. We are obliged under the FCA Rules to record certain communications (including telephone calls, electronic communications and instant messaging) which relate to, or are intended to lead to, the buying or selling of an investment. You have the right to request a copy of such recordings relating to your Jarvis SIPP at any time in the five-year period beginning on the date of the relevant recording. We may monitor and record other communications and calls.
    13. If we are negligent, knowingly in default, act fraudulently, or breach these terms and conditions or Applicable Law (as relevant), then we are legally responsible to you for the results of our actions unless set out below.
    14. If we make a mistake acting on your instructions to deal in, switch or sell investments, we will correct it as soon as possible, and reimburse you for any loss that is a direct result of our error. This reimbursement may occur outside your Jarvis SIPP due to the tax treatment of such corrections.
    15. We will not be responsible to you:
      1. if you suffer a loss because the value of your Assets fall;
      2. if you suffer a loss because you fail to comply with these terms and conditions or with any applicable legal requirement or because of any action which we take or refrain from taking in order to ensure that we comply with your instructions;
      3. for any action which we take or refrain from taking in order to ensure that we comply with Applicable Law;
      4. if we delay or fail to execute a transaction because of market conditions which may prevent us from being able to execute it in accordance with our order execution policy or Applicable Law;
      5. if you suffer a loss that was not reasonably foreseeable by you or us when accepted your Application for a Jarvis SIPP or is not otherwise a natural result of the breach;
      6. if you suffer any loss or damage as a result of an external event or something else that is unavoidable and outside our reasonable control, or as a result of any steps which we reasonably take in response to such (including the unavailability of our systems);
      7. for any deals on your Jarvis SIPP made by any person you have authorised to deal on your Jarvis SIPP (such as your financial adviser) that are placed incorrectly or without your authority;
      8. for the performance of any third party (for example, any broker required to execute a transaction), unless otherwise stated in these Terms & Conditions.
    16. In this clause, the word “loss” includes but is not limited to any liability to tax or penalty under tax law.
      1. The responsibilities in this section also apply to the Nominee and the Trustee. We are responsible for their respective actions or omissions.
  2. Your Responsibilities
    1. By opening your Jarvis SIPP, you agree that you will not take part in activity that may be considered to be market abuse. If we believe that your Jarvis SIPP is being used to engage in market abuse, we reserve the right to take such action as we deem to be appropriate.
  3. SIPP Establishment
    1. You can generally open and maintain a Jarvis SIPP if you are an individual aged 18 years or over, and aged under 75 years (if you are aged 75 years and over, you may open and maintain a Jarvis SIPP via a Transfer, however you will be unable to claim tax relief on any contributions into your Pension).
    2. As part of the Jarvis SIPP opening process, you will set up a username and password, and provide certain other personal security details which you will use to access the Jarvis SIPP. You must keep your security details secret. You must not disclose them to anyone or allow any other person to access your Jarvis SIPP using your security details. We are not responsible for any loss that your Jarvis SIPP may incur as a result of not having kept your security details and/or password secret.
    3. The submission of your Application does not constitute our acceptance of your Jarvis SIPP which we may decline entirely at our discretion. These Terms & Conditions come into force when we accept your Application.
    4. Under applicable money laundering regulations, we are required to verify the identity of our investors and their beneficial owners (which for your Jarvis SIPP may include your employer’s beneficial owners where Contributions are made by your employer) and obtain additional information in relation to them. In order to do this, we may carry out electronic searches on private and public databases and use credit reference agencies which will record that an enquiry has been made. We may also need to ask you for further documentation as evidence.
    5. Until we have verified your identity, we will place restrictions on your Jarvis SIPP, we may prevent any payments of Benefits to you or refuse any Contributions or Transfers.
    6. We will confirm when we have accepted your Application and you will become a Member of the SIPP as long as you have supplied all relevant information about any tax relief and other information requested as part of the application process.
