APPLICATION TO REQUEST THAT REQUIREMENTS ARE IMPOSED ON FIRM

Affinion International Limited hereby applies, pursuant to Part 4A of the Financial Services and
Markets Act 2000, for the requirements set out in the schedule below.

SCHEDULE

General

1.
This schedule sets out the terms of the requirements to be imposed on Affinion
International Limited, to take immediate effect.

Affinion International Limited (FRN 311584)

Requirements included in the Firm's permission at the request of the Firm under section
55L of the Financial Services and Markets Act 2000




Terms referred to:

1.
In these Requirements:

1.1
‘Act’ means the Financial Services and Markets Act 2000 (as amended from time
to time).

1.2
‘Agreed Scheme Claim’ is defined at page 1 of the Scheme Document at Part 1 of
Annex B.

1.3
'Amendment Date' is defined at page 2 of the Scheme Document at Part 1 of
Annex B.

1.4
‘Applicable Bar Date’ means the Bar Date which is applicable to a Scheme
Creditor.

1.5
‘Authority’ means the body corporate previously known as the Financial Services
Authority and renamed on 1 April 2013 as the Financial Conduct Authority.

1.6
‘Bar Date’ for the Scheme of Arrangement means each of the following, as
applicable, provided that, in each case, if the Bar Date falls on a day which is not a
Business Day, it shall be deemed to fall on the next Business Day:

1.6.1
subject to paragraphs 1.6.2 and 1.6.3, the date falling seven months
after the Scheme Effective Date (the ‘Non-Exceptional Circumstances
Bar Date’);

1.6.2
subject to paragraph 1.6.3, if, in respect of a Scheme Creditor, one or
more of the Exceptional Circumstances apply, the date falling thirteen
months after the Scheme Effective Date in respect of such Scheme
Creditor (the 'Exceptional Circumstances Bar Date'); or

1.6.3
if, in respect of a Scheme Creditor, such Scheme Creditor has been
requested by the Scheme Administrators to re-submit a new Claim Form
in accordance with Clause 3.5 of the Scheme of Arrangement, and the 30
day period for return of such Claim Form falls on a date:

(A)
after the expiry of the Non-Exceptional Circumstances Bar Date,
or

(B)
if one or more of the Exceptional Circumstances apply, after the
expiry of the Exceptional Circumstances Bar Date,

the date upon which such 30 day period expires in respect of such
Scheme Creditor.

1.7
‘Business Day’ is defined at page 3 of the Scheme Document at Part 1 of Annex
B.

1.8
'Business Partners' means

1.8.1
Barclays Bank Plc;

1.8.2
Santander UK Plc;

1.8.3
The Royal Bank of Scotland Plc;

1.8.4
HSBC Bank Plc;

1.8.5
Clydesdale Bank PLC;

1.8.6
Tesco Personal Finance plc;

1.8.7
Capital One (Europe) Plc;

1.8.8
Lloyds Bank Plc;

1.8.9
Northern Bank Limited T/AS Danske Bank;

1.8.10
The Co-operative Bank Plc; and

1.8.11
AIB Group (UK) Plc T/AS Allied Irish Bank GB in Great Britain and First
Trust Bank in Northern Ireland.

1.9
‘Business Partner Affiliate’ means, in relation to any Business Partner, a
Subsidiary of that Business Partner or a Holding Company of that Business Partner
or any other Subsidiary of that Holding Company, including but not limited to the
Business Partner Undertaking Affiliates.

1.10
'Business Partner Undertaking Affiliate' means those Business Partner Affiliates
who have signed a Deed of Undertaking, being:

1.10.1
Bank of Scotland plc;

1.10.2
National Westminster Bank Plc;

1.11
'Card Security Product' means a card security product provided by the Firm which
was sold by the Firm or a Business Partner or a Business Partner Affiliate in the
UK under one of the following product names, described more particularly in Annex
A:

1.11.5
Sentinel Excel

1.11.6
Safe and Secure Plus

1.12
‘Claim Form’ means the claim form in respect of a Scheme Card Security Product
in the form set out at page 29 of the Scheme Document at Part 1 of Annex B.

1.13
'Court' means the High Court of Justice in England and Wales.

1.14
'Court Order' means the order of the Court sanctioning the Scheme under section
899 of the Companies Act 2006 (as amended from time to time).

