Welcome to Utmost PanEurope Online
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WEBSITE TERMS OF USE
(“TERMS OF USE”)
GENERAL:
This Site is hosted by Utmost Services Limited under number 059248C of Royalty House, Walpole Avenue, Douglas, Isle of Man IM1 2SL and is a service provided jointly by Utmost Limited and Utmost PanEurope dac to promote their respective product propositions. Details of each company are set out below.
Utmost Limited (“Utmost Limited”) is a company limited by shares. Registered in the Isle of Man under number 056473C. Registered office: Royalty House, Walpole Avenue, Douglas, Isle of Man, IM1 2SL, British Isles. Utmost Limited is authorised by the Isle of Man Financial Services Authority. Details about the extent of Utmost Limited’s authorisation by the Isle of Man Financial Services Authority are available upon request. Utmost Limited is a member of the Association of International Life Offices and a member of the Manx Insurance Association (MIA).
Utmost PanEurope dac (“Utmost PanEurope”) is a designated activity company. Registered in Ireland under number 311420. Registered office: Navan Business Park, Athlumney, Navan, Co. Meath C15 CCW8, Ireland. Utmost PanEurope is authorised by the Central Bank of Ireland.
Utmost Limited and Utmost PanEurope, are, in these Terms of Use where the context permits, referred to collectively as “Utmost”.
ACCESS TO UTMOST WEB PAGES AND THE APPLICABLE UTMOST ENTITY FOR THESE TERMS OF USE
As you navigate and access pages on the Site, you will be able to access content about Utmost and, where relevant, the products made available by the respective licensed product providers, for which:
(i) Utmost Limited and Utmost PanEurope are responsible jointly, where it contains generic statements which are not product specific;
(ii) Utmost Limited is responsible exclusively and relates to its specific product range;
(iii) Utmost PanEurope is responsible exclusively and relates to its specific product range.
These Terms of Use will apply between you and the respective product provider whose product pages you choose to review or with whom you already hold a product and you log-in to see relevant details relating to your product. Some of these Terms of Use are, where indicated, specifically for Utmost Limited and Utmost PanEurope as applicable. The remaining Terms of Use are generic and apply to either company whose website pages or login area you access.
DEFINITIONS:
(i) “Utmost” (including “we” or “us”) where the context permits means either or both Utmost Limited or Utmost PanEurope depending on which entity is responsible for the part of the Site which you choose to view.
(ii) “Utmost Group” means either Utmost Limited or Utmost PanEurope, their respective subsidiaries, their holding company or any subsidiary thereof depending on the part of the Site which you choose to view (“subsidiary” and “holding company” have the meanings given in section 1 of the Isle of Man Companies Act 1974 (as amended) and in section 7 and section 8 respectively of the Companies Act 2014 of Ireland (as amended) where appropriate).
(iii) “Utmost Wealth Solutions” is the brand name used by a number of Utmost companies.
(iv) “Client” means a private customer, a retail customer or a retail client.
(v) “Intermediary” means a person or entity which has terms of business with Utmost, directly authorised by or registered with the UK Financial Conduct Authority or other acceptable regulatory authority with appropriate permissions to act as agent to private and/or retail customers.
(vi) “You” or “yourself” or “your” means the user of this Site being either a client or an intermediary as appropriate.
COMPLAINTS
If you have any complaints in respect to the parts of this Site provided by Utmost Limited please write to: Customer Experience, Utmost Limited, 2nd Floor, Royalty House, Walpole Avenue, Douglas, Isle of Man IM1 2SL, British Isles.
If you have any complaints in respect to the parts of this Site provided by Utmost PanEurope please write to: Utmost PanEurope, Navan Business Park, Athlumney, Navan, Co Meath C15 CCW8, Ireland.
The information on this Site is provided for information purposes only and none of the information constitutes an offer to contract.
APPLICABLE LAW
The use of this Site in respect to any part of it provided by Utmost Limited is governed by the law of the Isle of Man and the Isle of Man courts shall have exclusive jurisdiction in respect of any dispute.
The use of this Site in respect to any part of it provided by Utmost PanEurope is governed by the law of the Republic of Ireland and the Irish courts shall have exclusive jurisdiction in respect of any dispute.
