Accumulating ad-hoc advice
We are always delighted to add value where we can, and this can manifest itself in
occasional ad-hoc advice. However, we reserve the right to raise a separate fee where the
cumulative value of time spent providing ad-hoc advice over a given period becomes
Applicable law
Our engagement letter, the schedule of services and our standard terms and conditions of
business are governed by and should be construed in accordance with English and Welsh
law. Each party agrees that the courts of England and Wales will have exclusive jurisdiction
in relation to any claim, dispute or difference concerning this engagement letter and any
matter arising from it. Each party irrevocably waives any right to object to any action being
brought in those courts. Lidertax Ltd reserves its right to recover all costs with relation to
any dispute and / or legal action.
Where we are required to perform a significant bookkeeping role as part of an agreed
service (EG the submission of year end accounts or the submission of VAT returns), we
reserve the right to charge a bookkeeping fee. A significant bookkeeping role is one that
requires the processing of transactions or the correction of transactions already recorded
and the subsequent aggregation of data into a format from which summary information can
be extracted (IE a report normally known as a Trial Balance).
Client identification
As with other professional services firms, we are required to identify our clients for the
purposes of the UK anti-money laundering legislation. We will request from you, and retain,
such information and documentation as we require for these purposes and/or make
searches of appropriate databases. If we are not able to obtain satisfactory evidence of
your identity, we will not be able to proceed with the engagement.
Client money
We may, from time to time, hold money on your behalf. The money will be held in a client
bank account, which is segregated from the firm’s funds. The account will be operated, and
all funds dealt with, in accordance with Clients’ Money Regulations.
We will return monies held on your behalf promptly, as soon as there is no longer any
reason to retain those funds. If any funds remain in our client account that are unclaimed,
and the client to which they relate has remained untraced for five years, or we as a firm
cease to practise, we may pay those monies to a registered charity.
We may subject to a written notification deduct our fee prior to transferring the money
back to the client.

Commissions and other benefits
In some circumstances we may receive commissions or other benefits for introductions to
other professionals or in respect of transactions which we arrange for you.
We are committed to providing you with a high-quality service that is both efficient and
effective. However, should there be any cause for complaint in relation to any aspect of our
service please write to Aneta Nowakowska. You can contact her by e-mail:
aneta.nowakowska@lidertax.co.uk Where your complaint relates to that person, you should
instead please contact Agnieszka Mackojc on agnieszka.mackojc@lidertax.co.uk We agree
to investigate any complaint carefully and promptly and do everything reasonable to put it
right. We endeavour 14 days to respond to your complaint.
At all times during and after this engagement, we will keep your data confidential, except as
required by law or as provided for in regulatory, ethical or other professional
pronouncements applicable to us or our engagement. We will not provide any third party
with your data, unless, we have your duly signed form of authority to release any
documents/data to third parties.
You agree that, if we act for other clients who are or who become your competitors, to
comply with our duty of confidentiality it will be sufficient for us to take such steps as we
think appropriate to preserve the confidentiality of information given to us by you, both
during and after this engagement. These may include taking the same or similar steps as we
take in respect of the confidentiality of our own information.
In addition, if we act for other clients whose interests are or may be averse to yours, we will
manage the conflict by implementing additional safeguards to preserve confidentiality.
Safeguards may include measures such as separate teams, physical separation of teams, and
separate arrangements for storage of, and access to, information.
You agree that the effective implementation of such steps or safeguards as described above
will provide adequate measures to avoid any real risk of confidentiality being impaired.
We may, on occasions, subcontract work on your affairs to other tax or accounting
professionals. The subcontractors will be bound by our client confidentiality terms.
If we use external or cloud-based systems, we will ensure confidentiality of your information
is maintained.
We reserve the right, for the purpose of promotional activity, training or for other business
purposes, to mention that you are a client. As stated above, we will not disclose any
confidential information.

