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TERMS OF BUSINESS

Pat Britton & Co. Ltd t/a Britton Insurance
Crennan House, Tirconaill Street, Donegal Town, Co. Donegal, F94 R628
Tel: 074 9721304
Email: admin@brittoninsurance.com
Website: www.brittoninsurance.com

Effective Date: 1st July 2026 Version 5

1. Introduction

These Terms of Business set out the basis upon which Pat Britton & Co. Ltd t/a Britton Insurance (“the Firm”, “we”, “us”, “our”) will provide insurance intermediary services to you.

This document contains important information regarding our regulatory status, services, remuneration arrangements, complaints procedures, data protection obligations and your rights and responsibilities as our client.

By instructing us to act on your behalf and by proceeding with any transaction through our firm, you acknowledge receipt of and acceptance of these Terms of Business.

We reserve the right to amend these Terms from time to time and will notify clients of any material changes.

2. Regulatory Status

Pat Britton & Co. Ltd trading as Britton Insurance is regulated by the Central Bank of Ireland as an Insurance Intermediary under the European Union (Insurance Distribution) Regulations 2018.

Central Bank Reference Number: C4560

The Central Bank maintains a public register of regulated entities which may be viewed at: www.centralbank.ie

Copies of our regulatory authorisations are available upon request and is displayed in the public area of our office.

We are registered with the Competition and Consumer Protection Commission as a Credit Intermediary.

3. Codes of Conduct

We comply with all applicable regulatory requirements including:

• Consumer Protection Code
• Insurance Distribution Regulations 2018
• Consumer Insurance Contracts Act 2019
• Minimum Competency Code
• Fitness and Probity Standards
• Data Protection legislation
• Applicable Anti-Money Laundering legislation

We are committed to acting honestly, fairly and professionally in accordance with the best interests of our customers.

4. Our Services

We are authorised to advise on and arrange general insurance products including:

• Motor Insurance
• Household Insurance
• Commercial Insurance
• Farm Insurance
• Liability Insurance
• Property Insurance
• Motor Trade Insurance
• Personal Accident Insurance
• Other General Insurance Classes

A list of insurers and product providers with whom we hold agency appointments is available upon request.

5. Fair and Personal Analysis

Where we provide advice, we do so on the basis of a fair and personal analysis of the market.

This means we consider a sufficiently large number of insurance contracts and providers available within the relevant market to enable us to recommend a product suitable to your needs.

Before making a recommendation, we will gather sufficient information regarding your circumstances, requirements and objectives.

6. Demands and Needs

Before arranging an insurance policy, we will establish your demands and needs and provide appropriate information regarding the product recommended.

It is important that you provide complete, accurate and up-to-date information at all times to enable us to assess your requirements properly.

7. Communication

We may communicate with you by:

• Letter
• Email
• SMS
• Telephone
• Other durable electronic media

Where you provide an email address or mobile number, you consent to receiving communications electronically unless you instruct us otherwise.

Electronic communications may not always be secure. We recommend that sensitive personal or financial information should not be sent by unsecured email.

8. Vulnerable Customers

We recognise that some customers may experience circumstances that make them vulnerable.

Where we identify, or you inform us, that you may require additional support, we will take reasonable steps to adapt our services and communications to meet your needs and ensure you can make informed decisions.

If you believe you require additional assistance, please contact us.

9. Conflicts of Interest

Our objective is to avoid conflicts of interest whenever possible.

Where an unavoidable conflict arises, we will disclose the nature of the conflict to you before undertaking business and will take all reasonable steps to ensure your interests are protected.

A copy of our Conflict of Interest Policy is available upon request.

10. Remuneration and Charges

We are remunerated by a combination of:

• Commission paid by insurers or product providers
• Fees charged directly to clients
• Administration charges
• Premium finance commissions where applicable

Details of all remuneration arrangements are available on our website and will be disclosed in accordance with applicable regulatory requirements.

A current Schedule of Fees forms part of these Terms of Business.

All fees become due when the relevant service is provided unless otherwise agreed.

Fees are non-refundable unless otherwise required by law.

11. Premium Handling

Premiums are due on or before inception, renewal or amendment of cover.

We accept payment by:

• Electronic Transfer
• Debit Card
• Credit Card
• Cheque
• Cash (subject to regulatory and anti-money laundering restrictions)

Failure to pay premiums when due may result in cancellation, lapse or suspension of insurance cover.