Any waiver of such jurisdiction shall be at the discretion of the respective company as applicable. Such discretion to be exercised reasonably.
AVAILABILITY:
(i) We will endeavour to ensure that the Site is accessible for 24 hours a day. However, we will not be liable if, for any reason, the Site is unavailable at any time or for any period.
(ii) To the fullest extent permitted by applicable law we will not be liable for any loss or damage arising in contract, tort or otherwise if the Site becomes unavailable or is suspended for any reason.
INFORMATION
Full product details are contained in the relevant product guide, key features document and policy documentation, copies of which can be obtained via an intermediary or directly from us. A decision to invest should not be made on the basis of this Site alone. If there is any conflict between the details given on this Site and the relevant literature applicable to any products offered or insurance contract written by us then, the product literature and policy documentation will be regarded as the authoritative documents.
The tax efficiency of bonds issued by Utmost Limited in the Isle of Man or Utmost PanEurope in Ireland may change and their value depends on the investor’s circumstances.
The information contained on this Site does not constitute investment advice, legal advice or tax advice and investors are strongly advised to obtain their own professional advice.
The information and features of this Site do not constitute any form of advice or recommendation by us and are not intended to be relied upon by users in making (or refraining to make) any specific investment decisions.
Information contained on this Site is provided for information purposes only and we will use all reasonable endeavours to ensure that it is accurate at the date of publication.
Due to the nature of the internet, there may be circumstances in which errors or omissions in the information may occur which are beyond our reasonable control. For example unauthorised access by a third party. Consequently, Utmost will not be liable for loss or damages arising whether for loss of income or revenue, profits, anticipated savings or, in contract, tort or otherwise, directly or indirectly from the use of or reliance upon any information contained on the Site, unless the accuracy of the information has been checked with us before reliance is placed upon it.
Valuations shown on the Site are the latest bid values (mid-market for shares if applicable). We have and take no account of any surrender charges that may be incurred when surrendering the investment. It is assumed that all premiums due have been paid.
Please remember that the value of unit-linked funds can go down as well as up. There is no guarantee of the ultimate value of any investment (except where stated) or how much ‘income’ it can provide. The word ‘income’ refers to the regular payments of capital.
Past performance is not a guide to future performance.
Taking into account market fluctuations, currency fluctuations and initial charges, investors may not get back as much as they have invested.
SECURITY AND AUTHORITY
We will take all reasonable steps to ensure that personal information is disclosed only to those specified by you or as otherwise set out in these Terms of Use. However, the internet is an open system and we cannot and do not guarantee that the personal information you have entered will not be intercepted by others and decrypted.
If you should choose to use a digital certificate to identify yourself to the Site (after registering it with the Site) then the responsibility for the security and management of that certificate is entirely with you. Utmost accepts no responsibility in managing the certificate nor can we be held responsible should the security of the digital certificate be compromised.
Utmost accepts no responsibility for transactions carried out using your ID and password provided to or chosen by you in connection with the use of this Site and/or digital certificate, whether or not the transaction is made by you or someone else using your ID and password and/or digital certificate. You are responsible for protecting and securing your ID and password and/or digital certificate from unauthorised use. If you believe there has been a breach of security you should contact us immediately.
You authorise Utmost to act upon all instructions received in respect of your account via the Site when your ID and password are used and which appear to Utmost to have been issued by you. Instructions given by you for a joint account are binding on all other joint account holders.
LIABILITY
The Site also contains hypertext links to other websites. The responsibility for those sites is that of the parties who are identified as providing those sites and we accept no responsibility for them or their use or the content of any other site.
Utmost cannot warrant that this Site is free of viruses or technical defects of any description and will not be responsible for any technical problems arising from the use of this Site.
Utmost reserves the right to change the content, presentation, user facilities and availability of any part of the Site at our sole discretion.
If you are an intermediary you agree to:
Accept responsibility for ensuring that the documents produced by you for use by clients and/or Utmost are accurate and complete.
Not use any hypertext links or documents on the Site so as to mislead a client or Utmost in any way about the content of the Site or a particular document. The intermediary agrees to indemnify Utmost for any loss arising as a result of the misuse of any hypertext links.