  4. Making SIPP Payments and Contributions
    1. If you are eligible, you or your employer may make contributions to your Jarvis SIPP either on an ad-hoc or regular basis. These contributions can be done through a transfer of money via bank transfer, direct debit or other payment method made available by us from time to time.
    2. Personal contributions will normally be treated as having been paid net of basic rate tax which we will claim on your behalf from HMRC. The tax reclaim process normally takes between 6 to 12 weeks, during this time the money being reclaimed is not available for investment until we receive cleared funds from HMRC.
    3. Tax relief is granted at your highest marginal rate of income tax. If you are a higher rate tax payer, you will need to reclaim the additional tax relief through your self-assessment tax return.
    4. You must tell the Administration Company if you are not entitled to tax relief on all or part of the contributions. More information on contribution rules and limits are available on our website or by contacting a financial adviser.
    5. If you make contributions to your Jarvis SIPP which, when combined with other contributions to other UK pension schemes, exceed the amount on which you are entitled to tax relief, we may agree to refund the excess contributions to you provided there is sufficient money in your Jarvis SIPP to make the refund to you and repay any amounts due to HMRC. Any investment loss or growth in respect of a refunded contribution will be deemed to be outside the SIPP. A contribution cannot be refunded simply because it takes contributions over the Annual Allowance. Before we refund any excess contributions, we will require evidence that the payment will be authorised under the tax rules. Any excess tax relief already received from HMRC must be returned to HMRC within the timescale specified by HMRC. We are not responsible for any interest levied by HMRC on a refund of overpaid tax relief , also, see clause 4.11 below about the Annual Allowance.
    6. A refund of excess contributions can be requested at any time before the end of the sixth tax year following the tax year in which they were made. The maximum refund available will be the value of the excess contribution(s). A refund might be delayed if there is insufficient cash in your Jarvis SIPP.
    7. We can refund a contribution when we receive a valid request for a contribution which was:
      1. paid in genuine error (as defined by HMRC) and was not intended to be paid;
      2. an employer contribution which should have ceased on the termination of employment and was paid in error;
      3. a member or third party contribution where the member has insufficient earnings to attract tax relief on the contribution paid.
    8. Where there is insufficient money in your Jarvis SIPP to pay amounts due to us, HMRC or to pay Benefits or other payments due, we may require you to pay further funds into your Jarvis SIPP bank account or dispose of Assets to meet the amount due. We are entitled to direct the Trustee to dispose of Assets within your Jarvis SIPP as a portion of the largest holding sufficient to repay us, you or HMRC if the amount remains unpaid after 30 days. If you have taken Benefits or Transferred Out of the scheme or there is insufficient money in your Jarvis SIPP, you remain liable for any losses or costs incurred by us.
    9. Contributions paid by your employer are treated as being paid gross meaning there will be no further tax relief for us to claim. We will require your employer to provide additional information which indicates the payments they are committed to making on your behalf. Where payments are not received within the statutory timescale, we are obliged to notify The Pensions Regulator if it is deemed of material significance.
    10. If we receive a Contribution payment and we are not provided sufficient information to identify that this is intended to be for your benefit, then this may be returned to the payer.
    11. You should read the Jarvis SIPP Key Features document for more information about how to make contributions, tax rules and eligibility restrictions including Lifetime Allowance, money purchase Annual Allowance and tapered Annual Allowance. We will not be responsible for ensuring that your contributions remain below the Annual Allowance, money purchase annual allowance and tapered Annual Allowance. We will not normally accept contributions which exceed your available Annual Allowance or (if applicable) money purchase Annual Allowance.
    12. If you have incurred an Annual Allowance tax charge or money purchase Annual Allowance charge, you are responsible for paying them to HMRC. In the case of the Annual Allowance, you can also pay a share of the tax charge from your Jarvis SIPP as long as the amount due to HMRC is at least £2,000. The maximum amount you can pay in this way must not exceed the encashment value of your Jarvis SIPP after allowing for all fees, charges and other deductions. If you are a member of more than one pension scheme, the amount paid from your Jarvis SIPP should not in any case be more than a share in accordance with HMRC’s rules. To arrange the payment, you must tell us in writing that you wish to do so.
