Effective Date: 2nd March 2026

Introduction
These Terms of Business set out the general terms under which Clarity Financial Planning Limited (hereafter “Clarity Financial” or “we” or “us” or “our” or the “firm” or the “Company”) will provide business services to you and the respective duties and responsibilities of both the firm and you in relation to such services. This document contains details of the regulatory and statutory obligations and the respective duties of both the firm and you in relation to such services. It is intended to be clear and transparent in outlining our relationship with you. Any material changes to this document will be communicated to all affected clients in good time. Please take a few minutes to read through these and if you have any questions, we will be happy to answer same.

The full name and address of the firm and communication details are as follows:

Clarity Financial Planning Limited
Registered Office Address: 51 Bracken Road, Dublin, D18 CV48. Ireland
Email: Paul@clarityfinancial.ie
Mobile: 086 040 3548
Website: www.clarityfinancial.ie

Authorisation with the Central Bank of IrelandClarity Financial Planning Limited (C569099) is regulated by the Central Bank of Ireland as an insurance intermediary registered under the European Union (Insurance Distribution) Regulations 2018 and as an Investment Intermediary authorised under the Investment Intermediaries Act, 1995. Copies of our regulatory authorisations are available on request. The Central Bank of Ireland holds registers of regulated firms. You may contact the Central Bank of Ireland on 1890 777 777 or alternatively visit their website at www.centralbank.ie to verify our credentials.

Codes of Conduct
Clarity Financial Planning Limited is subject to the Consumer Protection Code, the Minimum Competency Code 2017, the Minimum Competency Regulations 2017 and the Fitness & Probity Standards which offer protection to consumers. These Codes can be found on the Central Bank’s website www.centralbank.ie

Our Services
Clarity Financial Planning Limited is a member of Brokers Ireland.

We provide advice and guidance in the areas of cashflow modelling regarding future financial planning in addition to the areas of investments, savings, pension planning pre and post planned retirement age, business associated protection cover and family protection.

Our principal business is to provide advice and arrange transactions on behalf of clients in relation to Life Assurance products including Life Assurance policies, Critical/Serious Illness, Income Protection, Pensions, PRSAs, ARFs, Savings and Investment products offered by insurance and investment companies.

Our client experience is paramount and we pride ourselves on building long lasting client relationships. We act as an intermediary or broker. This means that we will identify and select suitable products on a fair and personal analysis basis from insurers and on receipt of your instructions, we will transmit orders on your behalf to one or more product producers. This process applies to all classes of insurance policies. (See below under “Fair and Personal Analysis”). Clarity Financial Planning Limited does not have a tied relationship with any institution.

However, for certain types of pensions, savings and investment products, we will select suitable products on a limited basis (See below under “Limited Analysis”).

Our core beliefs are built around the Three Pillars of Clarity;

Clarity of Purpose – Defining and Understanding what our clients want and require

Clarity of Meaning – Ensuring our clients understand why our recommendations align with their objectives

Clarity of Action – Ensuring our clients understand how the goals can be achieved with guided financial planning

Fair and Personal Analysis
The concept of fair and personal analysis describes the extent of the choice of products and providers offered by an intermediary within a particular category of life assurance, general insurance, mortgages, and/ or a specialist area.  The number of contracts and providers considered must be sufficiently large to enable an intermediary to recommend a product that would be adequate to meet a client’s needs.

The number of providers that constitutes ‘sufficiently large’ will vary depending on the number of providers operating in the market for a particular product or service and their relative importance in and share of that market.  The extent of fair analysis must be such that could reasonably be expected of a professional conducting business, taking into account the accessibility of information and product placement to intermediaries and the cost of the search.  

In order to ensure that the number of contracts and providers is sufficiently large to constitute a fair and personal analysis of the market, we will consider the following criteria:

the needs of the customer,
the size of the customer order,
the number of providers in the market that deal with brokers,
the market share of each of those providers,
the number of relevant products available from each provider,
the availability of information about the products,
the quality of the product and service provided by the provider,
cost, and
any other relevant consideration.