Accept responsibility for any damages (including, without limitation, damages for loss of business or loss of profits) arising in contract, tort or otherwise from your inability to use or incorrect use of any material on this Site.
Fully indemnify Utmost for any losses, claims, costs or expenses suffered by the Utmost Group as a result of the intermediaries’ breach of this liability clause.
Utmost will not pass on your email address to any third party without your permission.
Occasionally we will email you to keep you up to date with new developments on the Site. In every email we send we will include instructions on how to unsubscribe so that you will not receive future emails. You may change your email address at any time and this can be updated on the Site.
COPYRIGHT AND OTHER INTELLECTUAL PROPERTY RIGHTS
Utmost owns or is the licensee of the copyright and all other intellectual property rights subsisting in its databases made accessible via the Site and all material on this Site.
You are not permitted to download, redistribute or extract any information on this Site in whole or in part other than that information relating directly to your portfolio or insurance policy issued by Utmost, or, if you are an intermediary, to your client’s portfolios.
As an intermediary you agree:
Not to use any documents or related graphics appearing on the Site for any reason other than conducting business with any of the companies in the Utmost Group.
Not to modify or amend any document or related graphics which are available on the Site in any way other than for the purpose of completing the variable permitted within the particular document, for example the inputting of personal data relating to individual clients.
Not to reproduce or store any documents or other information contained on the Site in any manner whatsoever, other than the documents produced as a result of conducting business with any of the companies within the Utmost Group and instruments, orders, regulations and Codes of Practices (whether or not having the force of law) which may apply to that business.
To print the documentation in the form it appears on the Site for the purposes of conducting business with any of the companies within the Utmost Group only and not to part print any information or documents, including the accompanying logos, appearing on the Site.
Not to use any graphics which appear on the Site separately from the accompanying text.
That copyright and any other rights in the material available on the Site are owned or licensed by members of the Utmost Group.
AMENDMENT OF USE
PRIVACY STATEMENT AND COOKIES
We use the information you give us, about yourself and other people, to provide the products and services you request and to operate and improve the Site. In order to support those products and services and the Site, we transfer information between different entities within the Utmost Group and to appointed data processors, but we do not transfer information to other parties, unless required to do so by law or regulation. Unless specified in the applicable privacy notice and privacy statement (referenced below), we do not carry out marketing using the information or transfer, or sell, your personal information to others for marketing purposes.
You may choose to use some of the hypertext links to other sites that are set out in this Site. Some of those sites may be restricted and require the completion of further information by you. You are responsible for the accuracy of your personal information.
Utmost sends cookies to your computer from this Site when you are logged in. The cookies transferred by Utmost are only used for enabling your logged in session to work smoothly and to track your usage of this Site. They store only an internal ID and tracking information and are not used for any other purposes. You may alter the cookies setting in your browser to prevent cookies from being transferred to your computer, but please be aware that if you do this you will not be able to use our secured Site.
Utmost has a comprehensive Cookies Policy which you may access here.
More details about how we use your information, your rights over this information and how you can exercise your rights can be found in the Utmost Limited or Utmost PanEurope Privacy Notice(s) which you may access here.
Utmost will endeavour to protect any information that the intermediary inputs into this Site, however the internet is not necessarily a secure system and the privacy of the intermediary and/or its clients cannot be guaranteed. Utmost shall not be liable for any damages resulting from the misuse of personal data supplied by the intermediary on the internet. If you are in any doubt, you should not input any data.
YOUR ACCEPTANCE OF THESE TERMS
The EU General Data Protection Regulation (GDPR), introduced on 25 May 2018, sets out how your personal data (information that is personally identifiable such as your name, address or email address) can be used in a lawful manner. GDPR also gives you new rights in relation to your personal data.
Utmost Wealth Solutions is committed to ensuring the security and confidentiality of the information you give us, about yourself and other people, which we use to provide our products and services, including online services. Details about how we use your information, your rights over this information and how you can exercise your rights can be found in the Privacy Notice(s) for the group of Utmost companies, which you can access via the following links.
This privacy statement explains how we collect, use and share our customer’s personal information. If you have any questions, please contact us using the details provided at the end of this document.
