Terms of Business

Doyle Pittam Limited t/a Progressive Financial Services Address: Unit 1 Ardee Court, Ardee Street, Dublin 8 Phone: 01 416 5598

Email: info@progressivefs.ie

Our Terms of Business set out the general terms under which our Firm will provide business services to you and the respective duties and responsibilities of both the Firm and you in relation to such services. Please ensure that you read these terms thoroughly and if you have any queries, we will be happy to clarify them. If any material changes are made to these terms, we will notify you. 

Terms of Business are effective from the 11^th March 2026  and apply until further notice.

Authorisation with the Central Bank of Ireland

Doyle Pittam Limited t/a Progressive Financial Services (The Firm) is regulated by the Central Bank of Ireland as an Insurance Intermediary registered under the European Union (Insurance Distribution) Regulations 2018 ; as an Investment Intermediary authorised under the Investment Intermediaries Act, 1995 and as a Mortgage Intermediary authorised under the Consumer Credit Act, 1995, and as a Mortgage Credit Intermediary under the European Union (Consumer Mortgage Credit Agreements) Regulations 2016. The Central Bank of Ireland holds a register of regulated Firms. You may contact the Central Bank of Ireland on 1890 777 777 or visit their website at www.centralbank.ie to verify our credentials. Copies of our authorisations are available on request.

Codes of Conduct

The Firm is subject to, and complies with, the Central Bank of Ireland’s Consumer Protection Code 2025, which comprises the Standards for Business Regulations and the Conduct of Business (Consumer Protection) Regulations 2025, the Minimum Competency Regulations 2017 (and associated Code), and the Fitness and Probity Standards issued under the Central Bank Reform Act 2010. These codes and regulations are in place for the protection of customers and are available on www.centralbank.ie or on request from us.

Securing Customer Interests

Under the Consumer Protection Code 2025, we must secure our customers’ interests and to act honestly, fairly and professionally in your best interests at all times. In practice, this means that we:

• provide advice based on a fair analysis of the market (unless we clearly tell you otherwise), taking account of your needs, circumstances, objectives and attitude to risk;
• recommend products and providers that we reasonably believe are suitable for you and that support your long‑term financial interests;
• identify, manage and disclose any potential conflicts of interest;
• are transparent about how we are paid for our services; and
• handle complaints promptly, fairly and consistently and learn from them to improve our services.

Our Services

Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life assurance, serious illness cover, other protection policies, pension policies, other retirement related policies, mortgages, and savings & investment policies. The Firm does not have a ‘tied’ relationship with any institution that would compromise our ability to offer you advice and choice. A full list of insurers, product producers and lending agencies with which we deal is available on request. The Firm is a member of Brokers Ireland.

Customers in Vulnerable Circumstances

We recognise that customers’ circumstances can change over time and that some customers may be in vulnerable circumstances due to, for example, health issues, disability, bereavement, relationship breakdown, financial difficulties, age, language or literacy barriers. Where we become aware, or you tell us, that you may need additional support, we will take appropriate steps to assist you. This may include giving extra time to make decisions, explaining information more than once, using clearer or alternative forms of communication, or allowing you to have a trusted person with you during meetings, subject to your consent and data protection requirements. Please let us know if you believe you may benefit from additional support at any stage.

Protection, Pensions & Investments

The Firm facilitates the arrangement of protection policies (life & serious illness cover and income protection), pensions and investment products on a fair analysis basis, i.e., providing advice after reviewing the various contracts and product providers available in the market, which enables us to recommend that suits your circumstances and meets your needs.

We will aid you with any queries you may have in relation to the policies, explain to you the various restrictions, conditions and exclusions attached to your policy, or in the event of a claim, we will assist you with the claims process.

We will explain the key features, benefits, restrictions, conditions and exclusions of any product we recommend to you in a clear and understandable way and will answer any questions you may have. We will also provide you with policy documents, literature and brochures so that you can consider them in your own time. It is important that you read these documents carefully to ensure you understand the nature of the cover and any limitations that apply to your policy, and please raise any queries with us if anything is unclear.