Conflicts of interest
We will inform you if we become aware of any conflict of interest in our relationship with
you or in our relationship with you and another client, unless we are unable to do so
because of our confidentiality obligations. We have safeguards that can be implemented to
protect the interests of different clients if a conflict arises. If conflicts are identified which
cannot be managed in a way that protects your interests, we regret that we will be unable
to provide further services.
If there is a conflict of interest that is capable of being addressed successfully by the
adoption of suitable safeguards to protect your interests, we will adopt those safeguards.
During and after our engagement, you agree that we reserve the right to act for other
clients whose interests are or may compete with or be adverse to yours, subject, of course,
to our obligations of confidentiality and the safeguards set out in the paragraph on
confidentiality above.
Data protection
10.1 Where we are the Data Controller and Data Processor.
We will be Data Controller (therefore determining how and for what purposes personal data
is being processed) in our delivery of all services, except for those for which we are the Data
Processor (see 10.2 below).
10.1.1 In this clause 10.1, the following definitions shall apply:
 ‘client personal data’ means any personal data provided to us by you, or on your behalf,
for the purpose of providing our services to you, pursuant to our engagement letter with
 ‘data protection legislation’ means all applicable privacy and data protection legislation
and regulations including PECR, the GDPR and any applicable national laws, regulations
and secondary legislation in the UK relating to the processing of personal data and the
privacy of electronic communications, as amended, replaced or updated from time to
 ‘controller’, ‘data subject’, ‘personal data’, and ‘process’ shall have the meanings given to
them in the data protection legislation;
 ‘GDPR’ means the General Data Protection Regulation ((EU) 2016/679); and
 ‘PECR’ means the Privacy and Electronic Communications (EC Directive) Regulations 2003
(SI 2426/2003).
10.1.2 We shall be considered an independent data controller in relation to the client
personal data. We will comply with all requirements and obligations applicable to us under
the data protection legislation in respect of the client personal data.
10.1.3 You shall only disclose client personal data to us where:
(i) you have provided the necessary information to the relevant data subjects regarding its
(ii) you have a lawful basis upon which to do so, which, in the absence of any other lawful
basis, shall be with the relevant data subject’s consent; and
(iii) you have complied with the necessary requirements under the data protection
legislation to enable you to do so.
10.1.4 Should you require any further details regarding our treatment of personal data,
please contact our data protection manager.
10.2 Where we act as the Data Processor
We will perform the role of Data Processor (therefore processing data on behalf of you, the
data controller) in our delivery of any payroll services we may from time to time provide to
you in respect of your officers and employees.
10.2.1 In this clause 10.2
 ‘client personal data’ means any personal data provided to us by you, or on your behalf,
for the purpose of providing our services to you, pursuant to our engagement letter with
 ‘data protection legislation’ means all applicable privacy and data protection legislation
and regulations including PECR, the GDPR and any applicable national laws, regulations
and secondary legislation in the UK relating to the processing of personal data and the
privacy of electronic communications, as amended, replaced or updated from time to
 ‘controller’, ‘data subject’, ‘personal data’, ‘personal data breach’, ‘processor’, ‘process’
and ‘supervisory authority’ shall have the meanings given to them in the data protection
 ‘GDPR’ means the General Data Protection Regulation ((EU) 2016/679); and
 ‘PECR’ means the Privacy and Electronic Communications (EC Directive) Regulations 2003
(SI 2426/2003).
10.2.2 We shall both comply with all applicable requirements of the data protection
legislation. This clause 10.2 is in addition to, and does not relieve, remove or replace, either
of our obligations under the data protection legislation.
10.2.3 We both acknowledge that for the purposes of the data protection legislation, you
are the Data Controller and we are the Data Processor. The Scope of Services attached to

our Engagement Letter together with our Privacy Notice sets out the scope, nature and
purpose of processing by us, the duration of the processing and the types of personal data
and categories of data subject.
10.2.4 In respect of the client personal data, unless otherwise required by applicable laws or
other regulatory requirements, we shall:
a. process the client personal data only in accordance with your lawful written instructions,
in order to provide you with the services pursuant to our engagement with you and in
accordance with applicable data protection legislation;
b. disclose and transfer the client personal data to our regulatory bodies or other third
parties (for example, our professional advisors or service providers) as and to the extent
necessary in order to provide you with the services pursuant to our engagement with you in
relation to those services;
c. disclose the client personal data to courts, government agencies and other third parties as
and to the extent required by law.
d. maintain written records of our processing activities performed on your behalf which
shall include: (i) the categories of processing activities performed; (ii) details of any on cross
border data transfers outside of the European Economic Area (EEA); and (iii) a general
description of security measures implemented in respect of the client personal data;
e. maintain commercially reasonable and appropriate security measures, including
administrative, physical and technical safeguards, to protect against unauthorised or
unlawful processing of any client personal data and against accidental loss or destruction of,
or damage to, such client personal data.
f. return or delete all the client personal data upon the termination of the engagement with
you pursuant to which we agreed to provide the services;
g. ensure that only those personnel who need to have access to the client personal data are
granted access to it and that all of the personnel authorised to process the client personal
data are bound by a duty of confidentiality;
h. notify you if we appoint a sub-processor (but only if you have given us your prior written
consent, such consent not to be reasonably withheld or delayed) and ensure any agreement
entered into with the relevant sub-processor includes similar terms as the terms set out in
this clause 10.2;
i. where we transfer the client personal data to a country or territory outside the EEA to do
so in accordance with data protection legislation;
j. notify you promptly if:

i. we receive a request, complaint or any adverse correspondence from or on behalf of a
relevant data subject, to exercise their data subject rights under the data protection
legislation or in respect of the client personal data; or
ii. we are served with an information or assessment notice, or receive any other material
communication in respect of our processing of the client personal data from a supervisory
body (for example, the Information Commissioner’s Officer);
k. notify you, without undue delay, in the event that we reasonably believe that there has
been a personal data breach in respect of the client personal data;
l. at your cost and upon receipt of you prior written notice, allow you, on an annual basis
and/or in the event that we notify you of personal data breach in respect of the client
personal data, reasonable access to the relevant records, files, computer or other
communication systems, for the purposes of reviewing our compliance with the data
protection laws.
10.2.5 Without prejudice to the generality of clause 10.2.2, you will ensure that you have all
necessary appropriate consents and notices in place to enable the lawful transfer of the
client personal data to us.
10.2.6 Should you require any further details regarding our treatment of personal data,
please contact our data protection officer in writing: maddie.schumann@lidertax.co.uk
We endeavour to response to your concerns within 14 days from receiving your e-mail or
10.2.7 Lidertax Ltd is registered with ICO. Should you wish to make a complaint to ICO,
please follow the link for ICO’s contact details: https://ico.org.ukc

Should we resign or be requested to resign we will normally issue a disengagement letter to
ensure that our respective responsibilities are clear. Should we have no contact with you for
a period of 12 months or more we may issue to your last known address a disengagement
letter and thereafter cease to act.
Electronic and other communication
Unless you instruct us otherwise, we may, where appropriate, communicate with you and
with third parties via email or by other electronic means. The recipient is responsible for
virus checking emails and any attachments. We always will send an attachment with a
protective password.
With electronic communication there is a risk of non-receipt, delayed receipt, inadvertent
misdirection or interception by third parties. We use virus-scanning software to reduce the
risk of viruses and similar damaging items being transmitted through emails or electronic
storage devices. However electronic communication is not totally secure and we cannot be
held responsible for damage or loss caused by viruses nor for communications which are
corrupted or altered after dispatch. Nor can we accept any liability for problems or
accidental errors relating to this means of communication especially in relation to
commercially sensitive material. These are risks you must agree to bear in return for greater
efficiency and lower costs. If you do not wish to accept these risks please let us know and
we will communicate by paper mail, other than where electronic submission is mandatory.
Any communication by us with you sent through the post system is deemed to arrive at your
postal address two working days after the day that the document was sent.