It remains your responsibility to ensure payment has been received and cover remains in force.

12. Premium Finance

Where requested, we may assist in arranging premium finance through third-party providers.

As a credit intermediary we may receive remuneration from finance providers.

Full details of any finance agreement, charges, interest rates and fees will be disclosed before you enter into any finance arrangement.

13. Anti-Money Laundering Requirements

To comply with anti-money laundering legislation we may request documentation to verify:

• Identity
• Address
• Source of funds
• Source of wealth where appropriate

Failure to provide requested information may delay or prevent us from providing services.

14. Claims

You must notify us immediately of:

• Any claim
• Any incident that may give rise to a claim
• Any circumstance which could affect an existing claim

You must provide all relevant information and cooperate fully with insurers and loss adjusters during the claims process.

Failure to notify claims promptly may prejudice your rights under the policy.

Outsourced Claims Management We have outsourced the provision of claims management services to Motorists Insurance Services Ltd (MIS), who act on our behalf in the administration and management of insurance claims. MIS will be your primary point of contact for claims handling and will liaise with insurers and other relevant parties to progress your claim. Britton Insurance remains responsible for the insurance distribution services we provide, while the settlement of claims remains the responsibility of the relevant insurer and is subject to the terms and conditions of the applicable policy.

15. Complaints Procedure

We are committed to maintaining the highest standards of service.

Complaints may be made:

In writing to:
The Compliance Officer
Pat Britton & Co Ltd
Crennan House
Tirconaill Street
Donegal Town
Co Donegal

Or by email: admin@brittoninsurance.com. We will acknowledge complaints promptly and investigate them fairly, consistently and within regulatory timelines.

If you remain dissatisfied with our final response, you may refer your complaint to:

Financial Services and Pensions Ombudsman
Lincoln House
Lincoln Place
Dublin 2
D02 VH29
Telephone: 01 567 7000
Email: info@fspo.ie
Website: www.fspo.ie

Your legal rights remain unaffected.

16. Consumer Insurance Contracts Act 2019

Where you are a consumer, your rights and obligations are governed by the Consumer Insurance Contracts Act 2019.

You must:

• Answer all questions honestly and with reasonable care.
• Review all proposal forms and statements of fact carefully.
• Notify us of any changes in circumstances.
• Cooperate with insurers during claims investigations.

Insurers may only rely on non-disclosure or misrepresentation in accordance with the provisions of the Act.

Full details of your rights are available upon request.

17. Non-Consumer Commercial Clients

Where you are a commercial client and are not a consumer for the purposes of the Consumer Insurance Contracts Act 2019, you remain under a duty to disclose all material facts.

Failure to disclose material facts may result in:

• Cancellation of cover
• Claims being declined
• Difficulty obtaining insurance in future

If in doubt, disclose the information.

18. Data Protection

We are committed to protecting your personal data and processing it lawfully, fairly and transparently.

Personal data is processed for purposes including:

• Insurance broking services
• Policy administration
• Claims handling
• Regulatory compliance
• Fraud prevention
• Legal obligations

You have rights including:

• Access
• Rectification
• Erasure
• Restriction of processing
• Data portability
• Objection to processing

Our Privacy Notice is available on our website and upon request.

You may contact us regarding data protection matters at: dataprotection@brittoninsurance.com

You also have the right to lodge a complaint with the Data Protection Commission.

19. Call Recording

Telephone calls may be recorded and monitored for:

• Quality assurance
• Staff training
• Fraud prevention
• Complaint investigation
• Regulatory compliance

Recordings will be retained in accordance with our data retention policies.

20. Compensation Arrangements

We are members of the Investor Compensation Scheme established under the Investor Compensation Act 1998.

Compensation may be payable where client monies or assets cannot be returned and where eligibility criteria are met.

Compensation is subject to statutory limits applicable at the relevant time.

We are also members of the Brokers Ireland Compensation Fund.

Further information is available on request.

21. Cyber Fraud Warning

Criminals increasingly target financial transactions through email fraud.

We will never advise changes to our bank account details solely by email.

You should independently verify any request to amend payment instructions by contacting our office using known contact details before making any payment.

22. Regular Reviews

Insurance needs change over time.

You should review your insurance arrangements regularly and notify us of any changes to your circumstances.

Failure to do so may result in inadequate insurance protection.