The Invinitive SIPP Member Information Guide

The Trust Deed and Scheme Rules are the legally binding foundation of the Invinitive SIPP. They establish the scheme under trust, define the roles of the Scheme Administrator and Trustee, and set out how benefits, contributions, transfers and member arrangements operate.

If there is any inconsistency between this Member Guide and the Trust Deed and Scheme Rules, the Trust Deed and Scheme Rules will always prevail. Where appropriate, the Key Features, Terms & Conditions, Costs & Charges and Permitted Investments documents provide additional detail.

The Key Features document explains the main characteristics of the Invinitive SIPP, including its aims, risks, benefits and options. It is designed to help you understand the nature of the product before deciding whether to proceed.

The Terms & Conditions form your contractual agreement with Invinitive Financial UK Ltd in relation to operating your SIPP and using the platform. They cover areas such as account operation, trading, charges, transfers, complaints and liability.

This document sets out the fees and charges applicable to your SIPP. Charges may include administration fees, custody fees, transaction charges and fees for specific events or services.

To begin a transfer, a member must submit a valid transfer request and any supporting documentation required by Invinitive and their existing provider. The transfer process often involves multiple parties, including the existing pension provider, administrators, custodians and industry transfer services. As a result, transfer timescales can vary significantly.

Some transfers may be processed electronically, while others require manual processing. Transfers involving non-cash assets (for example, in-specie transfers) may take longer and may be subject to additional checks or restrictions imposed by your current provider.

Certain pension arrangements contain safeguarded or protected benefits, such as guaranteed annuity rates, protected retirement ages, or other guarantees. These benefits may be lost on transfer. In some cases, the presence of safeguarded benefits may restrict or prevent a transfer altogether.

It is the member's responsibility to identify and understand any safeguarded benefits attached to their existing pension and to consider the implications of transferring. Invinitive does not assess or confirm whether safeguarded benefits exist or whether giving them up is appropriate.

All pension transfers are subject to regulatory checks designed to protect members and the pension system from fraud, scams and financial crime. Invinitive is required to carry out due diligence in accordance with pension transfer regulations, anti-money laundering legislation and anti-scam guidance.

This may include requesting additional information from the member, the ceding provider or third parties. Where required by law or regulation, Invinitive may delay, pause or refuse a transfer request.

Invinitive does not control the actions or processing times of transferring providers and cannot guarantee transfer timescales. Delays may arise due to third-party processes, incomplete documentation, asset complexity or regulatory requirements.

Once a transfer is completed, the transferred assets or cash will be allocated to the member's SIPP in accordance with the scheme rules. Members should review their account promptly following completion of a transfer to ensure the assets have been received as expected.

Invinitive maintains a Permitted Investments List which sets out the categories of investments that may be held within the SIPP. This list reflects HMRC rules on taxable and non-taxable property and the FCA's asset classification framework. It is not a list of approved or recommended investments, nor does inclusion imply that an investment is low risk or suitable for a particular member.

The FCA classifies SIPP assets as either standard or non-standard assets. This classification relates to the level of responsibility placed on the SIPP operator and the operational complexity of holding the asset, rather than its potential risk or return.

• Standard assets are typically easy to value and can normally be realised within 30 days. Examples include cash, unit trusts, OEICs, exchange-traded funds, listed shares and most listed bonds.
• Non-standard assets are assets that do not meet the FCA's standard asset definition, including assets that are difficult to value, illiquid, or complex to administer. Both standard and non-standard assets can carry significant risk.

Invinitive's platform is designed to support daily-dealing investments only. Assets that cannot be reliably valued or realised within a reasonable timeframe will not be permitted.

Subject to acceptance and ongoing compliance, permitted investment categories may include:

• Cash and deposit accounts with regulated banks or building societies
• Listed securities on HMRC-recognised exchanges
• Government and corporate bonds meeting minimum credit standards
• Unit trusts, OEICs and other FCA-authorised or UCITS collective investment schemes
• Exchange-traded funds and investment trusts
• Regulated pension funds and investment bonds
• Structured deposits and structured products, subject to prior Trustee approval
• Depositary interests and certain alternative listed securities
• Venture Capital Trusts and investment-grade gold bullion

The availability of specific investments is at Invinitive's discretion and may change over time.

Certain investments are not permitted within the Invinitive SIPP. These include, but are not limited to:

• Residential property and overseas property
• Unregulated collective investment schemes and peer-to-peer lending
• Cryptocurrencies and contracts for difference
• Land banking, life settlements and carbon credits
• Tangible moveable property such as art, antiques or collectibles
• Loans to connected parties or unsecured third-party loans

Investments that could give rise to unauthorised payment charges or expose the scheme to disproportionate risk will not be accepted.

Invinitive reserves the right to decline, restrict or require the sale of any investment where:

• The investment falls outside the permitted categories
• Insufficient cash is available to support the transaction or ongoing costs
• The investment conflicts with regulatory requirements or trustee duties
• The investment is excessively complex, illiquid or costly to administer

If an investment is acquired without Invinitive's knowledge or falls outside permitted parameters, Invinitive may take steps to dispose of the investment in accordance with the scheme rules.

Benefits from the Invinitive SIPP are normally available once a member reaches the normal minimum pension age set by legislation. This age is currently 55, increasing to 57 from April 2028, although it may change again in the future. In limited circumstances, such as serious ill-health, benefits may be available earlier in accordance with HMRC rules.