Specifically on the subject of PHI it is our policy to 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.

For regular premium pension and investment contracts where the monthly contribution is less than €250, we operate a ‘house view’ under which we generally recommend New Ireland Assurance for pension contracts (PRSA, Personal and Executive pensions) and regular saver contracts (FutureSave). This approach is based on our assessment of product pricing, fund range, service and overall value to customers and is kept under regular review. Where we believe that another provider or product is more suitable for you, based on your individual circumstances and objectives, we will recommend that instead. We will review this periodically and adjust if/when necessary.

Please note, we charge €500 for the establishment and registration of a Bare Trust.

Sustainability Factors – Investment/IBIPS/Pension Advice

When providing advice on insurance‑based investment products (IBIPs) or pension products, we will ask you about any preferences you may have in relation to environmental, social and governance (ESG) factors and sustainable investments.

At present, we do not systematically consider the principal adverse impacts of investment decisions on sustainability factors in our advice processes. We believe the information currently available from product manufacturers and in the market is not yet sufficiently consistent and comparable for us to do so in a robust way. We do, however, consider your stated sustainability preferences when comparing products that are otherwise suitable for your needs and objectives, and we will explain any material ESG‑related features or limitations of products that we recommend.

We keep this approach under review and may update it as industry standards, data and regulatory expectations in this area develop.

Mortgages

Through the lenders or other undertakings with which we hold an agency, The Firm can provide advice on and arrange products from the following range: fixed-rate mortgages, variable rate mortgages, capital & interest mortgages, interest only mortgages, residential investment property, pension mortgages and home reversion loans. We provide mortgages on a fair analysis basis, in accordance with professional criteria, regarding which contract would be adequate to meet your needs.

We will need to collect sufficient information from you before we can offer any advice on housing loans. This is because a key issue in relation to mortgage advice is afford ability and is guided by Central Bank rules and regulations.

When assessing your application for a housing loan or mortgage, we will collect sufficient information to assess affordability and the sustainability of repayments over the term of the loan, in line with Central Bank rules and the Consumer Protection Code 2025. Where appropriate, we will outline any relevant mortgage switching options and explain the potential benefits and costs of switching, including how any incentives, cashback offers or other features may affect the overall cost of credit over the life of the loan.

Clawback

If we receive commission from a product provider (and offset the commission against the fee we would have otherwise charged you) but the commission is subsequently clawed back by the provider due to early encashment by you or because of 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.

Regular Reviews

With your agreement, we may review the policies you take out on a periodic basis to ensure that you are kept informed as to their benefits and to check whether they are still suitable for your needs. As your circumstances change, your needs will also change-you must advise us of those changes and request a review of the relevant policy so that we can ensure that you are provided with up-to-date advice and products best suited to your needs. Failure to update us of changes in your circumstances,

or request a review, may result in you having insufficient insurance cover and/or inappropriate investments. Any failure to disclose material information may invalidate your claim and render your policy void.

Fair Analysis

The concept of fair analysis is derived from the Insurance Mediation Directive. It 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 be reasonably expected of a professional conducting business, considering 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 analysis of the market, we will consider the following criteria:

• Needs of the customer
• Size of the customer order
• Number of providers in the market that deal with brokers
• Market share of each of those providers
• Number of relevant products available from each provider
• Availability of information about the products
• Quality of the product and service provided by the provider
• Cost and any other relevant consideration

Fees & Charges

We are renumerated by commissions for our investment, insurance, and mortgage intermediary services. You may elect to deal with us on a fee basis. Our hourly rate is €250 and we may price the arrangement of a product and advice in advance of engaging with a provider on your behalf.

