CIRCA5000 | The CIRCA5000 Personal Pension Key Features Document

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The CIRCA5000 Personal Pension Key Features Document

Last Updated: 1/9/2023

INTRODUCTION

The CIRCA5000 Personal Pension is administered by Gaudi Regulated Services Limited (“Gaudi”). The Financial Conduct Authority is a financial services regulator. It requires Gaudi, the Scheme Administrator, to give you this important information to help you to decide whether the CIRCA5000 Personal Pension is right for you.

You should read this document carefully so that you understand what you are buying, and then keep it safe for future reference. If you do not understand any aspect of this document then please ask CIRCA5000 or seek independent advice.

If you are unsure whether this product, its features, investment options and charges are right for you then you should take appropriate financial advice. Gaudi, CIRCA5000 (the promoter and distributor of the CIRCA5000 Personal Pension) and Seccl (the “Custody Provider”), are not authorised to give you financial or investment advice.

AIMS OF THE CIRCA5000 PERSONAL PENSION

The pension plan is designed to let you:

  • Save for your future in a tax-efficient and flexible way.
  • Invest your pension in companies building a better future.
  • Take control of your pension fund investments, and combine and manage pension pots from past jobs.
  • Manage your pension savings digitally in the CIRCA5000 app.
  • Have complete control over how much you contribute at any time.
  • Make transfer payments from other suitable pension arrangements.
  • Specify to whom you would like benefits to go to on your death, although the decision rests with the Scheme Administrator.

Please note that the CIRCA5000 Personal Pension does not at present offer a facility to take your pension benefits when you reach your intended retirement age. This currently means you will have to transfer your pension fund to another provider when you want to take your money out or convert it to an income.

YOUR COMMITMENT

Once you have opened a CIRCA5000 Personal Pension, your commitments include:

  • To pay money in and/or transfer benefits from other suitable pension arrangements.
  • Keeping those funds within a registered pension scheme until you take benefits, the earliest age at which is currently 55, but rising to 57 from 6th April 2028.
  • Taking responsibility for the choice of the investments in your pension fund.
  • To adhere to the Terms and Conditions of the pension plan. Please see the CIRCA5000 Personal Pension Terms and Conditions for more details.
  • To tell CIRCA5000 if you stop being eligible for a pension or for tax relief. Please see the ‘Questions and Answers’ section for examples where this could be the case.
  • Paying the fees in accordance with CIRCA5000’s Terms of Business.

RISKS

Below are outlined risks associated with saving for retirement through a pension plan. Some of the risks below refer to the investment performance of the funds in your pension plan. Remember that you are responsible for the investment decisions. In many instances, the funds you invest in will also have key information documents that outline the specific risks applicable to that investment and you are recommended to read these as well as this document

The favourable tax treatment for pension savings and the age at which you can first start to take benefits could change in the future.

Investment performance or charges may be better or worse than expected, which could affect the potential size of your pension fund and therefore the benefits you receive.

The charges or fees you pay in relation to this pension plan may be higher than expected, which could affect the potential size of your pension fund and therefore the benefits you receive.

Other things that can affect the potential size of your pension fund and the benefits you receive include the amount you pay or transfer into the pension plan, which could be lower than you anticipated, or if you take benefits earlier than you were aiming for.

Investment conditions can also affect your pension income - if you convert your pension fund to an annuity (i.e. purchase a policy from an insurance company that provides you with a regular income) then prevailing interest rates at the time of conversion will affect the amount of annuity you will receive. Generally speaking, lower interest rates mean lower annuity amounts, although annuity amounts are also affected by other factors such as life expectancy and your state of health.

Alternatively, if you decide to draw your pension income directly from your pension fund then investment returns may not sustain your income requirement.

There may be a delay in receiving benefits if some of your investments cannot be sold quickly.

You have a right to cancel your pension plan within the first 30 days. Where you have invested during this period and you exercise your right to cancel then the amount returned will be the amount realised less any costs associated with the investment and subsequent disinvestment.