1.15
'Deed of Undertaking' means a deed of undertaking executed in accordance with
Clauses 2.3 and 2.4 of the Scheme Document at Part 1 of Annex B.

1.16
‘DISP’ means the Dispute Resolution Sourcebook from the Authority’s Handbook of
Rules and Guidance.

1.17
‘Dispute Resolution Procedure’ is defined at page 5 of the Scheme Document at
Part 1 of Annex B.

1.18
‘Disputed Scheme Claim’ is defined at page 5 of the Scheme Document at Part 1
of Annex B.

1.19
‘Exceptional Circumstances’ is defined at page 5 of the Scheme Document at
Part 1 of Annex B.

1.20
‘Excluded Product Holder’ is defined at page 5 of the Scheme Document at Part
1 of Annex B.

1.21
‘Firm’ means Affinion International Limited, a company registered in England with
registered number 1008797 and registered office at Charter Court, 50 Windsor
Road, Slough SL1 2EJ.

1.22
'Holding Company' means in relation to a person, any other person in respect of
which it is a Subsidiary.

1.23
‘Ombudsman’ means the Financial Ombudsman Service.

1.24
‘Permission’ means the Firm's permission under Part 4A of the Act.

1.25
‘Product Holder’ is defined at page 7 of the Scheme Document at Part 1 of Annex
B.

1.26
‘Practice Statement Letter’ means the letter issued to each Scheme Creditor in
accordance with the Practice Statement (Schemes of Arrangement with Creditors)
dated 15 April 2002.

1.27
'Redress Amount' is defined at page 8 of the Scheme Document at Part 1 of
Annex B.

1.28
‘Redress Determination’ is defined at page 8 of the Scheme Document at Part 1
of Annex B.

1.29
‘Redress Scheme’ means the redress scheme promoted by Schemeco that the
Firm is required to establish and operate (along with the Business Partners and
Business Partner Undertaking Affiliates) under these Requirements, which
incorporates the Scheme of Arrangement further details of which are set out in
Annex B, and which is a “consumer redress scheme” for the purposes of DISP.

1.30
'Registrar of Companies' means the Registrar of Companies in England and
Wales.

1.31
‘Requirement Date’ means the date that these Requirements come into effect.

1.32
‘Scheme Administrators’ means Kevin Gill and Ben Cairns of Ernst & Young LLP
of 1 More London Place, London SE1 2AF or such other persons appointed
pursuant to the terms of the Scheme of Arrangement.

1.33
‘Scheme of Arrangement’ means the solvent scheme of arrangement under Part
26 of the Companies Act 2006 described more particularly in Annex B.

1.34
‘Scheme Adjudicator’ is defined at page 9 of the Scheme Document at Part 1 of
Annex B.

1.35
‘Scheme Card Security Product’ means any Card Security Product:

1.35.1
Purchased (or renewed) directly from the Firm; or

1.35.2
Purchased (or renewed) from the Firm, following an introduction by a
Business Partner or Business Partner Affiliate; or

1.35.3
Purchased (or renewed) directly from a Business Partner or a Business
Partner Affiliate.

1.36
‘Scheme Claim’ is defined at page 9 of the Scheme Document at Part 1 of Annex
B.

1.37
‘Schemeco’ means AI Scheme Limited, a company registered in England with
registered number 09295299 and registered office at 35 Great St Helen’s, London
EC3A 6AP.

1.38
'Scheme Creditor’ means any Product Holder, other than an Excluded Product
Holder, who purchased (or renewed) a Scheme Card Security Product on or after
14 January 2005 but before the Amendment Date, whether or not they still hold a
Scheme Card Security Product, who has a Scheme Claim.

1.39
‘Scheme of Arrangement Effective Date’ means the date on which the Court
Order is delivered to the Registrar of Companies in accordance with Clause 2.2 of
the Scheme Document at Part 1 of Annex B.

1.40
‘Selling Issues’ is defined at page 10 of the Scheme Document at Part 1 of Annex
B.

1.41
‘Subject Matter’ of the Redress Scheme means any claim, action or other right of

any description however arising in relation to, in connection with, or arising from
Selling Issues which a Scheme Creditor has against the Firm or a Business Partner
or Business Partner Affiliate under, in connection with, or arising from a Scheme
Card Security Product, but only to the extent that the claim, action or other right
relates to loss suffered on or after 14 January 2005. For the avoidance of doubt,
any claim, action or other right of any description however arising relating to loss
suffered before 14 January 2005 is outside the scope of (and unaffected by) the
Scheme of Arrangement, and therefore outside the Subject Matter of (and
unaffected by) the Redress Scheme.