Utmost Ireland designated activity company (“Utmost Ireland”) trading as Utmost Wealth Solutions is authorised by the Central Bank of Ireland and regulated by the Financial Conduct Authority in the UK for Conduct of Business Rules. Utmost Ireland is a leading provider of international savings, protection and investment solutions. Utmost Ireland is part of the Life Company Consolidation Group (“LCCG”) which is specialist company operating in the European life assurance sector.
As our customer you provided us with certain information and entered into a contract with us to issue you with a policy and provide you with ongoing services. Some examples of how we use your information are:
(1) To administer your contract/policy with us
Reviewing transactions and correspondence to enable us to deal with your queries
Managing and administering your policy in accordance with your terms and conditions
Contacting you to deal with your transaction requests including applications for new policies, additional premiums, full and partial surrenders where applicable
Managing our relationship with you (for example, updating you on changes to our business or updating your record with us if you change your address)
Responding to any complaints you make
(2) To meet legal and regulatory obligations
As a regulated life assurance company we are required to comply with a range of different legal obligations such as tax reporting, data protection and financial crime prevention. Sometimes we have to share your information with regulatory authorities, for example:
Sharing information with Financial Services Ombudsmen in relation to complaints you make
Reporting information to tax authorities including, for example, reporting under the Foreign Account Tax Compliance Act (“FATCA”) and Common Reporting Standard (“CRS”) requirements
Meeting obligations we have in relation to the prevention and detection of crime such as money laundering, the reporting of suspicious transactions and requirements to check our records against financial sanctions lists and report matches.
(3) To improve our business
From time to time we may request feedback from our customers in order to improve the service we offer, for example by conducting customer satisfaction surveys.
We will only communicate with you to share important information about your policy or changes to our business. We will not conduct any marketing activity with you without your explicit consent to do so.
We will only collect, use and share your information where we have a valid reason to do so under data protection legislation. We have four main reasons for collecting and using your information which are set out below. Often we will need your information for more than one reason, for example, in order to perform a contract and to meet a legal obligation.
(1) Group companies
We use more than one company in our group to deliver our products and services to you. We may share your data with other LCCG companies as part of our commitment to offer you financial products and services that may be of interest to you. We may also share your data with other LCCG companies in order to meet with our legal obligations.
(2) Service Providers
We use third party companies to provide services so we can administer your policy and deliver a service to you; for example, customer service providers or IT system companies that hold or analyse your information and carry out searches that help us trace you if we have lost touch.
(3) Reinsurers
A reinsurer is another insurance company who takes on the risk of when and how much we have to pay customers on their policy. Like other insurance companies we use reinsurers to help us manage our risk.
(4) Anyone you ask us to share your information with
If you ask us to share your information with a third party we will. For example, with a financial adviser, solicitor etc. If a third party asks for your information, we will check with you to confirm that we have your authority to release it.
(5) Other parties
As outlined above, under “What your information is used for” we have a legal obligation to provide information from time to time to regulatory bodies such as tax authorities, law enforcement agencies and Ombudsmen.
(6) Professional advisers
We use professional advisers to provide services to us, for example legal advice, accountancy services and consultancy services.
(7) Courts and those involved in any legal process
If a court requires us to disclose your information or if it needs to be disclosed as part of a legal process.
(8) Anyone in the future who may buy or merge with our business
If we merge with another company or are sold to another organisation then we will need to share your information with them.
We are based and operate primarily in Ireland. However, information that we collect from you in Ireland may be viewed from, transferred to, or stored, outside the European Economic Area (EEA).
We ensure that we put in place appropriate safeguards when we allow your information to be processed outside the EEA.
We do not keep your information for longer than is necessary. Different information will need to be held for different periods of time; this may be due to a variety of reasons including legal obligations and to enable us to provide you with a good level of customer service.
We try not to ask you for personal information that we don’t need. If we ask you for personal information that seems unnecessary to you, please contact our Customer Services team for an explanation.
If you do not provide certain information we may not be able to provide our service to you; for example, if you don’t provide the information requested on a surrender form we may not be able to process your surrender.
We have set out a summary of your key rights below, but have not included all the circumstances or conditions which apply to them. If you have any questions on your rights, you can contact our Customer Services team for help.