While the pension plan can accept transfers from other pension schemes, not all transfers may be suitable. For all transfers you are responsible, with the help of a financial adviser if necessary, for ensuring that the transfer is suitable for you.

A cash transfer from another pension scheme will mean your pension fund may miss out on investment growth for the time it takes from disinvestment under the transferring scheme to investment under this pension plan. You may therefore wish to consider transferring the investments in-specie where this is an available option. The transferring scheme may charge you for making an in-specie transfer.

QUESTIONS AND ANSWERS:

About the CIRCA5000 Personal Pension

What is the CIRCA5000 Personal Pension?

The CIRCA5000 Personal Pension is a pension plan that allows you to save for retirement in a tax-efficient and flexible way.

The benefits you can receive are subject to UK pensions legislation. This includes rules about limits on contributions that can qualify for tax relief, the earliest age you can take benefits and limits on what those benefits can be without incurring tax penalties, including the amount that can be taken as tax-free cash payments.

Who is the CIRCA5000 Personal Pension for?

To be eligible for this product you must be a UK resident and have reached the age of 18.

This product is intended to be used by people who want to:

  • Invest their pension in companies building a better future. Many workplace pensions invest in industries like oil by default. With a CIRCA5000 Personal Pension, you will invest in businesses working for our planet and its people instead.
  • Bring together old pension pots from previous employers and manage them in one easily-accessible place, potentially reducing fees and giving access to better investment performance.
  • Receive tax relief on pension contributions. Your contributions will be topped up by basic rate tax relief (currently 20%) which the Scheme Administrator will collect from the HMRC. For example if you add in £800 your pension will receive an extra £200. Higher rate taxpayers can claim more direct from HMRC. All subject to limits, allowances and personal circumstances.

If you are in any doubt as to whether this pension plan is right for you, then you should consider speaking to a financial adviser.

Who will administer my CIRCA5000 Personal Pension?

Gaudi Regulated Services Limited will administer your pension plan in accordance with the Trust Deed and Rules. This involves the day to day running of your pension plan, ranging from processing contributions, transfers, investments and paying benefits, to ensuring the pension plan adheres to HMRC rules and regulations.

CIRCA5000 provides the digital systems to allow you to interact with and receive information about your pension plan via its app.

Seccl, the Custody Provider, provides the platform and systems on which investments will be held.

Is this a Stakeholder pension scheme?

No. Stakeholder pension schemes are a specific form of pension that must meet Government minimum standards relating to contributions, charges, and provision of a default investment fund. Stakeholder schemes are generally available and it is for you to consider, with the assistance of a financial adviser, if required, whether one might meet your needs as well as the pension plan on offer.

What are the Trust Deed and Rules?

The Trust Deed and Rules are the legal documents that have established the GRSL SIPP Scheme (the “GRSL SIPP”) under which the CIRCA5000 Personal Pension operates and govern how the Scheme is administered. These documents also appoint the Trustee and the Scheme Operator. The Trustee of the CIRCA5000 Personal Pension is Gaudi Trustees Limited and the Operator is Gaudi Regulated Services Limited who is authorised and regulated by the Financial Conduct Authority.

What are the banking arrangements?

Payments in to and out of the CIRCA5000 Personal Pension will be made via a bank account held with Lloyds Bank Plc, by the Custody Provider on behalf of the Trustee. The bank account is segregated from those of the Trustee. The account is a pooled account so that in the event of a bank’s failure your claim will be for a share of the cash held in all such accounts held at the bank. No minimum balance will be retained. Bank failure is also covered under the Financial Services Compensation Scheme.

What will my pension plan be worth?

The final value of your pension plan will depend on how much is paid in, how long you invest for, the charges paid, and how well the investments perform.

The following information are examples to show the effect time and performance could have on the returns you could receive with the CIRCA5000 Personal Pension. In reality your circumstances may differ meaning you could achieve more or less than the amounts shown below.

