Blankstone Sington Limited

Limits on the record

• Restriction on taking on new clients effective 16 November 2021

  1. Blankstone must not accept, without the prior written consent of the Authority, any new clients except for taking on as a client the executor(s) of an existing client in the event of the existing client’s death.

• Restriction on client money and custody assets effective 16 November 2021

  1. Blankstone must not accept, without the prior written consent of the Authority, any new client money or new custody assets from, or on the account of, existing clients. This requirement does not apply to the acceptance of new client monies or custody assets from existing clients and / or third parties by Blankstone as a result of or in relation to the following: a. Existing clients re-investing the investment gains or redemption proceeds from sale of an existing asset; b. Receipt of dividends or coupons; c. Rights issues; d. Corporate actions including maturing bonds; e. Receipts of new client money or custody assets from an existing client which have not been solicited by the Firm, but such receipts must be returned by the Firm to the client within five working days of receipt; f. Receipts of client money or custody assets on the account of the Blankstone Pension Fund (including as a result of funding transactions made by Blankstone); g. Settlement of trades instructed but not yet settled as at the date of this requirement taking effect; and h. Margin calls and movements associated with trades and positions that are open as at the date of this requirement taking effect.

• Assets Restriction effective 16 November 2021

  1. Blankstone must not, without the prior written consent of the Authority, in any way dispose of, withdraw, transfer, deal with or diminish the value of any of its own assets (whether in the United Kingdom or elsewhere). 2. The assets restriction does not apply to monetary payments or the disposal of assets made by Blankstone in the ordinary course of business, amounting to no more than £500,000, whether as a single transaction or a combination of related transactions, over the period of one month. For the avoidance of doubt (but non-exhaustively) an asset transfer involving the sale of client relationships to another person shall not be regarded as in the ordinary course of business, and the following types of payments shall not be regarded as payments in the ordinary course of business: a) Payments of unusual or significant amounts to Blankstone’s controllers, shareholders, directors, officers, employees, or any connected persons. b) The making of any capital distribution. c) The making of any gift or loan by Blankstone to any party. d) Payments made as part of any financial restructuring or reorganisation of its business (whether share or asset based). 3. The assets restriction also does not apply to: a) Payments of funds to Blankstone’s suppliers in the ordinary course of business and in satisfaction of Blankstone’s contractual and legal obligations. b) Usual and proper salary payments made by Blankstone. c) Payments or transfers involving Blankstone’s own assets that are necessary to comply with the FCA’s rules in CASS in relation to client money and/or custody assets, including where it is necessary to transfer its own assets to fund a shortfall. d) Payments made to fund the Blankstone Pension Fund.

• Notification requirements effective 16 November 2021

  1. By [3 working days of the signed Requirement], Blankstone must publish in a prominent place on its website [https://blankstonesington.co.uk/] a notice setting out the terms and effects of Paragraphs 1 to 5 in a form to be agreed in advance with the Authority. 2. Blankstone must, by 2pm on the Friday of each week, provide the Authority with written confirmation that it is adhering to the requirements. 3. Blankstone must, by 11am on Tuesday of each week, provide the Authority with weekly client money reconciliations as at the close of business on the previous Friday. 4. Blankstone must, by 11am on Tuesday of each week, provide the Authority with custody assets reconciliations as at close of business on the previous Friday for those custody asset reconciliations normally performed daily.