Right to stop us using your information – if you don’t want us to use your information for our business interests you can ask us to stop and we will do so unless there is an important reason why we need to continue using it.
Right to stop us marketing to you – you can ask us not to send you marketing messages.
Right to access your information – you have the right to ask for a copy of the information that we hold about you and this will usually be provided free of charge. For your security, we will take reasonable steps to confirm your identity before providing you with any personal information we may hold about you.
Right to transfer your information – you can request that we transfer certain information we hold about you to you or to a third party in electronic form.
Right to ask us to delete your information – in certain circumstances you can ask us to stop using or holding your information. If we can delete your information we will, but sometimes we have to maintain records for legal reasons. If we cannot comply with your request, then we will contact you and explain why. If you ask us to stop using your information we will still keep it where we are legally obliged to, but we will not use it for other purposes.
Right to give or withdraw your Consent – if you have given consent for us to use your information then you have the right to withdraw your consent at any time. However, if you do withdraw your consent we may not be able to continue to provide the product or service you have contracted us to provide; for example, if you withdraw consent to use health information you provided in a claim form we may not be able to process your claim.
If we have shared the personal information in question with another company (including another company within the LCCG group), we will also let them know that you have asked us to stop using or keeping your information unless it is very difficult or not possible for us to do so.
It is important that the information we hold about you is accurate and up to date. Please let us know if your information changes, or if the information we hold about you is incorrect. You can ask our Customer Services team to update or correct your information.
If we have disclosed the personal information in question to another company (including another company within the group), we will also let them know about the changes unless it is very difficult or not possible for us to do so.
We may change this privacy statement from time to time to keep it up to date, or to comply with legal requirements. In that case a revised version of this privacy statement will be uploaded to our website.
If you have any questions or concerns about our use of your information or would like a copy of the information we hold about you, please contact our Customer Services team on the details below, marking your query for the attention of our Data Protection Office:
Name: Utmost Ireland dac
Address:
Ashford House
Tara Street
Dublin 2
D02 VX67
Ireland
Email: info@utmostwealthsolutions.ie
Phone: 0845 6029281
If you are unhappy with any aspect of the service we provide, please let us know using the Customer Services team details above.
You also have the right to complain to the Data Protection Commissioner, contact details as follows:
Telephone:
+353 57 8684800
+353 (0)761 104 800
Lo Call Number: 1890 252 231
Fax: +353 57 868 4757
E-mail: info@dataprotection.ie
Postal Address:
Data Protection Commissioner
Canal House
Station Road
Portarlington
R32 AP23 Co. Laois
This Privacy Notice explains how Utmost Limited and Utmost Trustee Solutions Limited as part of the Utmost Isle of Man Group (together ‘Utmost’ and the ‘Utmost Isle of Man Group’ or ‘our’, ‘us’ and ‘we’ as the context shall permit) hold, control and process your personal data. If you have any questions you can contact us using the details provided at the end of this notice.
This website is hosted by Utmost Services Limited ("Utmost Services") on behalf of Utmost Limited and Utmost PanEurope dac (both companies referred to herin as "Utmost"). The companies are ultimately responsible for content which relates solely to their company and products. Please see the Terms of Use for more information and the relevant company and regulatory information. Here is our cookie policy for this website and the types of cookies we use on it. The cookies are held by Utmost Services on behalf of Utmost.
What are Cookies?
Cookies are small files that websites place on the device you’re using to browse the website. Cookies are commonly used to record some aspect of your visit to a website, such as choices you’ve made or preferences you’ve set during your visit.
How and why we use Cookies
We use cookies to give you the best experience when you visit our website. By using cookies, we can make it easier for you to do many things, such as managing your accounts, policies, or login details, and applying for products and services. Cookies can also allow us to tailor the content of our website so we can show you services or adverts we think you may be interested in.
Keeping your personal information safe
Our cookies do not store personal information such as your name, address, phone number or email in a format that can be read by others. The cookies we use cannot read or search your computer, smartphone or web-enabled device to obtain information about you or your family, or read any material kept on your hard drive.
We do use a small number of cookies that store encrypted versions of information where you have asked us to, such as the ‘Remember me’ function that allows us to remember your Account username for subsequent visits. However, this is encrypted so that only Utmost can read this information. The website that places a cookie owns that cookie. This means only that website and other websites that it has agreed to share information with can read the information stored using a cookie.