The following table shows what the value of your CIRCA5000 Personal Pension could be, and the annual income it could provide if you did not take the tax-free lump sum, using a range of possible contributions and periods to retirement. These figures account for the effects of inflation, so are in ‘real terms’.

The figures are based on the following assumptions:

  • 5% annual growth.
  • An inflation rate of 2.0%, so after deducting 2.0% each year for inflation the growth rate in real terms will be 2.9%.
  • Intended retirement at age 65.

The actual rates of return will depend on the value of your portfolio and the performance of your investments. As such, returns may differ from those shown.

Here is what you might get back from your CIRCA5000 Personal Pension, after 1 year, investing in the People & Planet Adventurous investment model:

DESCRIPTION(£) VALUE
Amount to be invested£5,000
What you might get back without charges£5,150.00
What you might get back with charges£5,127.24

These illustrations have been produced using an annual fee of 0.45% and a net annual growth rate of 3%. They do not take into consideration any fee free periods (or other offers) agreed with you, that may reduce the amount you pay in fees.

You will be sent an annual statement showing how your pension plan is doing. The value of your pension plan will also be available in the CIRCA5000 app.

How much pension income will I get?

While you cannot currently draw benefits from the CIRCA5000 Personal Pension and will have to transfer to another pension plan to do this, pension plans usually allow you, once you have attained minimum pension age, to draw as much or as little of your pension fund as income as you like, when you like, along with offering different benefit options. How much pension income you will get therefore depends on your choices and many variable factors such as income tax, the value of your pension plan and investment performance.

What are the charges?

CIRCA5000 charges you a fee, which is based on a percentage of the value of your pension portfolio and is deducted monthly from your portfolio. When there is insufficient cash in your pension portfolio, assets will automatically be disinvested as required.

CIRCA5000 uses this fee to pay the service providers required for running your pension plan. In broad terms, these fees cover such things as administration, custody, payment processing ,etc. Therefore you do not pay a fee directly to Gaudi for the administration services it provides to CIRCA5000. The fees for your CIRCA5000 Personal Pension are detailed in full in the separate ‘Fees Document’, which is an appendix of CIRCA5000’s Terms of Business.

There may be rare situations where an additional fee is required for carrying out work not covered by this fee. Where this arises you will be notified before any work is carried out to agree this additional fee.

Please remember that asset managers may also charge for the purchase and sale of assets. Refer to their separate key information documents for details.

PAYING INTO THE CIRCA5000 PERSONAL PENSION

What are my payment options?

Transfers in from other pension plans

You can transfer pension benefits from other suitable pension arrangements and qualifying recognised overseas pension schemes at the discretion of the Scheme Administrator.

Transfer in of funds that are in drawdown are not currently accepted.

Transfers from defined benefit pension schemes and schemes that provide safeguarded benefits are not accepted.

In specie transfers may be possible if the funds held in the current pension are the same as those held in CIRCA5000. Please contact hi@circa5000.com for more information.

Please note that if you are transferring benefits from another pension scheme that has tax-free cash protection this protection may be lost on transfer.

If you are in any doubt about the benefit of transferring, you should contact a qualified financial adviser.

Making contributions

If you are eligible to make UK tax relievable pension contributions you can choose to make:

one-off contributions; or

regular contributions, which includes the CIRCA5000 ‘Round up’ facility.

Contributions can be made by debit card only subject to a minimum of £5.

It is generally recognised that making regular contributions is a good habit to get into but you are not committed to maintain them.

Through the CIRCA5000 Personal Pension you have the flexibility to decrease or even stop your regular contributions should you need to.

Importantly you can increase them too when, for example, you feel you can afford to contribute more on a regular basis or you can even top up your regular contribution by making additional one-off contributions when it suits you.

Remember though, reducing or stopping contributions, even temporarily, will reduce the possible value of your pension fund at retirement.

UNDERSTANDING TAX RELIEF ON PENSION CONTRIBUTIONS

Will I get tax relief on what I pay into my pension plan?