1.42
'Subsidiary' means a subsidiary within the meaning of section 1159 of the
Companies Act 2006.

1.43
‘these Requirements’ means the requirements and provisions in this document
including its Annexes.

2.
Expressions defined in the Authority’s Handbook of rules and guidance or at paragraph 1
above have the meanings given to them unless the context otherwise requires.

3.
The Firm is an authorised firm which sold the Card Security Products.

4.
The Firm considers that customers may be due compensation in respect of the Card
Security Products as a result of Selling Issues.

5.
Although no formal determination that there have been Selling Issues has been made by
the Authority in relation to the Card Security Products, the Firm has been holding voluntary
discussions with the Authority and has chosen, in the interests of fairness to customers
and with the agreement of the Authority, to undertake a customer contact and consumer
redress scheme to compensate Scheme Creditors who have Scheme Claims and who fall
within paragraph 1.35.1 above.

6.
Following discussions between the Authority, the Firm and the Business Partners, on
behalf of themselves and their Business Partner Affiliates, and without any admission of
liability on the part of the Firm, the Business Partners or the Business Partner Affiliates:

6.1
the Business Partners, on behalf of themselves and their Business Partner
Affiliates, have agreed to contribute to a consumer redress scheme to compensate
Scheme Creditors who have Scheme Claims and who fall within paragraphs
1.35.2-1.35.3 above, on the basis that such consumer redress scheme is combined
with the Firm's consumer redress scheme described at paragraph 5 above and that
such combined consumer redress scheme takes the form of and is implemented
via the Scheme of Arrangement;

6.2
the Authority, the Firm and the Business Partners, on behalf of themselves and
their Business Partner Affiliates, have agreed to the combined consumer redress
scheme described at paragraph 6.1 above, with the Firm and the Business
Partners, on behalf of themselves and their Business Partner Affiliates, agreeing to
share the administrative costs of the combined consumer redress scheme; and

6.3
the Authority, the Firm and the Business Partners, on behalf of themselves and
their Business Partner Affiliates, have agreed to implement the combined
consumer redress scheme via the Scheme of Arrangement. The Firm and the
Business Partners, on behalf of themselves and their Business Partner Affiliates,
have each agreed to contribute to the costs of the Scheme Administrators.

7.
For the purposes of concluding the contracts relating to the Card Security Products
between Product Holders and the Firm, the Business Partners and Business Partner
Affiliates acted on behalf of the Firm.

8.
The Firm agrees to procure that Schemeco will promote the Redress Scheme. Schemeco
has been specifically set up for the purposes of promoting the Redress Scheme.

9.
Schemeco has assumed by deed poll any liabilities which the Firm may have in relation to
the Scheme Card Security Products resulting in Schemeco being jointly and severally liable
with the Firm for these liabilities on a primary basis.

10.
Accordingly, the Firm has applied to the Authority for these Requirements. The Authority
has consulted with the Prudential Regulation Authority and the Authority has accepted the
application.

11.
Pursuant to section 404F(7)(b) of the Act, a provision may be included in the Firm’s
Permission corresponding to section 404B of the Act, binding the Ombudsman to
determine certain complaints for which the Firm is responsible that are referred to the
Ombudsman by reference to what, in the opinion of the Ombudsman, the determination
under the "consumer redress scheme" should be or should have been.

12.
Under sections 55L and 404F(7) of the Act, the following requirements and provisions are
included in the Firm’s permission:

12.1
the Firm must establish and operate (together with the Business Partners and their

Business Partner Undertaking Affiliates) the Redress Scheme by:

12.1.1
procuring that Schemeco will:

(A) issue the Practice Statement Letter to each Scheme Creditor on or

before the deadline specified in paragraph 14.1 below;

(B) file an application within 8 weeks of the date of these Requirements

with the Court seeking permission to summon a meeting of the
Scheme Creditors to consider the Scheme of Arrangement in such
manner as the Court directs;

(C) within 8 weeks of the Court granting Schemeco permission to call a

meeting of the Scheme Creditors to consider the Scheme of
Arrangement, send a notice to Scheme Creditors summoning them
to the meeting, and providing them with an explanatory statement
regarding the effect of the Scheme of Arrangement and a voting
form;