Links to sites provided by others
If you follow a link from our website to another website, please be aware that the owner of the other website will have their own privacy and cookie policies for their site. We recommend you read their policies as we are not responsible or liable for what happens at their website.
How to manage and switch off cookies
Your web browser provides settings that allow you to manage or switch off cookies. If you do switch off cookies, remember that you may not be able to use all of the services on our websites. You can find out more about managing and switching off cookies at the independent website: allaboutcookies.org
The types of cookies we use on this website
Strictly necessary Cookies
These cookies are essential for our online services and tools to work. They collect or record information that we need to make our website work. Common uses for this type of cookie include:
storing information so that shopping baskets can be provided
storing information for e-billing
allowing users to log in or access private areas of a website.
These cookies only last for a single browsing session – when you leave our website, they are removed.
Performance Cookies
These cookies help us to monitor and improve how our website works.
Common uses for this type of cookie include:
collecting information about which pages visitors go to most often
noting if visitors get any error messages from webpages
understanding which links visitors like to follow (including adverts) and which they choose not to.
The information collected using these cookies is anonymous and cannot be used to identify an individual visitor.
Functionality Cookies
These cookies allow us to provide you with enhanced features that need to remember your preferences and choices, such as your user name, language or region. They also let us monitor how our website is performing so we can keep on improving it.
Common uses for this type of cookie include:
providing you with local information, such as health providers in your area
remembering how you like to use our site, such as what text size you like or what media software you use
remembering what topics you’re interested in so we can provide you with related products, services and information.
The information we store in these cookies is encrypted so that only we can read it.
Utmost Services Limited has a UK office at: Saddlers House, 5th Floor, 44 Gutters Lane, London, EC2V 6BR. Registered branch number BR018821.
The following company is registered in Ireland. Utmost PanEurope dac (No 311420) is authorised by the Central Bank of Ireland. Registered office: Navan Business Park, Athlumney, Navan, Co. Meath C15 CCW8, Ireland.
Contact Details
Telephone: 0845 602 9281
Email: info@utmostwealthsolutions.ie
Web: www.utmostwealth.com
Telephone calls may be recorded.
The Utmost Group is committed to working towards the eradication of slavery and human trafficking.
We are a global provider of insurance and savings solutions in the UK and Internationally. The Group is owned by its two Founders and a number of funds managed by Oaktree Capital Group LLC. Further details of our ownership structure are available in the Governance section of our Annual Report, available online at www.utmostgroup.co.uk.
This is the Utmost Group’s first combined statement on its approach to modern slavery following the completion of a corporate reorganisation whereby the Company became the holding company of the Utmost Group. Previously, each of the Group’s International and UK businesses issued a statement made in accordance with the Modern Slavery Act 2015 (the “Act”). As a business that places corporate and social responsibility at the heart of its values, the Utmost Group recognises that respecting human rights is the right thing to do and ensures the appropriate actions are taken to manage risks relating to modern slavery.
This statement sets out the steps taken by the Utmost Group or actions underway during the financial year ended 31 December 2020 to date, to assist in the detection and prevention of modern slavery across its business operations and supply chains.
The Utmost Group is a leading provider of insurance and savings solutions. It was formed through the consolidation of life assurance businesses, and provides modern, flexible solutions which assist our customers in securing their financial futures. The Group has over 950 employees predominantly based in the UK, Ireland, the Isle of Man and Guernsey, with a small number of staff working in branch operations in Singapore and Hong Kong, and at a distribution office in the Dubai International Finance Centre.
We are committed to preventing modern slavery or human trafficking in our supply chains or in any part of our business. The Group is committed to conducting business responsibly and upholding the highest standards of governance throughout our operating businesses. During 2021 the Group has implemented a Group Corporate Governance Manual and Policy Suite framework which alongside this statement contains relevant policies, such as our Corporate Social Responsibility Policy, and Outsourcing Management Policy, which sets out the necessary principles to manage and mitigate key risks and safeguard the business and all its stakeholders, including employees, suppliers, and customers.