The Government encourages people to save for their later years by giving income tax relief on contributions paid into pension plans.

There is a limit on how much tax relief you can receive on pension contributions, but providing you are under the age of 75 and a relevant UK individual (which you will be if you are a UK resident), you will be eligible to receive income tax relief on contributions up to the tax relievable limit.

There are also various types of Annual Allowance which, if exceeded, mean you will have a personal tax charge that effectively claws back some of the tax relief your pension plan receives. These are explained below.

What is the tax relievable limit?

This is the greater of £3,600 and 100% of your earnings, known as relevant UK earnings, a full definition of which can be provided on request but which includes salary and bonuses paid to you if employed or, if self-employed, your income which is chargeable to income tax.

This limit is referred to as the gross contribution limit, i.e. ignoring tax relief, and applies to the total personal contributions you make in a tax year to all pension plans you have.

The contributions you make to this pension plan are referred to as net contributions, i.e. allowing for basic rate income tax relief to be added. Therefore, with current basic rate income tax of 20%, the amount you can pay in (the net contribution tax relievable limit) is the greater of £2,880 and 80% of your earnings.

Can I make contributions above the tax relievable limit?

No. This pension plan does not allow contributions above the tax relievable contribution limit to be made.

How do I get the tax relief on my contributions?

Basic rate tax relief is automatically collected from HMRC by the Scheme Administrator and is paid into your pension plan, although it can take several months for it to be received from HMRC.

For example, for a total contribution of £1,000 you would pay £800 and the Scheme Administrator would claim £200 tax relief from HMRC. (This example is based on 20% basic rate income tax.)

If you pay income tax at a higher rate than the basic rate, you can claim extra tax relief through your self-assessment tax return. You will receive this tax relief rather than it going into your pension plan, but it does make your contribution even more cost-effective.

For example, for a total contribution of £1,000 you would pay £800 and the Scheme Administrator would add £200 basic rate tax relief claimed from HMRC. If you pay 40% income tax on at least £1,000 of earnings then you can claim a further £200 in tax relief. Therefore your pension contribution of £1,000 would only cost you £600.

Is there any tax relief on employer contributions?

You will not get tax relief on any employer contributions but you will not be taxed on them as a benefit in kind either. Your employer will normally get tax relief on their contributions, as they are treated as a business expense. Employer contributions are deemed to be paid gross and do not count towards the tax relievable limit. However, they do count towards the pension contribution Annual Allowances, which are explained below. Please note that the CIRCA5000 Personal Pension does not accept employer contributions.

How might I be taxed on pension contributions?

Although your pension plan will receive basic rate tax relief on contributions you make, up to the tax relievable contribution limit, you may receive a personal tax charge directly from HMRC if total contributions in a tax year to all pension plans exceed the Annual Allowance, or if applicable, the Tapered Annual Allowance or Money Purchase Annual Allowance.

You are allowed to make contributions above the Annual Allowances (but not above the tax relievable limit) in this pension plan. The tax relief received into your pension plan remains there, but you should consider the impact of receiving a personal tax charge on the excess contribution, which will reduce the tax-efficiency of making such pension contributions.

Total contributions for this purpose include:

  • Your gross contributions, which includes any contributions paid by a third party.
  • Employer contributions.
  • Any increase in the value of retirement benefits you build up within a tax year in a defined benefit pension scheme.

For the avoidance of doubt, transfers between pension arrangements are not included.

What are the different types of Annual Allowance?

Annual Allowance

Currently £40,000.

This applies to everyone, unless subject to the Tapered Annual Allowance, and is set each year by the Government.

Tapered Annual Allowance

Currently between £40,000 and £4,000.

If you are a high earner i.e. have `adjusted income’ of over £240,000 and `threshold income’ of over £200,000 then your Annual Allowance will be subject to a tapered reduction of £1 for every £2 of earnings above £240,000 up to earnings of £312,000. This means your Annual Allowance could be reduced to £4,000.

Money Purchase Annual Allowance

Currently £4,000.

