Minor Non-Monetary Benefits Disclosure (“MNMBs”)

Investment firms may only provide or accept benefits in kind (non-monetary benefits) in relation to the provision of an investment service that:

are capable of enhancing the quality of the service provided to clients;
do not impair compliance with the firm’s duty to act in the best interests of the client; and
are clearly disclosed.

This is the summary disclosure with regard to MNMBs made on behalf of SG Kleinwort Hambros Bank Limited, SG Kleinwort Hambros Bank Limited - Jersey Branch, SG Kleinwort Hambros Bank Limited - Guernsey Branch, and SG Kleinwort Hambros Bank Limited - Gibraltar Branch (individually and collectively “Kleinwort Hambros”), as referred to in their respective Terms of Business.

The below table indicates the kind of MNMBs that Kleinwort Hambros may provide or receive:

Description

Gifts and hospitality of a reasonable value.

Kleinwort Hambros adheres to a Gifts, Business Entertainment and Corporate Events Policy, which establishes the minimum standards to be maintained when giving and receiving gifts and/or the provision or acceptance of business entertainment and corporate events, particularly when the other party is a provider of investment products or services.

Information or documentation relating to products or services which is generic in nature or personalised to reflect the circumstances of an individual client e.g. product literature, freepost envelopes, articles, news items, information about mortgage finance or financial promotions.

Research relating to a new issue of shares which is produced prior to the issue by a person that is providing underwriting or placing services to the Issuer and made available to prospective investors in the issue.

Research that a third party makes widely available and does not allocate valuable resources to, short term market commentary on financial instruments containing a brief unsubstantiated summary of a third party’s opinion, or research material or services that does not concern or inform views on specific financial instruments or does not explicitly or implicitly recommend or suggest an investment strategy or provide a substantiated opinion as to the value or price of such instruments, or does not contain analysis and original insights.

- Quotations and / or projections relating to investment products;
- Advice on the completion of forms or documents;
- Access to data or processing facilities;
- Access to electronic dealing or quotation systems;
- Software that gives information about investment products.

Assistance for the development of software or other IT facilities where it will generate cost savings to the firm or its clients.

Material which is paid for by the issuer promoting a corporate issue, provided the relationship with the issuer is disclosed and it is made available at the same time to all interested investment firms or the general public.

Participation in or contributions towards conferences, seminars and other training events on financial instruments or investment services, including reasonable hospitality.

Reasonable travel and accommodation expenses when the firm participates in or provides market research or training conducted by another firm.

Kleinwort Hambros adheres to a Travel and Expenses Policy, which summarises the guidelines for those incurring business related expenditure on behalf of the firm.

10.

Other minor benefits that are capable of enhancing the quality of the service provided to clients and do not impair the firm’s duty to act in the best interests of the client.