Product Producers with whom we hold written letters of appointment are as follows:

• Irish Life Assurance plc

• New Ireland Assurance Company plc

• Zurich Life Assurance plc

• Aviva Life & Pensions Ireland DAC

• Standard Life International DAC

• Royal London Insurance DAC

Life, Serious Illness, Pensions and Income Protection

• We provide life assurance, serious/critical illness, income protection and pensions from life assurance companies on a fair and personal analysis basis i.e. providing services on the basis of a sufficiently large number of contracts and product producers available in the market to enable us to make a recommendation, in accordance with professional criteria, regarding which contract would be adequate to meet your needs.

• We will provide assistance to you for any queries you may have in relation to the policies or in the event of a claim during the life of the policy and we will explain to you the various restrictions, conditions and exclusions attached to your policy.

• However, it is your responsibility to read the policy documents, literature and brochures to ensure that you understand the nature of the policy cover; particularly in relation to Permanent Health Insurance (“PHI” or income protection) and serious illness policies.

• Specifically on the subject of PHI policies we will explain to you; a) the meaning of disability as defined in the policy; b) the benefits available under the policy; c) the general exclusions that apply to the policy; and d) the reductions applied to the benefit where there are disability payments from other sources.

• For a serious illness policy, we will explain clearly to you the restrictions, conditions and general exclusions that attach to that policy.

Savings & Investments

• We provide savings & investment products from life assurance companies on a fair and personal analysis basis.

• We can provide advice on investments and structured products in the event of considering an investment or reinvestment; we will outline the various options available to you, particularly in relation to the nature of the investment risk and/or other restrictions.

Limited Analysis
We provide professional advice in relation to certain types of pensions, savings and investments on a limited basis and can arrange to provide these products and services with the following product producers with whom we have a written appointment:

• Conexim Advisors Limited;

• Newcourt Retirement Fund Managers Limited

Sustainability Factors – Investment/IBIPs/Pension Advice
In accordance with the Sustainable Finance Disclosure Regulation (‘SFDR’), we inform you that when providing advice on insurance-based investment products/Investments, we do not assess, in addition to relevant financial risks, relevant sustainability risks as far as this information is available in relation the products proposed/advised on. This means that we do not assess environmental, social or governance events/conditions that, if they occur, could have a material negative impact on the value of the investment.

When providing advice on insurance-based investment products (‘IBIPs’) or investment advice we do not consider the impact of our advice that result in negative effects on sustainability factors (namely environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters), because these are currently limited to relevant products on the market which meet these criteria. The area of sustainability within the investment fund industry is still relatively new and as the issue progresses, we will review our position. The firm will review this approach on an annual basis in March 2027.

Impact on Return
We have not assessed the likely impacts of sustainability risks on the returns of Investment/Pensions since we have not been able to identify any sustainability risks that are relevant.

Statement of Charges
At Clarity Financial Planning Limited, we believe our clients should not only receive full disclosure of fees and charges but should also fully understand the levels of these fees and charges and the associated impact on you and your financial plan in advance of Clarity Financial arranging a product or service.

Clarity Financial Planning Limited will be remunerated for the services we offer you by one of, or a combination of the following means;

• By commission, fee or any other type of remuneration earned from Insurers and Product Producers to whom orders are transmitted. Summary details of these payments will be included in a product information document which you will receive.

• In addition, we may earn a non-monetary benefit which we will only accept if it enhances the quality of our service to you our client. For example: attendance at a product seminar or assistance with branding, IT support etc.

• By the investment managers as a shared management fee deducted from your investment and/or

• By you directly, in the form of a fee which we will discuss and agree in advance of the provision of advice, services or assisting in or executing transactions.

• Where we receive recurring commission, this forms part of the remuneration for initial advice provided. We reserve the right to charge additional fees if the number of hours relating to on-going advice/assistance exceeds 10 hrs.

• Where a fee is charged additionally and the company receives commission from a product provider, we shall explain if the commission will be offset against the fee either in part or full. Commissions received are not offset against fees unless agreed with the client in writing.