  5. Pension Input Period
    1. Your pension input period is a period of time defined by HMRC to measure your contributions paid. Your first pension input period starts when we accept your first contribution and ends the following 5 April. Subsequent pension input periods will be aligned with the tax year.
    2. The ‘Annual Allowance’ is defined by HMRC and limits the amount of tax relief available on pension savings in a pension input period. If the total of all pension savings made by you (or for you) exceed the annual allowance, you may be liable to a tax charge.
  6. Transferring existing pensions to us
    1. We may, at our discretion, accept a request to transfer all or part of your pensions from other UK registered pension scheme into your Jarvis SIPP. We will not accept a transfer from a pension with Safeguarded Rights (as defined in Section 48(8) of the Pension Schemes Act 2015).
    2. We may, at our discretion, accept transfers of benefits from other Authorised Schemes, subject to the Trust Deed. Benefits comprising uncrystallised (and crystallised benefits in due course) can be accepted and will all be separately identified within your Jarvis SIPP.
    3. It is your responsibility to ensure a transfer of pension benefits is in your best interests. You should consider taking advice from a suitably qualified financial adviser. We do not provide advice. Our acceptance of a transfer is in no way an endorsement of the suitability for you of the transfer.
    4. We reserve the right to reasonably refuse or refund a transfer (whether in part or whole).
    5. Where you request a cash transfer or In-Specie transfer of approved investments from an existing pension you take responsibility for initiating all transfer instructions. The Administration Company does not accept responsibility for delays in receiving transfers.
    6. We can decline a transfer of any of the Investments to be transferred. This will be limited to Investments we are unable to hold. We will inform you if this is the case.
    7. You agree that we may obtain any information we believe is necessary from your previous pension scheme to comply with Applicable Law.
  7. Right to cancel your Product
    1. You may change your mind and cancel your Jarvis SIPP by informing us through the Message Hub within 30 days from the date of opening the Jarvis SIPP. If you cancel your Jarvis SIPP within the cancellation period, you may not get back the full amount you invested. We will pay back your initial Contribution made within this period, less any fall in value of investments you have made due to market movements.
    2. Where you have Transferred into the Jarvis SIPP from another Authorised Scheme, you may change your mind and cancel the transfer by emailing us on support@pensionjar.com within 30 days from the date of requesting the Transfer. If your Transferring Authorised Scheme has already released the Transfer value, they may refuse to take your Transfer back. You will need to choose an alternative Authorised Scheme to receive the Transfer value. We’ll pay back your Transfer, less any fall in value of investments you have made due to market movements and any charges that have been paid to Jarvis.
    3. These Terms & Conditions will apply until your Membership of the scheme ceases or your Jarvis SIPP is closed. Termination of these Terms and Conditions shall not affect accrued rights, existing commitments or any contractual provision intended to survive termination. We reserve the right to close your Jarvis SIPP if you have not made any Contributions nor a Transfer of benefits from another Authorised Scheme, within 6 months of the date of your Application.
  8. Cash Management and interest
    1. The Custodian will hold Contributions paid, and cash Transfers made into your SIPP in a pooled Client Account in accordance with the Trust Deed and Applicable Law. Any Cash held by the Custodian will be held as client money and managed in accordance with the FCA Rules.
    2. Interest received by the Custodian is allocated to your Jarvis SIPP Account. Cash held, where applicable, earns interest from the day it has been identified as relating to you and it is credited to your Account.
    3. Interest is accrued based on the cash held within your Jarvis SIPP Account and applied to your Account within a reasonable amount of time of it being received by the Custodian, as long as the Account remains open.
    4. Interest will be calculated and applied gross to your Jarvis SIPP Account.
    5. The average interest rates paid to Clients and the prevailing bank rates may change on a frequent basis. You agree we do not have to notify you of any changes in these rates but the current rate will be available to view at www.seccl.tech.
  9. Your Assets
    1. The Assets within your Jarvis SIPP will be held in the name of the Nominee on behalf of the Custodian. The Trustee remains the beneficial owner.