Where you have started drawing benefits flexibly from any pension arrangement and have triggered the Money Purchase Annual Allowance, contributions to this pension plan and other money purchase pension schemes will be subject to the much lower Money Purchase Annual Allowance.

How much will the tax charge be if I exceed an Annual Allowance?

The amount of tax charged on the excess contribution over the relevant Annual Allowance will be your highest marginal rate of income tax and will ordinarily be paid by you to HMRC via declaring the excess payment on your self-assessment tax return.

It may be possible to request that the tax charge is paid out of your pension plan funds if you are eligible under ‘Scheme Pays’ rules.

If you have not fully used your available Annual Allowance from the previous three tax years and provided you were a member of a registered pension scheme during that period, you may be able to `carry forward’ that unused allowance and include it in your self-assessment tax return. This may reduce or eliminate the Annual Allowance tax charge. This cannot be used where a Money Purchase Annual Allowance tax charge applies.

If you think you may be close to, or exceed, an Annual Allowance and you are in any doubt about its impact, you should seek financial advice as this is a complex area.

Can I make contributions if I have ‘Enhanced Protection’ or ‘Fixed Protection’?

If you have either Enhanced or Fixed Protection then it will be lost if you make, or someone on your behalf makes, a contribution. Losing protection could have serious tax consequences as you may have to pay a Lifetime Allowance charge (See `Is there a limit on benefits I can take from my pension plan?’ below for what this means).

Enhanced Protection was introduced to protect pension funds built up prior to 6th April 2006 from being subject to a Lifetime Allowance charge.

The Government subsequently reduced the Lifetime Allowance on three separate occasions on 6th April 2012, 2014, and 2016 and accordingly introduced Fixed Protection to protect funds built up prior to each of those dates from the Lifetime Allowance charge.

Protection from the Lifetime Allowance is a complex area and if you are in any doubt as to whether making a contribution will affect any protection you have, you should seek appropriate financial advice.

Is my pension fund taxable?

Pension funds do not pay UK taxes on income or capital gains from investment growth. However, tax cannot be reclaimed on UK and some overseas dividends.

INVESTING IN THE CIRCA5000 PERSONAL PENSION

What can I invest in?

You can invest in investments available through the CIRCA5000 app.

You can choose to invest in one of the themed model portfolios available through the CIRCA5000 Personal Pension.

You can take your own investment decisions or use the guidance provided by CIRCA5000 to help you determine which investment may be suitable for you. Please note that the guidance provided on suitable investments does not constitute advice and you are responsible for selecting the investment appropriate for you.

You can change your choice of investments whenever you like. Please remember that asset manager charges may apply.

LIMITS

Is there a limit on benefits I can take from my pension plan?

While you cannot currently take benefits from the CIRCA5000 Personal Pension and will have to transfer to another pension plan to do this, you should be aware that there are limits on how much benefits you can take without incurring additional tax charges.

The maximum you can take from all your pension arrangements without incurring an additional tax charge is called the Lifetime Allowance (“LTA”) as set each year by the Government. If you exceed the LTA and any LTA protections you may have, you will be subject to the Lifetime Allowance charge. If the excess is retained in your pension plan to be taken as pension income the charge is 25% and if taken as a lump sum it will be 55% of the amount above the available Lifetime Allowance. The charge will be deducted from your fund and paid to HMRC.

The original intention was for the LTA to increase each tax year in line with inflation. The Government has temporarily frozen the LTA at £1,073,100 for the tax years 2021/22 through to 2025/26. In the past there were a series of reductions in the LTA and the Government made it possible for individuals potentially affected by the reductions to apply for various types of protection from the Lifetime Allowance charge.

You can still apply for Fixed and Individual Protection 2016 of £1.25m, provided that you have not had contributions paid to any pension schemes since 6th April 2016 and you do not already have Enhanced or Primary Protection. This will generally only be of interest to people who expect both that, at the time they take their pension benefits, the standard Lifetime Allowance will remain below £1.25m and that the value of their pension benefits will exceed the Lifetime Allowance applying at that time.