Fees and payment terms
Our fees may depend, not only upon the time spent on your affairs, but also on the level of
skill and responsibility and the importance and value of the advice we provide, as well as the
level of risk.
If we provide you with an estimate of our fees for any specific work, the estimate will not be
contractually binding unless we explicitly state that will be the case. Otherwise, our fees will
be calculated on the basis of the hours worked by each member of staff necessarily engaged
on your affairs, multiplied by their charge-out rate per hour, VAT being charged thereon.
Indicative hourly charge-out rates are set out in paragraph 24 below.
If requested, we may indicate a fixed fee for the provision of specific services or an
indicative range of fees for a particular assignment. It is not our practice to identify fixed
fees for more than a year ahead as such fee quotes need to be reviewed in the light of
events. If it becomes apparent to us, due to unforeseen circumstances, that a fee quote is
inadequate, we reserve the right to notify you of a revised figure or range and to seek your
agreement thereto.
In some cases, you may be entitled to assistance with your professional fees, particularly in
relation to any investigation into your tax affairs by HMRC. Assistance may be provided
through insurance policies you hold or via membership of a professional or trade body.
Other than where such insurance was arranged through us, you will need to advise us of any
such insurance cover you have. You will remain liable for our fees regardless of whether all
or part are liable to be paid by your insurers.
We will bill monthly and our invoices will be due for payment within 10 days of the invoice
date. Our fees are exclusive of VAT which will be added where it is chargeable. Any
disbursements we incur on your behalf, and expenses incurred in the course of carrying out
our work for you, will be added to our invoices where appropriate.
Unless otherwise agreed to the contrary, our fees do not include the costs of any third
party, counsel or other professional fees. If these costs are incurred to fulfil our
engagement, such necessary additional charges may be payable by you.
We reserve the right to charge interest on late paid invoices at the rate of 8% above bank
base rates under the Late Payment of Commercial Debts (Interest) Act 1998. We also
reserve the right to suspend our services or to cease to act for you, having given written
notice, if payment of any fees is unduly delayed. We intend to exercise these rights only if it
is fair and reasonable to do so.
If you do not accept that an invoiced fee is fair and reasonable, you must notify us within 21
days of receipt, failing which, you will be deemed to have accepted that payment is due.
If a client company, trust or other entity is unable or unwilling to settle our fees, we reserve
the right to seek payment from the individual (or parent company) giving us instructions on
behalf of the client, and we shall be entitled to enforce any sums due against the group
company or individual nominated to act for you.

Help us to give the best service
We are committed to providing you with a high-quality service that is both efficient and
effective. If, at any point you would like to discuss with us how our service to you could be
improved, or if you are dissatisfied with the service you are receiving, please let us know by
contacting Aneta Nowakowska 07931702846 or via aneta.nowakowska@lidertax.co.uk
We undertake to look into any complaint carefully and promptly and to do all we can to
explain the position to you.
We will only assist with implementation of our advice if specifically instructed and agreed in
Intellectual property rights and use of our name
We will retain all intellectual property rights in any document prepared by us during the
course of carrying out the engagement except where the law specifically states otherwise.
You are not permitted to use our name in any statement or document you may issue unless
our prior written consent has been obtained. The only exception to this restriction would be
statements or documents that, in accordance with applicable law, are to be made public.
If any provision of our engagement letter or terms of business is held to be void, that
provision will be deemed not to form part of this contract. In the event of any conflict
between these terms of business and the engagement letter or appendices, the relevant
provision in the engagement letter or schedules will take precedence.

Internal disputes with a client
If we become aware of a dispute between the parties who own or are in some way involved
in the ownership and management of the business, it should be noted that our client is the
business and we would not provide information or services to one party without the express
knowledge and permission of all parties. Unless otherwise agreed by all parties we will
continue to supply information to the normal place of business for the attention of the
directors. If conflicting advice, information or instructions are received from different
directors in the business we will refer the matter back to the board of directors and take no
further action until the board has agreed the action to be taken.
Investment advice
Investment business is regulated by the Financial Services and Markets Act 2000. If, during
the provision of professional services to you, you need advice on investments including
insurances, we may have to refer you to someone who is authorised by the Financial
Conduct Authority or licensed by a Designated Professional Body, as we are not.
Insofar as we are permitted to do so by law or professional guidelines, we reserve the right
to exercise a lien over all funds, documents and records in our possession relating to all
engagements for you until all outstanding fees and disbursements are paid in full.
Limitation of liability
We will provide our services with reasonable care and skill. Our liability to you is limited to
losses, damages, costs and expenses directly caused by our negligence or wilful default.
We will not be liable if such losses, penalties, surcharges, interest or additional tax liabilities
are caused by the acts or omissions of any other person or due to the provision to us of
incomplete, misleading or false information or if they are caused by a failure to act on our
advice or a failure to provide us with relevant information.
We will not be liable to you for any delay or failure to perform our obligations under this
engagement letter if the delay or failure is caused by circumstances outside our reasonable
We will not accept responsibility if you act on advice given by us on an earlier occasion
without first confirming with us that the advice is still valid in the light of any change in the
law or your circumstances.
We will accept no liability for losses arising from changes in the law or the interpretation
thereof that are first published after the date on which the advice is given
We will not be responsible or liable for any loss, damage or expense incurred or sustained if
information material to the service we are providing is withheld or concealed from us or
misrepresented to us. This applies equally to fraudulent acts, misrepresentation or wilful
default on the part of any party to the transaction and their directors, officers, employees,
agents or advisers.
This exclusion shall not apply where such misrepresentation, withholding or concealment is
or should (in carrying out the procedures which we have agreed to perform with reasonable
care and skill) have been evident to us without further enquiry beyond that which it would
have been reasonable for us to have carried out in the circumstances.
You agree to indemnify us and our agents in respect of any claim (including any claim for
negligence) arising out of any unauthorised disclosure by you or by any person for whom
you are responsible of our advice and opinions, whether in writing or otherwise. This
indemnity will extend to the cost of defending any such claim, including payment at our
usual rates for the time that we spend in defending it.
You have agreed that you will not bring any claim of a kind that is included within the
subject of the limit against any of our partners or employees on a personal basis.