    2. Jarvis SIPP permitted investment range is currently restricted to the Cash and Assets meeting the FCA’s definition of “standard investments” all of which must be capable of being held by the Custodian and administered by us. Broadly speaking this means an asset has to be an FCA authorised or recognised collective investment SIPP or a listed security and capable of being valued on a regular basis and sold within 30 days.
    3. Any investment income, including interest, or capital gains from your investments will be held by the Custodian on your behalf and will form part of the Assets and, therefore, value of your Jarvis SIPP.
    4. All investment instructions are made by you or your Adviser Firm to Seccl Custody Limited and neither Seccl Custody Limited nor Digital Pension Trustee Limited shall be responsible for any investment decision.
    5. The Administration Company has discretion to direct the Trustee to dispose of an Asset without consultation with you or your prior agreement when the following situation occurs:
      1. the continued retention of an Asset would be unlawful;
      2. the continued retention of the Asset would impose tax or other costs which your Jarvis SIPP may not be able to meet;
      3. the Asset needs to be disposed of to meet any tax liability or other liabilities or costs (including our own) (see section 4.8);
      4. where there are insufficient funds in your Jarvis SIPP to pay amounts due to us, HMRC or to pay Benefits or other payments due (see sections 4.8 and 9.5);
      5. to comply with a court order.
  10. Jarvis SIPP Statements
    1. We will provide you a number of statements, a pensions statement annually, quarterly Valuation Statements and such statements required by Applicable Law, showing you a summary and valuation of all your Jarvis SIPP Assets and every transaction executed for you in the previous reporting period. Your Valuation Statements will be made available for you to view in the Message Hub, and you agree that you will access the Message Hub from time to time in order to review your most recent Valuation Statement. You agree to tell us of any discrepancy or issues with these Valuation Statements in reasonable timeframe. In the absence of any such notification, we will be entitled to assume that the valuation is an accurate reflection of your Jarvis SIPP.
  11. Transfers Out
    1. We on behalf of the Trustee have discretion whether or not to accept your request to Transfer Out the value of your Jarvis SIPP to another Authorised Scheme.
    2. We will not Transfer Out benefits in accordance with these terms and conditions unless we are satisfied as to each of the following:
      1. we have proper authority and approval to make the Transfer Out;
      2. all outstanding fees, charges and liabilities have been settled; and
      3. making the Transfer Out is not likely to prejudice any protected benefits, or be unlawful or be made to an unrecognised or unregistered pension SIPP or be made to a SIPP suspected of being involved in any kind of investment scam or pensions liberation.
    3. We will not transfer out benefits to Recognised Overseas Pension Schemes (ROPS).
    4. In some circumstances it may be necessary for us to delay a Transfer Out, particularly where we are unable to realise or re-register some of the Assets, particularly Assets that are not readily realisable. Such circumstances could lead to you having to defer Transferring Out or taking Benefits.
    5. In the event that you are transferring out to take retirement income or benefits you will be required to discuss your options with, Pension Wise from MoneyHelper https://www.moneyhelper.org.uk/en/pensions-and-retirement/pension-wise.
    6. If we receive an income payment, a dividend or other Cash amount relating to your Jarvis SIPP, after you have Transferred Out from your Jarvis SIPP, we will ensure that such payments will be sent onto the receiving Authorised Scheme in accordance with the strict requirements set out in Applicable Law.
    7. In the limited circumstances permitted by Applicable Law, such as the winding up of the scheme, we shall be entitled to Transfer Out the value of your Jarvis SIPP without your consent or instructions.
  12. Jarvis SIPP Charges
    1. Charges apply to your Jarvis SIPP in relation to your Membership of the Scheme.
    2. You authorise the deduction and retention of all charges, applicable tax and reasonable expenses from your Jarvis SIPP bank account. All charges shown below are exclusive of Value Added Tax (“VAT”) unless stated otherwise. You agree that charges can be rounded up to the nearest whole £1.
    3. We will charge the following annual fee based on the value of your Jarvis SIPP:
      1. Jarvis Platform Fee of 0.75% for the first £75,000 of assets, reducing to 0.35% thereafter
      2. Fund Charge of 0.20% to 0.22% – this is based on our current Vanguard and Legal & General fund range. This charge is subject to change. We will notify You sufficiently in advance of any change.