Every time you take benefits from a pension plan, some of your LTA is used up. Checks against the LTA are carried out at various points, including:

  • Whenever you use part of a pension fund to:
    • take a tax-free cash sum.
    • create a drawdown fund.
    • purchase a lifetime annuity.
  • In the event of your death before age 75.
  • At age 75 (if you still have funds in the pension plan).

At each of the above stages, an allowance is made for any tests that have already been carried out.

Lifetime Allowance charges apply to any further benefits taken once all the LTA is used.

TRANSFERS

Can I transfer out of my pension plan?

You can transfer all or part of your pension plan to another registered pension scheme at any time.

You may be able to transfer some or all of the investments held in your CIRCA5000 Personal Pension to your new pension plan if it is also able to hold those investments. Otherwise your investments will have to be sold and a cash transfer made.

Taking benefits from the pension plan

Currently you will need to transfer some or all of your pension fund in the CIRCA5000 Personal Pension to another pension plan in order to take your pension benefits. The type of benefits you can typically take from a pension plan are summarised below but you should check the terms and conditions of any alternative pension plan.

Benefits summary

OPTIONFROM AGE 55 (RISING TO 57 FROM 6th APRIL 2028)
Pension Commencement Lump Sum (tax-free cash)Up to 25% of your pension fund can normally be taken as tax-free cash payments when combined with designating funds to flexi-access drawdown or purchase of an annuity. Note: receiving the Pension Commencement Lump Sum does not trigger the Money Purchase Annual Allowance.
Use your pension fund to buy a lifetime or five-year pension income, often referred to as an annuityAn annuity can be purchased, the amount of which will be determined by the value of your pension fund and annuity rates available in the annuity purchase. Generally speaking, annuity rates depend on interest rates, life expectancy and the type of pension benefits you are buying (e.g. an increasing or level pension and whether any guarantees or dependants’ benefits are included). If you are in poor health or have a lifestyle that could adversely affect your life expectancy (e.g. heavy smoker), then you may get an enhanced annuity rate. Note: income received via an annuity does not trigger the Money Purchase Annual Allowance.
Draw a pension income directly from your pension fundFlexi-access drawdown - You may designate some or all of your pension fund into flexi-access drawdown. The fund remains invested and you can draw as much or as little income from the drawdown fund as you wish, when you wish (subject to the Terms and Conditions of the pension plan). The income you draw from the fund will be subject to income tax. Note: the Money Purchase Annual Allowance is triggered when you first drawdown an income but there is no obligation to draw an income. Uncrystallised Funds Pension Lump Sum – You may use some or all of your pension fund to provide you with this type of payment. 25% of the lump sum is tax-free, the remainder will be subject to income tax. Note: taking this lump sum will trigger the Money Purchase Annual Allowance.
A combination of the above to meet your individual requirementsYou could take a combination of the benefits described above and you do not have to take benefits all in one go. An annuity can be purchased from funds in drawdown as well as from uncrystallised funds. The way in which you take benefits is flexible and can be structured to meet your individual requirements.

When can I take benefits?

While you cannot currently take benefits from the CIRCA5000 Personal Pension and will have to transfer out to another pension plan to do so, these general rules apply.

You may take income from a pension plan currently from age 55, but rising to 57 from 6th April 2028. You may also take benefits earlier if you suffer serious ill health or an illness or an accident which leaves you permanently unable to carry out your current occupation and you cease that occupation.

On reaching age 50, you can use Pension Wise from MoneyHelper, a free and impartial government backed service, to help you understand what your pension benefit choices are and how they work. This service can be accessed via https://www.moneyhelper.org.uk/en/pensions-and-retirement/pension-wise.

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.

On death, different tax treatments apply depending on whether you die before or after 75 - please see the section ‘Death benefits from your pension plan’ below.

DEATH BENEFITS FROM YOUR PENSION PLAN

What if I die?