The initial meeting where we complete the fact find is free, our hourly rate applies thereafter. The Firm may receive commission and other payments from product producers or lenders on the completion of business. If we receive commission from a product provider, this may be offset against the fee that we charge you. Where the commission is greater than the fee due, the commission will become the amount payable to The Firm unless an arrangement to the contrary is made. Proof of any such agreement must be signed. We reserve the right to charge additional fees if the number of hours relating to on-going advice/assistance exceeds 10 hours per annum. Fund based commission may be added in respect of pension and investment products, this shall not exceed more than 1% per annum.

We may receive up to 1% of the loan for arranging mortgage finance, which is paid by the mortgage lender. The actual amount of commission will be disclosed at a later stage in the ESIS which will be forwarded to you by the lender. The Firm holds the right to charge a fee of no less than €500 for completing a mortgage application on a client’s behalf. For applications that take more than two hours, The Firm reserves the right to charge its hourly rate of €250 in addition.

Conflict 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. A full copy of our conflict of interest policy is available upon request.

Complaints

If you have a complaint about the services provided by Doyle Pittam Limited t/a Progressive Financial Services, please outline the details of your complaint to us, preferably in writing. We will acknowledge your complaint within 5 business days and we will investigate it fairly, consistently and promptly. We will provide you with regular written updates and we will aim to resolve your complaint as quickly as possible. If, after we have issued our final response, you are dissatisfied with the outcome, or if your complaint has not been resolved within the applicable timeframes, you are entitled to refer your complaint to the Financial Services and Pensions Ombudsman (FSPO), Lincoln House, Lincoln Place, Dublin 2, D02 VH29 (www.fspo.ie). The FSPO provides a free, independent and impartial service to complainants and there is no charge for bringing a complaint to the FSPO.

Data Protection Policy

The Firm is committed to protecting and respecting your privacy, while complying with the requirements of the General Data Protection Regulation 2018 and the Irish Data Protection Act 2018. The data which you provide to us will be held on a secure computer database (cloud) for the purpose of arranging transactions on your behalf. When a paper file(s) has been provided the originals will be returned to you on request or shredded after the file is uploaded to our cloud. 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, which you can find on our website https://progressivefs.ie/privacy/.

We would like to keep you informed of insurance, investment, mortgage and any other services provided by us or associated companies with which we have a formal business arrangement, and which we think may be of interest to you. We would like to contact you by way of letter, email or telephone call. If you would like to receive such marketing information, please request a permission statement from us or add your details to the contact form on our website.

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

Communication Channels and Digital Services
We may communicate with you and provide information using a range of channels, including face‑to‑face meetings, post, telephone, email and, where agreed with you, online or video‑conferencing tools. We will agree with you how we will communicate and provide documentation. Where we use digital channels, we will take appropriate steps to verify your identity, to keep your information secure and to record your consent to proceed with any recommended transactions. You may request paper copies of documentation at any time.
Your security is very important to us. We will never ask you to share your full online banking passwords or PINs, or to transfer money to new accounts by email or text message. If you receive a communication that appears to be from us but that you are unsure about (for example, asking you to click a link, download an attachment or transfer funds), please contact us using the contact details on this Terms of Business document or on our official website before taking any action.

Unregulated Services

In addition to our regulated intermediary services, we may provide certain tax planning, estate planning, voluntary national insurance contributions, tax credit updates or other advisory services that do not constitute regulated financial services under Irish law. Where we provide any such unregulated services, we will clearly identify them to you in advance. Unregulated services are not subject to the Consumer Protection Code 2025 or other Central Bank of Ireland codes of conduct and are not covered by the Investor Compensation Scheme or the Financial Services and Pensions Ombudsman.

Compensation Scheme

The Firm is a member of the Investor Compensation Scheme, 1998 which provides certain remedies to eligible clients or “eligible investors” of authorized investment Firms as defined by the Act.

Compensation may be payable where money or investment instruments owed or belonging to clients are 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
• the extent that the client’s loss is recognised for the purposes of the

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.

The main details of the operation and conditions can be found on www.investorcompensation.ie.