        1. If We cease trading, there may be a Fee for transferring out Your pension to another Registered SIPP.
        2. There are no other regular ongoing fees related to Your Jarvis SIPP.
    1. Where permitted by Applicable Law, we are entitled to recover costs not stipulated in but incurred by us in the administration of your Jarvis SIPP. These costs include, but are not limited to, any losses, claims or liabilities involved with acquiring, valuing or disposing of any Assets; administration costs involved with complying with any court orders; disbursements or other charges or commissions levied by any investment or other professional advisers in line with the terms & conditions agreed with them; any tax charges, industry levies, duties or liabilities.
    2. We will provide you with an annual illustration showing the effect of costs and charges on the return of your Jarvis SIPP.
    3. All charges, fees and expenses due are deducted from your Jarvis SIPP bank account. Where there are insufficient funds within the Jarvis SIPP bank account, we may require you to pay further funds into the Jarvis SIPP bank account or dispose of Assets to meet the amount due. We are entitled to direct the Trustee to dispose of Jarvis SIPP Assets as a portion of the largest holding if the amount remains unpaid after 30 days.
    4. Where amounts due to us remain outstanding for more than 30 days, we are entitled to add interest to the sum outstanding at a rate of 3% AER above the Bank of England’s base rate.
    5. We are entitled to increase charges each year with effect from 1st May in line with the increase in the Average Weekly Earnings Index plus 1% which is published by the Government Office of National Statistics for the twelve-month period ending 30th September of the preceding year. Where charges are increased in line with this clause no notice will be given.
    6. We may facilitate through your Jarvis SIPP the payment of any Adviser Firm Charges which you have agreed with your Adviser Firm to be paid in this way.
    7. We also have the right to increase charges in certain circumstances, as outlined in Clause 14.
  1. Closing your Jarvis SIPP
    1. If you decide to close your Jarvis SIPP, you cannot automatically withdraw the value. The Assets or Cash held in your Jarvis SIPP can only be Transferred Out to another Authorised Scheme in accordance with these Terms & Conditions and the Trust Deed.
    2. We may close your Jarvis SIPP, on giving you notification, if (i) we cease to act as Administration Company and a suitable replacement cannot be found, or (ii) it becomes impractical to continue to administer your Jarvis SIPP in accordance with any Applicable Law.
    3. If we close your Jarvis SIPP on these grounds, we will give you at least 90 days’ notice of the closure and will explain your options for Transferring Out to another Authorised Scheme.
  2. Your personal information
    1. We are the data controller for the personal information you give us. We will not pass your personal information to anyone, other than as detailed in our Privacy Policy (which can be found at www.seccl.tech). By accepting these Terms & Conditions, you agree and consent to our obtaining, using and storing your personal information as set out in our Privacy Policy.
  3. Intellectual property
    1. All copyright, trademarks and other intellectual property in the materials and information on our website are owned or licensed by Seccl Technology Limited or by external content providers. Nothing in these Terms & Conditions or on the website should be regarded as granting any licence or right to or in any trademark or service mark of Seccl Technology or any third party.
  4. Complaints & FSCS Cover
    1. If you have a complaint about any element of the Jarvis SIPP, please send us an email on support@pensionjar.com or contact Seccl Custody, the scheme administrator at support@seccl.tech or via telephone on: 01225 435200. Our lines are open Monday to Friday 09:00 to 17:00.
    2. Your complaint will be handled by a person of appropriate competence and experience. That person will not have been directly involved in the matter which is the subject of the complaint
    3. We will endeavour to resolve any complaint as soon as possible
    4. If a final response has not been issued within four weeks of receipt of your complaint, we will write to you providing a holding response that will indicate when we make further contact. This further contact will be within eight weeks of receipt of the complaint
    5. By the end of the eight weeks, we must send you either a final response or a response which explains that we are still investigating the complaint, giving reasons for the delay and likely timescales. We will also, where appropriate, provide you with details of the Financial Ombudsman Service, along with a copy of their leaflet ‘Your Complaint and the Ombudsman’ and a statement confirming that an approach can be made by you to the Financial Ombudsman Service if you are dissatisfied with the outcome or the length of time the matter has taken.
      1. Financial Ombudsman Service