• Where we do not receive commissions from a product provider or where we provide advice only service we may charge a fee and will notify you of the fee basis in advance of any service being provided.

• We may receive regular renewal or trail commission while your product remains in force. All remuneration received contributes to the costs of the ongoing administration services we provide to you.

• As an alternative to commission based advice, you may choose to pay our remuneration in the form of fees, or we may agree a fee for services provided on a case-by-case basis.

• Fees are calculated on a time spent basis, at rates determined by the nature and complexity of the relevant work and the seniority of the personnel. These fees will range from €250 per hour for Directors and €100 per hour for Support Staff. However, in the event that a revised fee occurs, it will be set out in writing in advance of providing a service.

• Our comprehensive cashflow financial plan, a core element and basis for financial planning advice within Clarity Financial is available as a standalone service for an initial fee ranging from €2,000 to €2,500. This fee is payable in advance and is nonrefundable once planning work has begun. A review fee of €500 may apply, this however may be offset from ongoing renumeration/trail commission.

  Pursuant to Regulation 68 of the Consumer Protection Code, we must make available in our offices, a summary of the details of all arrangements for any fee, commission, other reward or remuneration provided to us which has been agreed with our product producers. Our Remuneration Document can be found displayed in our public offices and on our website (www.clarityfinancial.ie).

Personal Retirement Savings Accounts (PRSAs) – Fees
Where advice is requested for PRSAs, the following hourly fees will apply:

Advisor fees: €200 per hour.

Additional fees may be payable for complex cases or to reflect value, specialist skills or urgency. We will notify you in advance of providing you with these services.  Our scale of fees for such cases range may vary depending on the complexity and volume of work required. If we receive commission from a product provider, this may be offset against the fee which we will charge you.

Ongoing Remuneration
We wish to inform you that we receive ongoing remuneration from Product Providers in respect of the financial service provided to you. This remuneration is based on a percentage of the value of your investment, annual premiums and is intended to cover the ongoing service that we provide to you in relation to this product.

The nature of the service for which this remuneration is payable includes regular reviews of your product, updates on performance, and continued access to our advice.

Clawback
If we receive commission from a product provider but the commission is subsequently clawed-back by the provider because of early encashment by you or because of the transferring of the assets or business to another provider or in any circumstances consequent on your actions or omissions, we will charge a fee to you that is equal to 100% of the clawed-back commission. That fee will be owing in simple contract upon the claw-back of the commission.

Disclosure of Information

Consumer Insurance Contracts Act 2019 (‘CICA’)
This duty of disclosure applies to consumers as defined above in the Financial Services and Pensions Ombudsman Act 2017.

You are required to answer all questions posed by us or the insurer honestly and with reasonable care. The test will be that of the ‘average consumer’. The ‘average consumer’ per Directive No. 2005/29/EC of the European Parliament and of the Council of 11 May 2005, is one that is reasonably well informed and reasonably observant and circumspect, taking into account social, cultural and linguistic factors.

You are not under any duty to volunteer information over and above what is required to answer the questions posed to you. The questions we require you to answer are material to the risk to be undertaken by the relevant insurer, or the calculation of the premium by the relevant insurer, or both.

You will be required to answer specific questions. Where you do not provide additional information (after being requested to do so) it can be presumed that the information previously provided remains unchanged.

It is important that you answer all questions honestly and with reasonable care. Failure to do so may result in an insurer cancelling the contract, rejecting a claim or limiting the amount paid in the event of a claim only if it establishes that non-disclosure of material information was an effective cause of the insurer entering into the relevant contract of insurance and on the terms on which it did.

New Business
You may cancel a contract of insurance, by giving notice in writing to the insurer, within 14 working days after the date you were informed that the contract is concluded. This does not affect the notice periods already provided under European Union (Insurance and Reinsurance) Regulations 2015 or the European Communities (Distance Marketing of Consumer Financial Services) Regulations 2004 which is 30 days in respect of life policies, irrespective of whether the sale took place on a non-face to face basis.