Subject to scheme rules and prevailing legislation, members may have access to a range of benefit options, including:

• A pension commencement lump sum (PCLS), typically up to the maximum permitted under HMRC rules
• Flexi-access drawdown (FAD), allowing funds to remain invested while income is withdrawn
• Uncrystallised Funds Pension Lump Sums (UFPLS), which means you have a combination of both PCLS and flexi access drawdown in one payment

Members may choose to take benefits in stages rather than all at once, depending on their circumstances and preferences.

The tax treatment of pension benefits depends on individual circumstances, including tax residency and marginal tax rates at the time benefits are taken. Tax rules may change, and Invinitive does not provide tax advice or confirm the tax treatment of withdrawals.

Invinitive operates on an execution-only basis and does not advise on when or how to take benefits. Members are responsible for understanding the impact of withdrawals on the long-term sustainability of their pension fund and for considering whether professional advice is appropriate.

Pension transfers are subject to anti-scam, due diligence, anti-money-laundering and pension transfer regulations. Invinitive may request additional information from the member or third parties to satisfy these requirements. Where required by law or regulation, Invinitive may delay, pause or refuse a transfer request if necessary, including in circumstances where "red" or "amber" flags are identified in transfer screening.

Members initiating a transfer out are responsible for:

• ensuring the receiving scheme accepts the transfer
• understanding the features, charges and risks attached to the receiving pension arrangement
• ensuring all required information and documentation are provided promptly

Invinitive does not provide personal advice on whether transferring out is suitable or recommended.

Members should carefully consider that transferring benefits can result in the loss of guarantees or protected elements of their current pension arrangement. Examples may include:

• protected retirement ages
• guaranteed annuity rates
• enhanced death benefits
• other legacy guarantees or bonuses

Such benefits attached to certain legacy arrangements may not be available in the receiving scheme, potentially affecting retirement outcomes. Members should verify this with the ceding provider and, if in doubt, seek professional advice.

Where permitted by the scheme rules and regulatory framework, members may request a partial transfer or a full transfer. The ability to transfer part of a pension may depend on the nature of the arrangement and the terms of the ceding provider. Members should check with both Invinitive and the receiving scheme whether partial transfers are supported.

Transfers may be conducted in cash or, where supported by both schemes, in-specie, meaning assets are transferred without being sold. The feasibility of in-specie transfers depends on: whether the receiving scheme can hold the same assets; regulatory and operational constraints; and the nature of the assets themselves.

Where assets must be sold to facilitate a transfer, members should be aware that this may result in being out of the market for a period, which could impact investment performance.

Transfer timescales vary significantly depending on the ceding provider, the receiving scheme, the asset types involved and the completeness of documentation. Providers may complete transfers in a matter of weeks or longer. Invinitive and the receiving scheme will coordinate to progress the transfer, but neither can guarantee specific dates for completion. Delays may occur for reasons outside Invinitive's control.

Once a transfer is completed, the assets or cash will be allocated to the member's new pension arrangement in accordance with the scheme rules of the receiving provider, and the member should check that the transfer has been processed as expected.

The value of investments held within the Invinitive SIPP can go down as well as up. Past performance is not a reliable indicator of future results, and there is no guarantee that a member will receive back more than they have invested.

Taking withdrawals, particularly at a high rate, may reduce the longevity of the pension fund and increase the risk that funds are exhausted earlier than expected.

Tax rules and pension legislation may change in the future, which could affect the availability and taxation of benefits.

Holding excessive amounts of cash within a pension may reduce the real value of savings over time due to inflation, particularly after charges are taken.

The Invinitive SIPP is a UK-registered personal pension scheme within the meaning of Part 4 of the Finance Act 2004 and is established under trust.

The scheme is governed by Rules adopted by a Trust Deed dated 19 October 2022. In the event of any conflict between scheme documentation and prevailing legislation, current pensions statute law will override the scheme rules.

The scheme is administered and operated by Invinitive Financial UK Ltd (the Scheme Administrator) and the assets are held under trust by Invinitive Trustees Ltd (the Scheme Trustee). Invinitive Nominee Ltd acts as nominee in relation to certain investments where appropriate.

For reference, the key regulatory identifiers for the Invinitive SIPP are:

• FCA Firm Reference Number (FRN): 964301
• HMRC Pension Scheme Tax Reference (PSTR): 20007274RW
• The Pensions Regulator (TPR) Scheme Reference: 12019304

Invinitive Financial UK Ltd does not provide financial, investment or tax advice. Members seeking guidance may wish to consult an authorised financial adviser or access the free government-backed MoneyHelper / Pension Wise service.

Invinitive Financial UK Ltd and Invinitive Trustees Ltd act as data controllers in relation to personal data held for the purposes of administering the Invinitive SIPP. Personal data is processed in accordance with data-protection legislation and may be shared with third-party service providers where necessary for scheme administration or where required by law.

Members have the right to request access to their personal data and further information about how it is used.

The Invinitive SIPP is covered by the Financial Services Compensation Scheme (FSCS), subject to eligibility criteria and compensation limits. FSCS protection applies to certain regulated activities and does not cover investment performance or market losses.

Further details about complaints handling and FSCS protection are set out in the Terms & Conditions and on the FSCS website.