The Group’s approach to human rights extends beyond our supply chain, to employees and contracted staff and we are committed to paying the national living wage in the UK. The system of internal controls implemented by our operating businesses includes: -
Protecting employees and whistle blowers
Identifying and assessing potential risk areas in our supply chains.
Mitigating the risk of slavery and human trafficking occurring in our supply chains.
We follow the principles of good corporate governance and Enterprise Risk Management and do not tolerate any malpractice, whether committed by senior managers, employees, suppliers, or contractors acting on our behalf.
A new Group Code of Conduct (“Code”) is being developed that will apply to all directors, officers, and employees, requiring that they adhere to the Code. Our employees are encouraged to report any practices or actions where they believe these to be inappropriate or inconsistent with the Code or that may compromise the ethical standards or integrity of the organisation.
The Group Whistleblowing Policy sets out requirements for reporting inappropriate, unethical, or otherwise activities that are inconsistent with the Code. This policy enables an employee to report any improper conduct or unethical behaviour via line management, senior management, the relevant Chief Risk Officer, Company Secretary, Head of HR or Chair of the Audit Committee. This Policy and the associated Guidance Notes are communicated to all employees at least annually and are easily accessed. Where employees feel that they cannot raise a concern with these individuals, they may make contact on a confidential basis with the Chairman of the local Audit Committee, after which their report will be investigated and considered by the Non-Executive Directors of the relevant subsidiary company.
Employees may also raise their concerns with the Chairman of the Audit, Risk and Compliance Committee of Utmost Group Limited or if they deem it necessary, employees may wish to contact the applicable external regulator. At all times during any investigation the Whistleblower’s identity will be kept confidential. All employees are reminded annually of their right to raise concerns under the Whistleblowing Policy, and to consult with associated guidance.
It is important to us that our commitment to human rights is shared by our suppliers. The Utmost Group accepts a range of goods and services from suppliers located across the globe, although the majority of suppliers have their operations locally (in the Isle of Man, Ireland or Guernsey) or the United Kingdom. Goods and services utilised by the Utmost Group and its subsidiaries primarily consist of investment services, catering, cleaning, office furniture and stationery, electrical equipment, IT software, property maintenance and utilities. As the Utmost Group businesses operate in the financial services sector, the risk of being exposed to modern slavery is considered lower than in other industries. However, we recognise that financial services firms cannot be complacent as to the risks that exist in their supply chains and a risk-based approach is taken to identify any high risk suppliers and prioritise them for review.
Where we enter into or renew a contract with a supplier, we will negotiate terms to include standard contractual obligations seeking to ensure that the supplier confirms they have adequate training and policies in place to comply with the act and avoid slavery.
There is a commitment throughout the Group to ensure that we respect human rights and continue to act as a responsible business. To achieve this, we have developed a Group Corporate Social Responsibility Policy and will ensure all employees of the Utmost Group will be provided with ongoing training to ensure that there is the appropriate level of awareness and consistency across the entire business to detect and ultimately prevent modern slavery from occurring anywhere in our supply chain.
This statement has been approved by the Board of Utmost Group Limited and signed on its behalf by the Utmost Group CFO.
Ian Maidens
12 May 2020
Utmost Wealth Solutions is the trading name used by a number of Utmost companies. Utmost Trustee Solutions is the trading name used by Utmost Trustee Solutions Limited. This term has been issued by Utmost Limited, Utmost PanEurope dac and Utmost Trustee Solutions Limited.
The following companies are registered in the Isle of Man: Utmost Limited (No 056473C), Utmost Administration Limited (No 109218C) and Utmost Trustee Solutions Limited (No 106739C), which are regulated or licenced by the Isle of Man Financial Services Authority. Utmost Services Limited (No 059248C) is an appointed representative of Utmost Limited. Each has its registered office at: Royalty House, Walpole Avenue, Douglas, Isle of Man, IM1 2SL British Isles.
Utmost PanEurope dac (No 311420), trading as Utmost Wealth Solutions, is regulated by the Central Bank of Ireland. Its registered office is Navan Business Park, Athlumney, Navan, Co. Meath C15 CCW8, Ireland.
Where required, all promotional material has been approved by Utmost Limited which is authorised in the UK by the Financial Conduct Authority.