The giving of notice of cancellation by you will have the effect of releasing you from any further obligation arising from the contract of insurance. The insurer cannot impose any costs on you other than the cost of the premium for the period of cover.

This right to cancel within the relevant cooling off period does not apply where, in respect of life insurance the contract is for a duration of six months or less.

The consumer is under a duty to pay their premium within a reasonable time, or otherwise in accordance with the terms of the contract of insurance.

A court of competent jurisdiction can reduce the pay-out to the consumer where they are in breach of their duties under CICA, in proportion to the breach involved.

Post-Contract Stage and Claims
An Insurer may refuse a claim made by a consumer under a contract of insurance where there is a change in the risk insured, including as described in an “alteration of risk” clause, and the circumstances have so changed that it has effectively changed the risk to one which the Insurer has not agreed to cover.

Any clause in a contract of insurance that refers to a “material change” will be interpreted as being a change that takes the risk outside what was in the reasonable contemplation of the contracting parties when the contract was concluded.

The consumer must cooperate with the Insurer in an investigation of insured events including responding to reasonable requests for information in an honest and reasonably careful manner and must notify the Insurer of the occurrence of an insured event in a reasonable time.

The consumer must notify the Insurer of a claim within a reasonable time, or otherwise in accordance with the terms of the contract of insurance.

If the consumer becomes aware after a claim is made of information that would either support or prejudice the claim, they are under a duty to disclose it. The Insurer is under the same duty.

If the consumer makes a false or misleading claim in any material respect (and knows it to be false or misleading or consciously disregards whether it is) the Insurer is entitled to refuse to pay and to terminate the contract.

Where an Insurer becomes aware that a consumer has made a fraudulent claim, they must notify the consumer advising that they are avoiding the contract of insurance. It will be treated as being terminated from the date of the submission of the fraudulent claim. The Insurer may refuse all liability in respect of any claim made after the date of the fraudulent act, and the Insurer is under no obligation to return any of the premiums paid under the contract.

Handling Clients’ Money
We do not hold money received in the course of providing insurance and investment services to our clients. Any money which we receive on your behalf will be forwarded to you or a named third party on your instructions. Any cheques or bank drafts should be made payable to a third-party provider as we are not authorised to hold client money.

Default on Payment by Clients
We will exercise our legal rights to receive payments due to us from clients (fees and insurance premiums) for services provided. In particular, without limitation to the generality of the foregoing, the firm will seek reimbursement for all payments made to insurers on behalf of clients where the firm has acted in good faith in renewing a policy of insurance for the client.

Product producers may withdraw benefits or cover in the event of default on payments due under policies of insurance or other products arranged for you. We would refer you to policy documents or product terms for the details of such provisions.

Receipts
Clarity Financial Planning Limited shall, pursuant to the Consumer Protection Code (as amended) and section 30 of the Investment Intermediary Act 1995, issue a receipt for each non-negotiable or negotiable instrument or payment received. These are issued with your protection in mind and should be stored safely.

Ongoing Suitability

Insurance based Investment Products
We will provide periodic assessments of the suitability of the insurance based investment product which we have recommended to you. 

Conflicts of Interest
It is the policy of our firm to avoid conflicts of interest in providing services to you. However, where an unavoidable conflict of interest arises, we will advise you of this in writing before providing you with any service.

Complaints
Whilst we are happy to receive verbal complaints, it would be preferable that any complaints are made in writing. We have a written procedure in place for the effective consideration and handling of complaints. Any complaint should be sent by email to paul@clarityfinancial.ie or by post to Paul Delaney, Clarity Financial Planning, 51 Bracken Road. Dublin. D18 CV48. Ireland

Any complaint that you may have in relation to the business services provided should be made in writing outlining the nature of your complaint. We will acknowledge your complaint in writing within 5 working days and we will fully investigate it. We shall investigate the complaint as swiftly as possible, and the complainant will receive an update on the complaint at intervals of not greater than 20 working days starting from the date on which the complaint is made.  On completion of our investigation, we will provide you with a written report of the outcome. In the event that you are still dissatisfied with our handling of or response to your complaint, you are entitled to refer the matter to the Financial Services and Pensions Ombudsman (FSPO). (contact details below).