(D) if the Scheme of Arrangement is approved at the meeting of the

Scheme Creditors, attend a further Court hearing seeking the Court's
sanction of the Scheme of Arrangement on or before the deadline
specified in paragraph 14.5 below;

(E) if the Scheme of Arrangement is sanctioned by the Court at the

further Court hearing, deliver the Court Order to the Registrar of
Companies on or before the deadline specified in paragraph 14.6
below;

(F) as soon as reasonably practicable (and in any event within 8 weeks)

after the Scheme of Arrangement becomes effective, give notice in
writing to the Scheme Creditors to notify them that the Scheme of
Arrangement has become effective;

12.1.2
entering into and complying with, a deed of undertaking, under which it
will (in particular):

(A) agree to instruct counsel to appear on its behalf at the hearing at

which the Scheme of Arrangement is to be sanctioned by the Court,
to give an undertaking to the Court to consent to the Scheme of
Arrangement and be bound by the Scheme of Arrangement on the
terms and conditions and in such form as may be sanctioned by the
Court and agreed by the Firm and the Business Partners on behalf of
themselves and their Business Partner Affiliates;

(B) obtain HMRC Clearance (as defined in the Scheme Document at Part

1 of Annex B), and deliver HMRC Stamp Duty Clearance (as defined
in the Scheme Document at Part 1 of Annex B) to the Registrar of
Companies, in each case on or before the deadline specified in
paragraph 14.6 below;

(C) consent to, and undertake to be bound by the Scheme of

Arrangement on the terms and conditions and in such form as may
be sanctioned by the Court and agreed by the Firm and the Business
Partners on behalf of themselves and their Business Partner
Affiliates;

(D) undertake to pay any Redress Amount obliged to be paid by it, and

ensure that Schemeco procures that each Business Partner pays the
Redress Amount that the Business Partner is obliged to pay (on

behalf of themselves and their Business Partner Affiliates), pursuant
to and in accordance with the terms of the Scheme of Arrangement
(including the timelines for payment set out therein); and

(E) do or procure to be done all such acts and things as may be

reasonably necessary to be executed or done by it for the purpose
of giving effect to the Scheme of Arrangement including, but not
limited to, procuring that a website and telephone helpline will be
established in order to, among other things, publicise the Redress
Scheme, explain its key features, and assist Scheme Creditors
through each stage of the process.

12.1.3
complying or procuring compliance with the requirements set out in
Annex B that do not form part of the Scheme of Arrangement.

12.2
certain complaints are to be dealt with by the Ombudsman as described in Annex
C, on the basis that the Redress Scheme corresponds to or is similar to a
"consumer redress scheme" under section 404 of the Act.

Commencement and duration of these Requirements

13.
These Requirements come into effect immediately.

14.
These Requirements cease to have effect if:

14.1
the Practice Statement Letter is not issued by Schemeco within 12 weeks of these
Requirements;

14.2
court approval to the meeting of Scheme Creditors is not obtained by Schemeco by
22 July 2015;

14.3
the meeting of Scheme Creditors does not take place by 6 October 2015;

14.4
the Scheme of Arrangement is not approved by the requisite majority of Scheme
Creditors at the meeting of Scheme Creditors;

14.5
the Scheme of Arrangement is not sanctioned by the Court by 29 October 2015; or

14.6
the Scheme of Arrangement does not become effective by 31 October 2015.

15.
If these Requirements cease to have effect under paragraph 14:

15.1
the Authority agrees that, on the application of the Firm, or of its own initiative, it
will cancel these Requirements and remove them from the Firm’s Permission, and
the Firm's obligations under these Requirements shall cease; and

15.2
upon these Requirements being cancelled and removed from the Firm's
Permission, the Ombudsman shall consider complaints that would otherwise have
been covered by the Redress Scheme in accordance with DISP.

16.
Subject to paragraph 14, these Requirements remain in force unless otherwise varied or
cancelled. The Authority retains the discretion to vary or cancel these Requirements at its
own initiative in accordance with section 55L(3)(b) and (c) of the Act.