Limitation of third-party rights
The advice and information we provide to you as part of our service is for your sole use and
not for any third party to whom you may communicate it unless we have expressly agreed in
the engagement letter that a specified third party may rely on our work. We accept no
responsibility to third parties, including any group company to whom the engagement letter
is not addressed, for any advice, information or material produced as part of our work for
you which you make available to them. A party to this agreement is the only person / entity
who has the right to enforce any of its terms and no rights or benefits are conferred on any
third party under the Contracts (Rights of Third Parties) Act 1999.
Period of engagement and termination
Unless otherwise agreed in our engagement letter, our work will begin when we receive
implicit or explicit acceptance of that letter and signed consent form. Except as stated in
that letter, we will not be responsible for periods before that date.
Each of us may terminate our agreement by giving not less than 3 months’ notice in writing
to the other party except if you fail to cooperate with us or we have reason to believe that
you have provided us or HMRC with misleading information, in which case we may
terminate this agreement immediately. Termination will be without prejudice to any rights
that may have accrued to either of us before termination.
We reserve the right to terminate the engagement between us with immediate effect in the
event of: your insolvency, bankruptcy or other arrangement being reached with creditors;
an independence issue or change in the law which means we can no longer act; failure to
pay our fees by the due dates; or either party being in breach of their obligations if this is
not corrected within 30 days of being asked to do so.
In the event of termination of our contract, we will endeavour to agree with you the
arrangements for the completion of work in progress at that time, unless we are required
for legal or regulatory reasons to cease work immediately. In that event, we will not be
required to carry out further work and shall not be responsible or liable for any
consequences arising from termination.