Exchange Tower, Harbour Exchange Square, London E14 9SR

Telephone: 0800 023 4567 (call charges will vary)

Email: complaint.info@financial-ombudsman.org.uk

Website: www.financial-ombudsman.org.uk

      1. The Pensions Ombudsman

The Pensions Ombudsman may investigate and determine certain complaints or disputes about pensions that are referred to the Ombudsman in accordance with legislation, and may be contacted at:

10 South Colonnade Canary Wharf, London E14 4PU

Telephone: 0800 917 4487 (call charges will vary)

Email: helpline@pensions-ombudman.org.uk

Website: www.pensions-ombudsman.org.uk

    1. The Jarvis SIPP is covered by the FSCS. You may be entitled to compensation from the FSCS if we are no longer trading or are declared to be in default and cannot meet our obligations to you. This may apply separately to your Jarvis SIPP, its Assets and any Cash held in your Jarvis SIPP and the maximum amount of compensation available will depend upon the type of investment business, the FSCS compensation limits applying at the time of any failure and the circumstances of your individual claim. The current compensation limits are as follows:
      1. for Cash, such as the money in your Jarvis SIPP bank account – £85,000 per eligible claimant, per Bank;
      2. for Assets, £85,000, per eligible claimant, per financial institution (where the relevant financial institution is also covered by the FSCS).
    2. Our current banking partner is Lloyds Bank plc and we will inform you if this changes. For more information about how the FSCS might apply to you, please contact us or visit the FSCS website at fscs.org.uk. The FSCS’s address is 10th Floor, Beaufort House, 15 St Botolph Street, London EC3A 7QU.
  1. Changing or ending these Terms
    1. You agree to us transferring all or any of our rights and obligations under these Terms & Conditions to any one or more appropriate Seccl companies or any third parties which are appropriately regulated and authorised under Applicable Law. These obligations include the appointments of Seccl Custody Limited as the Administration Company and the appointment of Digital Pension Trustees Limited as the Trustee. If we do this, we will give you at least 90 days’ advance written notice of the transfer. In each case, we shall cease to have any responsibilities to you or your Jarvis SIPP from the time that the change takes effect to the extent that those obligations applied to our appointment. The new administration company, or trustee will take on our obligations to provide the services under these Terms & Conditions in our place. We will not transfer our rights and obligations unless we are satisfied that you will not be in a worse position or receive a poorer service.
    2. We may make reasonable and appropriate changes to these Terms & Conditions at any time whilst your Jarvis SIPP is open as follows:
      1. to meet any current or future change in law, including rules established by the FCA, HMRC or The Pensions Regulator, or regulation, guidance or regulatory approach;
      2. to make these Terms & Conditions easier to understand, including to correct any inaccuracies, omissions, errors or ambiguities;
      3. to take account of any reorganisation of the Seccl companies, or a transfer of rights as outlined at 14.1 above;
      4. to reflect any improvements to the services which we offer under these Terms & Conditions, or changes to our systems, our processes and procedures, market practice or customer requirements;
      5. to reflect any changes to terms agreed between us and any third parties which are relevant to your Jarvis SIPP;
      6. other than as described in 12 above, we may also make reasonable increases to our charges to reflect any changes to the costs that we incur;
    3. If we do make any changes to the Terms & Conditions, the latest version will always be available on our website at https://getjarvis.app/policies/ and you should refer to them regularly. Where we reasonably consider that changes are material or detrimental to you we will give you a minimum of one month’s notice of the proposed change and our reasons for making the change, unless we are required to make the change sooner (in which case we will give as much notice as we reasonably can).
    4. Notwithstanding clause 17.3, changes that are necessary due to reasons outside of our control (e.g. a change in legislation/regulation/ tax or interest rates or resulting from an act of a third party) may take effect on reasonable written notice and changes which are immaterial and not to your detriment may take effect immediately and without notice.
    5. In either case, if you are not happy with any change we make or plan to make to the Terms & Conditions, you can transfer to an Authorised SIPP of your choosing. We will not charge you a fee for this, if a fee ever becomes due.
  2. Jarvis SIPP Benefits
    1. We only allow you to take benefits from your Jarvis SIPP with the support and advice from a Financial Adviser. You can of course transfer your Jarvis SIPP to another Authorised Scheme and we will not charge you for this transfer.
    2. If you are 50 or over, the Government has launched a free and impartial service to help you understand what your choices are and how they work, this can be accessed online, over the telephone by calling 0800 138 3944 or face to face – see www.moneyhelper.org.uk/en/pensions-and-retirement/pension-wise.
    3. It is strongly recommended that prior to accessing your pension benefits you seek advice from a suitably qualified financial adviser or obtain guidance from Pension Wise.
    4. You can take benefits from your Jarvis SIPP from the Normal Minimum Pension Age by instructing contacting the Scheme Administrator at, sipp@seccl.tech to commence drawdown pension (flexi-access drawdown) with all or part of your Jarvis SIPP or the balance after taking any Pension Commencement Lump Sum (“PCLS”).
    5. You may be able to take benefits early if:
      1. you have transitional rights to a protected pension age, and you satisfy the conditions in the Trust Deed. A protected pension age was generally available for people who paid into a pension before 6 April 2006 and had a right to take their pension benefits at an earlier age than the current rules allow; or