Annex A: Summary of Card Security Products

A.1 Card Security Products are the Firm's credit card protection product, which typically featured

the following benefits:

A.1.1
being able to cancel all lost or stolen debit or credit cards and request replacements
in one phone call to the Firm’s contact centres which are open 24 hours a day, 7 days
a week;

A.1.2
insurance cover to replace a lost or stolen handbag, purse, wallet or briefcase;

A.1.3
emergency cash advance service when cards are lost or stolen;

A.1.4
insurance cover to replace personal cash lost or stolen at the same time as a card is
lost or stolen;

A.1.5
insurance cover for the telephone and communication costs of dealing with the loss of
a card and personal possessions including identity documents e.g. passports;

A.1.6
insurance cover for replacement of lost or stolen car or home keys and replacement
of locks for a customer’s home; and

A.1.7
insurance cover for fraudulent use of lost or stolen cards (now removed from all
products).

A.2 Card Protection was sold under the following product names: Card Protection, Sentinel,

Sentinel Gold, Sentinel Protection, Sentinel Excel, Safe and Secure Plus.

Annex B: Redress Scheme, including terms of the Scheme of Arrangement

Part 1: Terms of the Scheme of Arrangement

Part 2: Complaints and Redress Determinations

1. From and including the Requirement Date, DISP 1.1.11A R shall apply in respect of any

complaint made by a Scheme Creditor to the Firm, a Business Partner, a Business Partner
Undertaking Affiliate, or the Scheme Administrators (when acting on their behalf) where the
subject matter of the complaint falls within the Subject Matter of the Redress Scheme. Where
part of a complaint made by a Scheme Creditor to the Firm, a Business Partner, Business
Partner Undertaking Affiliate, or the Scheme Administrators (when acting on their behalf) falls
within the Subject Matter of the Redress Scheme, DISP 1.1.11A R shall apply in respect of that
part and references below to a complaint falling within this paragraph 1 shall be construed as
references to that part.


2. The Firm must establish and maintain a fair and intelligent filtering of cases in order to identify

whether a complaint (or parts of a complaint) received after the Requirement Date falls within
the Subject Matter of the Redress Scheme


3. If the Firm receives a complaint (or part thereof) falling within Paragraph 1 prior to the

Applicable Bar Date:

3.1. within 10 Business Days of the receipt of the complaint, the Scheme Creditor will be sent

a letter acknowledging the complaint, notifying the Scheme Creditor that the complaint
falls to be dealt with under the Scheme of Arrangement, and providing information about
the process for making a Scheme Claim;

3.2. if the Scheme Creditor subsequently submits a Scheme Claim under the Scheme of

Arrangement which is admitted as an Agreed Scheme Claim, the Scheme Administrators
will pay redress in accordance with the Scheme of Arrangement. If, having made an
Agreed Scheme Claim, the Scheme Creditor subsequently attempts to pursue his earlier
complaint, or makes a further complaint falling within the Subject Matter of the Redress
Scheme, the entity responsible for the complaint (and not, for the avoidance of doubt, the
Scheme Administrators) shall issue a Redress Determination notifying the Scheme
Creditor that his complaint fell to be dealt with under the Scheme of Arrangement, that he
has already made an Agreed Scheme Claim and has released the relevant entity from
further liability as a result of making the Agreed Scheme Claim;

3.3. if the Scheme Creditor subsequently submits a Scheme Claim under the Scheme of

Arrangement which becomes a Disputed Scheme Claim, the Scheme Adjudicator (on
behalf of the Firm, a Business Partner and/or a Business Partner Undertaking Affiliate, as
appropriate) will send a Redress Determination to a Scheme Creditor containing its
determination of the Disputed Scheme Claim ;

3.4. if, by 8 weeks prior to the Bar Date, the Scheme Creditor has not submitted a Scheme

Claim under the Scheme of Arrangement, the Scheme Administrators will send the
Scheme Creditor a letter reminding the Scheme Creditor of the information contained in
the letter at paragraph 3.1 above and reminding the Scheme Creditor of the impending
Bar Date for submitting a Scheme Claim under the Scheme of Arrangement; and

3.5. if the Scheme Creditor does not submit a Scheme Claim under the Scheme of

Arrangement, the entity responsible for the complaint shall, within 8 weeks after the
Exceptional Circumstances Bar Date, issue a Redress Determination notifying the
Scheme Creditor that his complaint fell to be dealt with under the Scheme of
Arrangement, that the time for making a claim under the Scheme of Arrangement has
passed and that his complaint is now time-barred.