Financial Services and Pensions Ombudsman
Lincoln House,
Lincoln Place 
Dublin 2

Phone: 01 567 7000
E-mail: info@fspo.ie
Website: www.fspo.ie

Data Protection
We are subject to the requirements of the General Data Protection Regulation 2018 (GDPR) and the Irish Data Protection Act 2018.

Clarity Financial Planning Limited is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client. 

The data will be processed only in ways compatible with the purposes for which it was given and as outlined in our Data Privacy Notice, this will be given to all our clients at the time of data collection. You have the right at any time to request a copy of any ‘personal data’ within the meaning of the GDPR that our office holds about you and to have any inaccuracies in that information corrected.

We will ensure that this Privacy Notice is easily accessible on our website (www.clarityfinancial.ie). If this medium is not suitable, we will ensure you can easily receive a copy by hard copy, or telephonic environment. (pre-recorded). 

Please contact us at info@clarityfinancial.ie if you have any concerns about your personal data.

Anti-Money Laundering and Countering the Financing of Terrorism
Clarity Financial Planning Limited reserves the right to request any information about a client which we need to know in order to comply with the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (as amended).

Governing Law and Jurisdiction
Our terms of business shall be governed by and construed in all respects according to the laws of the Republic of Ireland.

Vulnerable Clients
Where we have identified that a personal consumer is a vulnerable consumer, we must ensure that the vulnerable consumer is provided with such reasonable arrangements and/or assistance that may be necessary to facilitate him or her in his or her dealings with us. Identification of a consumer’s vulnerability or otherwise will require the exercise of judgement and common sense and should be based on a consumer’s ability to make a particular decision at a point in time. We consider that identification of a vulnerability should be an inherent part of the Knowing the Consumer (KYC) process, during which we should consider whether there is any evidence of consumer vulnerability. A full copy of our vulnerable client policy is available on request.

Compensation Schemes
We are members of the Investor Compensation Scheme operated by the Investor Compensation Company Ltd. See below for details.

Investor Compensation Scheme
The Investor Compensation Act, 1998 provides for the establishment of a compensation scheme and the payment, in certain circumstances, of compensation to certain clients (known as eligible investors) of authorised investment firms, as defined in that Act.

The Investor Compensation Company Ltd. (ICCL) was established under the 1998 Act to operate such a compensation scheme, and our firm is a member of this scheme.

Compensation may be payable where money or investment instruments owed or belonging to clients and held, administered or managed by the firm cannot be returned to those clients for the time being and where there is no reasonably foreseeable opportunity of the firm being able to do so.

A right to compensation will arise only:

If the client is an eligible investor as defined in the Act; and

If it transpires that the firm is not in a position to return client money or investment instruments owned or belonging to the clients of the firm; and

To the extent that the client’s loss is recognised for the purposes of the Act.

Where an entitlement to compensation is established, the compensation payable will be the lesser of:

90% of the amount of the client’s loss which is recognised for the purposes of the Investor Compensation Act, 1998; or

Compensation of up to €20,000.

For further information, contact the Investor Compensation Company Ltd. at (01) 224 4955.

Brokers Ireland Clients’ Compensation and Membership Benefits Scheme (BIC)
We are also members of the Brokers Ireland Clients’ Compensation and Membership Benefits Scheme (BIC). Subject to the rules of the scheme the liabilities of its members firms up to a maximum of €100,000 per client (or €250,000 in aggregate) may be discharged by the fund on its behalf if the member firm is unable to do so, where the above detailed Investor Compensation Scheme has failed to adequately compensate any client of the member. Further details are available on request.

Material changes to Terms of Business
We will modify these terms of business from time to time by written notice to reflect our current practise and/or changes to regulatory requirements which we are obliged to meet.