Prevailing charge out rates, minimum fees and discounts
Our hourly consultancy rates for the year commencing 1st May 2020 are:
 Chartered Tax Advisor – 95 per hour
 State Benefits – 36 per hour
 Self-Assessment – 42 per hour
 Accountant – 67 per hour
Rapid turnaround and very rapid turnaround services
The Rapid Turnaround service will be required when data is received by us as follows:
 For annual financial statements: less than 2 months before the relevant statutory filing
deadline at Companies House.
 For VAT returns: after the end of the 25 th day of the month following the end of the
quarter to which the return relates.
In case the rapid turnaround service is required an additional payment of 30 pounds per hour
shall be added to the upcoming invoice. The number of hours shall be subject to amount of
work and knowledge required to perform the task.
Reliance on advice
We will endeavour to record all advice on important matters in writing. Advice given orally is
not intended to be relied upon unless confirmed in writing. Therefore, if we provide oral
advice (for example during the course of a meeting or a telephone conversation) and you
wish to be able to rely on that advice, you must ask for the advice to be confirmed by us in
Retention of papers
You have a legal responsibility to retain documents and records relevant to your tax affairs.
During the course of our work we may collect information from you and others relevant to
your tax affairs.
We will return any original documents to you. Documents and records relevant to your tax
affairs are required by law to be retained for six years from the end of the accounting period
Although certain documents may legally belong to you, we may destroy correspondence
and other papers that we store electronically or otherwise that are more than seven years
old, except documents we think may be of continuing significance. You must tell us if you
wish us to keep any document for any longer period.
The provision of services regulations
In accordance with professional rules, we are required to hold professional indemnity
insurance. The contact details for the insurer and territorial coverage of the insurance are
available at the Head office.
Timing of our services
If you provide us with all information and explanations on a timely basis in accordance with
our requirements, we will plan to undertake the work within a reasonable period of time to
meet any regulatory deadlines. However, failure to complete our services before any such
regulatory deadline would not, of itself, mean that we are liable for any penalty or
additional costs arising.
Transfer of terms
The Lidertax Ltd may from time to time and in the ordinary course of business, change its
name and/or the legal entity through which they trade. In the event of any such change of
name and/or legal status, the terms of the Engagement Letter in place at the time, together
with accompanying the schedule(s) of service and standard terms and conditions will be
deemed to transfer in full to the new entity.
31a. Your responsibilities
You have undertaken to make available to us, as and when required, all the accounting
records and related financial information, including minutes of management meetings,
which we need to do our work.
You will provide us with all information and explanations relevant to the purpose and
compilation of the accounting records, and you will disclose to us all relevant information in
You are responsible for ensuring that, to the best of your knowledge and belief, financial
information, whether used by the business or for the accounting records, is accurate and
You are also responsible for ensuring that the activities of the business are conducted
honestly, and for safeguarding the assets of the business and for taking reasonable steps to
prevent and detect fraud and other irregularities.
You are responsible for monitoring your monthly turnover to establish whether you are
liable to register for VAT.
If you do not understand what you need to do, please ask us.
If you exceed the VAT registration threshold, and wish us to assist you in notifying HMRC of
your liability to be VAT registered we will be pleased to assist you in the VAT registration
You should notify us of your instructions to assist in your VAT registration in good time to
enable a VAT registration form to be submitted within the time limit of one month following
the month in which you exceed the VAT registration threshold in force at that time.
We will not be responsible if you fail to notify us in time and incur a late registration penalty
as a result.
You are responsible for ensuring that the business complies with the laws and regulations
that apply to its activities, and for preventing non-compliance and for detecting any that
You are responsible for making any payments due of corporation tax, VAT and in respect of
PAYE on time. Failure to do this may lead to automatic penalties, surcharges and/or interest.

31b. Your responsibilities
You are legally responsible for:
(a) Ensuring that your self-assessment tax returns are correct and complete;

(b) Filing any returns by the due date; and
(c) Making payment of tax on time.
Failure to do this may lead to automatic penalties, surcharges and/or interest.
Taxpayers who sign their returns cannot delegate this legal responsibility to others. You
agree to check that returns that we have prepared for you are complete before you approve
and sign them.
To enable us to carry out our work you agree:
(a) That all returns are to be made on the basis of full disclosure of all sources of income,
charges, allowances and capital transactions;
(b) To provide full information necessary for dealing with your affairs: we will rely on the
information and documents being true, correct and complete and will not audit the
information or those documents;
(c) To authorise us to approach such third parties as may be appropriate for information
that we consider necessary to deal with your affairs; and
(d) To provide us with information in sufficient time for your tax return to be completed and
submitted by the due date following the end of the tax year. In order that we can do this,
we need to receive all relevant information annually. Where feasible, we may agree to
complete your return within a shorter period but may charge an additional fee for so doing.
You will keep us informed of material changes in your circumstances that could affect your
tax liability. If you are unsure whether the change is material or not please let us know so
that we can assess its significance.
You will forward to us HMRC statements of account, copies of notices of assessment, letters
and other communications received from HMRC in time to enable us to deal with them as
may be necessary within the statutory time limits. Although HMRC have the authority to
communicate with us it is essential that you let us have copies of any correspondence
received because HMRC are not obliged to send us copies of all communications issued to
Where we have been requested to advise you and your spouse on the basis that you are a
family unit:
(a) You both agree that in all matters relating to your or your spouse’s tax and financial
affairs, we may deal directly with either of you and we may discuss with either of you the

tax liabilities and/or financial affairs of the other. If you wish to make any change to these
arrangements at any time, please let us know.
(b) In order for us to act for you as a couple in respect of a joint claim, you undertake that
all instructions, information or explanations either of you gives us will be on behalf of both
of you, unless you specifically tell us otherwise. Similarly, if one of you signs a document, it
will be on behalf of you both unless you instruct us to the contrary. If a conflict of interest
should arise between you in relation to any matter to do with your joint claim or
entitlement, we reserve the right to cease acting for both of you, or to advise one or other
of you to obtain independent advice.