When you die, your pension fund may be used to provide benefits to your beneficiaries. As the Scheme Administrator, Gaudi Regulated Services Ltd has discretion over the distribution of payments after your death. You are recommended to nominate and keep updated your chosen beneficiaries. You can do this from the Settings screen in the CIRCA5000 App. While it cannot be binding, the Scheme Administrator will take your wishes into account.

The following paragraphs summarise the benefits payable.

What benefits can be provided?

All of the pension fund is available to provide your beneficiaries with a lump sum payment.

Who can receive a lump sum payment?

Most people will qualify as an eligible beneficiary for lump sum death benefits under the Scheme Rules. The Scheme Administrator will use its discretion to choose who to make the payments to having made reasonable enquiries to identify the eligible beneficiaries.

How are death benefits claimed?

To claim death benefits, the person dealing with your affairs should contact CIRCA5000 at the address shown at the end of this document. They will confirm the information needed to pay the benefits as quickly as possible.

Are death benefits taxable?

On death, different tax treatments apply depending on whether you die before or after 75

  • Death before age 75: Benefit payments are not subject to income tax provided the lump sum is paid before two years from the date of notification of death to the Scheme Administrator. If benefits exceed the Lifetime Allowance then the recipients of the death benefits will be personally liable to pay the Lifetime Allowance charge to HMRC.
  • Death after age 75: Benefit payments to the recipient are subject to income tax at their applicable rate.
  • Inheritance tax: This is not normally payable although it may arise in the event that payments are made to your estate.

FURTHER INFORMATION

Can I cancel my pension plan?

If you change your mind, you have legal cancellation rights for a limited time period.

The right to cancel applies to the commencement of the pension plan and on receipt of a transfer into the pension plan.

In the event of cancellation, the net realisable value of any assets purchased and subsequently disinvested will form the basis of the amount returned. This means that having taken into account any fees or charges paid in relation to the investment and any price movements (particularly downwards), you may get back less than you originally invested.

The Scheme Administrator will only refund a maximum of the net contributions made and any money that is in excess of the net contribution will be paid to charity.

Cancelling your pension plan

If you want to cancel the pension plan, you should notify CIRCA5000 within the 30 day cancellation period. The pension plan cannot be cancelled after the cancellation period has ended.

Any contributions will be returned less any tax relief claimed on your behalf, which will be returned to HMRC.

If your pension plan has already received transfers in they will also be cancelled, as set out below, as part of your pension plan cancellation.

Cancelling a transfer request

If you want to cancel a transfer into the pension plan, you should notify [insert details] within the 30-day cancellation period. A transfer cannot be cancelled after the cancellation period has ended.

Where you cancel a transfer into your pension plan, the transferring scheme may not agree to accept back your transfer value, or may only accept it on revised terms, which are not acceptable to you, in which case you will be responsible for finding an alternative scheme to transfer the funds to.

What if I have a query or complaint?

If you have a query or complaint, please email CIRCA5000 at the address shown at the end of this document. If you have a complaint the Team will do all it can to resolve it. Details of the complaint handling process are available on request.

If you are not happy with the response and you wish to take the matter further you can refer it, free of charge and without giving up any other rights you may have, to one of the following:

The Pensions Ombudsman

10 South Colonnade Canary Wharf E14 4PU

Telephone number: 0800 917 4487

www.pensions-ombudsman.org.uk

The Pensions Ombudsman provides an Early Resolution Service, which may help resolve any complaint promptly. Please see:

https://www.pensions-ombudsman.org.uk/sites/default/files/publication/files/ERS%20factsheet.pdf.

Financial Ombudsman Service

Exchange Tower, London, E14 9SR

Telephone number: 0800 023 4567

www.financial-ombudsman.org.uk

Where can I find more information?

Please contact CIRCA5000. Its contact details can be found at the end of this document.

Can I get an illustration of benefits?

At the start of your pension plan, an illustration giving details of the potential benefits and costs will be supplied or on request prior to your plan commencing.