4. If the Firm receives a complaint (or part thereof) falling within Paragraph 1 after the Applicable

Bar Date:

4.1. if the Scheme Creditor made a Scheme Claim prior to the Exceptional Circumstances Bar

Date and the Scheme Creditor has not already received a Redress Determination, the
entity responsible for the complaint shall issue within 8 weeks of receiving the complaint a
Redress Determination notifying the Scheme Creditor that his complaint fell to be dealt
with under the Scheme of Arrangement, that he has already made a Scheme Claim and
the outcome of the Scheme Claim; and

4.2. if the Scheme Creditor did not make a Scheme Claim under the Scheme of Arrangement,

the entity responsible for the complaint shall issue within 8 weeks of receiving the
complaint a Redress Determination notifying the Scheme Creditor that his complaint fell to
be dealt with under the Scheme of Arrangement, that the time for making a claim under
the Scheme of Arrangement has passed and that his complaint is now time-barred.

5. If these Requirements cease to have effect pursuant to Paragraphs 12 or 14 of these

Requirements:
5.1. complaints (or any part thereof) falling within Paragraph 1 shall be dealt with by the entity

responsible for the complaint in accordance with DISP as if the complaint had been
received on the date that the Requirements cease to have effect; and

5.2. notwithstanding paragraph 5.1 above, the Firm must not take into account any period

during which the Requirements were in effect for the purposes of relying on any limitation
period (or periods) or time limits within which complainants must:
5.2.1. make complaints about matters within the Subject Matter of the Redress Scheme;
5.2.2. refer such a complaint to the Ombudsman; or
5.2.3. bring claims before the court about matters within the Subject Matter of the Redress

and the Firm must not otherwise limit any redress that may be due to the complainant,
when complying with DISP or otherwise, because of any period during which the
Requirements were in effect.

6. For the avoidance of doubt, nothing in these Requirements affects the Firm’s obligations to

resolve complaints (or parts of complaints) whose subject matter falls outside of the Subject
Matter of the Redress Scheme in accordance with their existing obligations, in particular under
DISP.

This Part 3 of Annex B describes the general scheme claims decisioning procedures to be followed
by the Scheme Administrators in administering the Scheme of Arrangement. However, reasonable
adjustments will be made by the Scheme Administrators to the administration process where such
adjustments are necessary to accommodate the disability of a Scheme Creditor that is notified or
otherwise drawn to the attention of the Scheme Administrators (as set out at section 10.13 of the
Scheme Document at Part 1 of Annex B).

1. Claim Form acceptance process

1.1. Claim Forms received by the Scheme Administrators will be scanned upon receipt. The

scanning process will be used to identify whether the Claim Form has been appropriately
completed.


1.2. Where the scanning process identifies that the Claim Form has been appropriately

completed, the Claim Form will then be processed in accordance with paragraph 2 below.


1.3. The scanning process will identify that the Claim Form has not been appropriately

completed where:
1.3.1. The Scheme Creditor has not signed the Claim Form;
1.3.2. The Claim Form is torn or in some other damaged state which renders the Claim

Form illegible; or

1.3.3. The Scheme Creditor has not written any comments in the box on the Claim Form.

In these cases, the Claim Form will be reviewed by the Scheme Administrators. Provided
that the Scheme Creditor has written comments in the box on the Claim Form and has
signed the Claim Form such that the Scheme Creditor’s intentions in submitting the Claim
Form can be established, the Claim Form will then be processed in accordance with
paragraph 2 below. In other cases, the Claim Form will not be accepted for processing
and the Scheme Creditor will be given no fewer than one further opportunity to re-submit
his or her claim, by being sent a new Claim Form for completion.

2. Process for determining the validity of claims

2.1. Each Claim Form which is accepted for processing under the process described in

paragraph 1 will then be manually reviewed by the Scheme Administrators. This will be a
brief review, the purpose of which is to ensure that only claims of Scheme Creditors who
are alleging Selling Issues are accepted as Scheme Claims.

2.2. Scheme Creditors will be treated as alleging Selling Issues and accepted as making a

Scheme Claim where the Scheme Creditor’s comments on the Claim Form suggest that
the Scheme Creditor:

2.2.1. wants his or her money back;

2.2.2. is dissatisfied with the way in which the Scheme Card Security Product was sold to

him or her, including (but not limited to) where the Scheme Creditor considers he
received unsuitable advice in relation to the sale of the Scheme Card Security
Product;

2.2.3. considers that the way in which the Scheme Card Security Product was sold failed to

comply with applicable regulatory rules or with the Authority’s Principles for
Businesses or was otherwise in breach of contract or any tortious duty of care or any
other requirement under the general law (taking into account relevant materials
published by the Authority, other relevant regulators, the Ombudsman and former
schemes, and including industry codes of practice);

2.2.4. alleges that the information provided about the Scheme Card Security Product failed

to be clear, fair and not misleading, or that such information was incomplete (for
example by omitting to mention material limitations or exclusions on the features or
benefits provided); or

2.2.5. alleges that the sale was concluded after applying inappropriate pressure.