      2. we are satisfied that you are, and will continue to be, incapable of carrying on your occupation because of physical or mental impairment (in this case you must provide medical evidence to show that you have become incapable of carrying on that occupation and will continue to be incapable of returning to it).
    6. At the point you wish to take benefits you will be required to complete an application/questionnaire, available by emailing, sipp@seccl.tech. You are entitled to a 30-day cancellation period, for the first instance of taking benefits, effective from the date you receive a cancellation notice. Where you receive payment of benefits to which you are entitled and subsequently exercise your right to cancel you will be required to return the payments received back to the Jarvis SIPP. Failure to do so will be deemed as overriding your cancellation instruction.
    7. With the exception of your PCLS, payments made by us to you from your Jarvis SIPP will be made net of tax under PAYE and can be paid at regular intervals. We will normally offer payment on a monthly, quarterly or annual basis. Payments are conditional on there being sufficient cleared funds available in your Jarvis SIPP. We may request that you dispose of Assets within your Jarvis SIPP on a proportional basis to ensure there are funds available if the amount remains unpaid after 30 days.
    8. Payment to you by means of flexi-access drawdown (“FAD”) can involve a payment of a tax-free PCLS with any income being taxable as income. FAD is an option to use your retirement fund to provide retirement income.
    9. We will not pay benefits in accordance with these SIPP Terms unless we are satisfied as to each of the following:
      1. you have received financial advice;
      2. we have proper authority to pay the benefits;
      3. we are in receipt of all the necessary information required by regulations;
      4. we have received all the fees due to us;
      5. all liabilities and costs have been satisfied by your Jarvis SIPP; and
      6. all outstanding transfers have been received by your Jarvis SIPP.
    10. Where you take benefits flexibly, your Annual Allowance will reduce. For details of this and how it could impact your retirement savings plans please speak with your Adviser.
    11. When you commence taking benefits from your Jarvis SIPP, the value of the part of your Jarvis SIPP being used for benefits must be tested against the Lifetime Allowance. A test against the Lifetime Allowance will also be made in other circumstances set by the Act. If the Lifetime Allowance is exceeded, there is a tax charge. If you do not provide us with the information that we need to calculate your available Lifetime Allowance, we shall be entitled to assume that none is available, and we shall deduct tax accordingly. We will deduct the tax charge from your Jarvis SIPP. You must provide us with the information necessary for us to calculate the tax charge. This information includes details of any protections from the Lifetime Allowance that you have. You are responsible for any further tax charges that may arise as a result of that information being incorrect or failing to be provide. If your personal Lifetime Allowance is exceeded, the excess will be taxed at your marginal rate, which we will pay directly to HMRC.
    12. In addition to FAD you have the following further options from Normal Minimum Pension Age:
      1. Take an Uncrystallised Funds Pension Lump Sum (UFPLS). We do not offer UFPLS, in order to access benefits in this manner you will need to transfer your pension to another provider that does.
      2. Purchase an annuity for life, we do not provide annuities so your choice of annuity must be selected from a UK insurance company.
  3. Death Benefits
    1. On your death the payments we make, and how these are taxed, will depend on:
      1. the Trust Deed;
      2. your age at the time of death; and
      3. how we exercise our discretion.
    2. Upon being notified of your death, in order to settle any death Benefits payable under your Jarvis SIPP your beneficiaries or legal representatives should send a copy of your death certificate (either original or certified copy) to us.
    3. On receipt of your death certificate, we will restrict all investment and freeze the portfolio until an instruction is received from the appointed representatives.
    4. We may, at our complete discretion, decide who should receive a lump sum death benefit and if in what proportion. The list of your potential beneficiaries include any one or more of your beneficiaries, dependants, nominees or successors.
    5. Where you have made a nomination, we will take your wishes into account but are not bound by them. This will include the ability to establish a new Jarvis SIPP for a new Scheme member.
    6. By exercising our discretion in favour of a dependant, nominee (such nominee must have been nominated by you), or other beneficiary, that dependent, nominee or beneficiary (as applicable) may choose for the Benefits to be paid in one or more of the following ways:
      1. a lump sum death Benefit;
      2. income from income drawdown; or
      3. the purchase of an annuity.
    7. We shall deduct any tax from the lump sum or income payments for which the SIPP may be liable. All nominees must be selected via our online process.
    8. On your death the value of your Jarvis SIPP can be used to provide a lump sum or an ongoing income or used to buy an annuity. If death occurs before your 75th birthday, then lump sum payments from your Jarvis SIPP and income from any new provider will generally not be subject to tax as long as it is possible to make a payment within the two years from the date we are notified of your death. If death occurs on or after your 75th birthday, then any lump sum payments are generally subject to tax.
  4. How to contact Seccl
    1. We recommend that you contact SECCL by email on support@seccl.tech.
    2. Please do not include any account details if you contact us by email.
    3. Seccl Technology Limited is registered in England and Wales No 10237930. Registered office 20 Manvers Street, Bath, BA1 1JW.
    4. Seccl Custody Limited, is registered in England and Wales No 10430958. Registered Office 20 Manvers Street, Bath, BA1 1JW. Seccl Custody Limited is authorised and regulated by the Financial Conduct Authority, registration Number 793200 and is a wholly owned subsidiary of Seccl Technology Limited.
  5. Additional Jarvis SIPP Definitions