COMPENSATION

The Financial Services Compensation Scheme (“FSCS”) may provide protection if the Scheme Administrator cannot meet claims made against it or if investments or money cannot be returned.

If you are eligible, the maximum level of compensation for claims against firms declared in default on or after 1st April 2019 is £85,000 per person per firm. Further information about compensation arrangements is available from the FSCS website at www.fscs.org.uk.

Pension plans are regulated contracts in their own right and hence are covered by the FSCS. Investments with regulated investment providers or insurance companies will be covered separately under the FSCS.

Those companies will provide information about the levels of cover provided.

Your status under the FSCS does not affect any statutory right you may have to compensation.

Some, but not all, investments held by your pension fund may also be similarly covered by compensation schemes. It is your responsibility to establish where this is and is not the case.

LAW

The law of England and Wales will be used to decide any dispute.

The information in this document is based on current understanding of the law and practice as at its version date. Every effort is made to ensure that this information is helpful, accurate and correct but the law and practice may change or may not apply to your personal circumstances. You should not take any action on the basis of this information alone as you should also read the Terms and Conditions and the Trust Deed and Rules. Before taking any action you should always consider taking appropriate financial advice.

HMRC practice and the laws relating to pension taxation are complex and depend on individual circumstances and changes which cannot be foreseen.

This product is a personal pension plan regulated by the Financial Conduct Authority. The CIRCA5000 Personal Pension is operated by Gaudi Regulated Services Limited who is authorised and regulated by the Financial Conduct Authority with permission to establish, operate and wind-up personal pension schemes.

TERMS AND CONDITIONS

This Key Features Document gives a summary of the CIRCA5000 Personal Pension. It does not include all the definitions, exclusions or terms and conditions.

The full contractual terms are set out in the Trust Deed and Rules and the Terms and Conditions. If you would like copies of these, or clarification of any of the information provided in this document, please contact CIRCA5000 at the email address shown at the end of this document.

The Terms and Conditions may be varied from time to time by giving you 30 days’ notice, except where the Scheme Administrator considers it to be to your benefit, or where changes in applicable laws or the rules of the relevant regulatory bodies or authority are required to take effect earlier than that date, in which case the Scheme Administrator will issue the notice of variation as soon as reasonably practicable.

CONTACTING CIRCA5000

The Scheme Administrator of the CIRCA5000 Personal Pension is Gaudi Regulated Services Limited.

The Trustee of the CIRCA5000 Personal Pension is Gaudi Trustees Limited and the Operator is Gaudi Regulated Services Limited.

The address of CIRCA5000 is:

3rd Floor, 86-90 Paul Street

London

EC2A 4NE

Email: hi@circa5000.com

Phone: 0151 452 6655 (Open Monday to Friday, 9am-5pm)

CIRCA5000 is a trading name of CIRCA5000 Ltd. CIRCA5000 Ltd is authorised and regulated by the Financial Conduct Authority (FRN: 846067). CIRCA5000 Ltd (No. 11200977) and registered at 3rd Floor, 86-90 Paul Street, London, EC2A 4NE.

“Gaudi” refers to the applicable entities of the Gaudi Group including Gaudi Limited (No. 6502014), Gaudi Regulated Services Limited (No. 6638918) and Gaudi Trustees Limited (No. 7898388) and registered at 2 Oakridge Office Park, Whaddon, Salisbury. SP5 3HT.

Gaudi Regulated Services Limited is authorised and regulated by the Financial Conduct Authority. (FRN: 488015).

Seccl Technology Limited is registered at 20 Manvers Street, Bath, BA1 1JW (No. 10237930). Seccl Custody Limited, a wholly owned subsidiary of Seccl Technology Limited, is registered at 20 Manvers Street, Bath BA1 1JW (No. 10430958), and is authorised and regulated by the Financial Conduct Authority (FRN: 793200).

You can check out these details on the Companies House website at www.gov.uk/government/organisations/companies-house and the FCA’s website at www.fca.org.uk/register.

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