In addition to the main definitions, the following words and expressions in this Schedule 2 have the meanings appearing below:

Act – the Finance Act 2004 covering pension schemes and defining the rules by which we can operate.

Annual Allowance – the amount set by HMRC that you, your employer and any third party can pay to all your pension(s) each tax year before additional tax charges may apply.

Application – your application for and any associated information regarding the Jarvis SIPP.

Authorised Scheme – a “UK registered pension scheme” or a “qualifying recognised pension scheme”, such terms as defined in the Act.

Benefit – any payment made from your Jarvis SIPP to you or person(s) legally entitled to receive such payments.

Contribution – a payment by you, an individual on your behalf and/or an employer into your Jarvis SIPP.

FCA Rules – the FCA’s Handbook of rules and guidance, as amended or replaced from time to time and including, where relevant, any directly applicable EU regulation.

Lifetime Allowance – is the maximum amount set by HMRC that an individual can save within registered pension SIPPs in their lifetime without incurring an additional tax charge.

Member – a person admitted to membership of the Scheme, having made an Application to do so and who has not thereafter left the Scheme, and Membership should be read accordingly.

Normal Minimum Pension Age – the earliest age at which tax law normally permits Benefits to be paid to pension scheme members without penalty other than in circumstances of ill health. Currently, it is age 55 and will rise to 57 from 6 April 2028.

SIPP – the self-invested personal pension holding Cash and Assets individually for you and for your benefit that enables you to make Contributions to and take Benefits from the scheme.

Scheme – the registered pension scheme known as the “Seccl Personal Pension” which has been established by the Trust Deed and registered with HMRC in accordance with Chapter 2 of Part 4 of the Finance Act 2004.

SIPP Administrator – Seccl Custody Limited or any successor that maybe appointed from time to time who is the appointed administrator of the Scheme.

The Pensions Regulator – the UK regulator of workplace pensions, which also has certain roles in relation to personal pensions.

Trust Deed – in relation to Seccl Personal Pension, the Trust Deed and rules for the SIPP as may be amended or supplemented from time to time. Transfer – the transfer of assets to the SIPP from another Authorised Scheme.

Transfer Out – the transfer from us of the value of all or part of your Jarvis SIPP to another Authorised Scheme.

Trustee – Digital Pension Trustees Limited in its capacity as trustee for the Scheme. Unauthorised Payment – a payment which is not authorised under the Act.