2.3. A Scheme Creditor will not be treated as alleging Selling Issues (and will not be accepted

as making a Scheme Claim or otherwise fall within the Subject Matter of the Redress
Scheme) where, for example:

2.3.1. he has returned a Claim Form but the comments on it indicate that he is happy with

the Scheme Card Security Product and/or is not seeking redress;

2.3.2. he has returned a Claim Form but the comments on it deal with a product other than

a Scheme Card Security Product; or

2.3.3. he has written unrelated or abusive text in his Claim Form which does not suggest

any allegation of Selling Issues.

2.4. For the avoidance of doubt, Scheme Creditors will be treated as alleging Selling Issues

and accepted as making a Scheme Claim where:

2.4.1. the Scheme Creditor alleges Selling Issues, but also indicates that he wants to keep

the Scheme Card Security Product. In such cases, the Scheme Creditor will be
accepted as making a Scheme Claim and eligible for compensation, but will be
notified when sent any compensation payable that his Scheme Claim has been
treated as a request to cancel the Scheme Card Security Product;

2.4.2. the Scheme Creditor alleges Selling Issues, but indicates that other features of the

Scheme Card Security Product such as the facility to cancel lost or stolen cards and
order replacements in one phone call was of benefit to them. In such cases, the
Scheme Creditor will be accepted as making a Scheme Claim and eligible for
compensation, but will be notified when sent any compensation payable that his
Scheme Claim has been treated as a request to cancel the Scheme Card Security
Product; and

2.4.3. the Scheme Creditor alleges Selling Issues, but also includes abusive or unrelated

text in the Claim Form.

2.5. All Claim Forms which are identified as not alleging Selling Issues shall be subject to a

second review by the Scheme Administrators for quality assurance purposes.


3. Valid claims

3.1. A Scheme Creditor whose Claim Form is (a) accepted for processing under the steps

identified in section 1 above and (b) identified as alleging Selling Issues (and thereby
making a Scheme Claim) under the steps identified in section 2 above will be eligible to be
paid compensation under the terms of the Scheme Document in Part 1 of this Annex B.
The amount of compensation payable shall be calculated in accordance with the terms set
out on pages 7 and 8 of the Scheme Document at Part 1 of this Annex B.


4. Claim Forms returned after the Bar Date

4.1. If Scheme Creditors return their Claim Forms to the Scheme Administrators after the Bar

Date, those Claim Forms will not be accepted or reviewed in accordance with the steps
described in sections 1 to 3 above, as such those Scheme Creditors will not be entitled to
compensation under the terms of the Scheme of Arrangement.

5. Dispute Resolution Procedure

5.1. If a Scheme Creditor disagrees with the rejection of his Claim Form by the Scheme

Administrators or with the amount of compensation payable to him, he may initiate the
Dispute Resolution Procedure.

Part 4: Reminder Letters

1. If a Scheme Creditor meets any of the following three conditions:

1.1. a Scheme Creditor has submitted a voting form under the Scheme of Arrangement;

1.2. a Scheme Creditor has submitted a complaint to the Firm about Selling Issues after the

effective date of these Requirements; or


1.3. a Scheme Creditor has been sent a replacement compensation Claim Form under the

Scheme of Arrangement because the Scheme Creditor had previously submitted a Claim
Form that was deemed to be spoiled for the purposes of Clause 3.5 of the Scheme of
Arrangement;


but has not, by 8 weeks prior to the Non-Exceptional Circumstances Bar Date, submitted a
Scheme Claim under the Scheme of Arrangement, the Scheme Administrators will send the
Scheme Creditor a letter reminding the Scheme Creditor of the impending Non-Exceptional
Circumstances Bar Date for submitting a Scheme Claim under the Scheme of Arrangement.

Part 5: Updates to the Authority

1. The Scheme Administrators will provide the Authority with periodic updates on the operation of

the Redress Scheme on such terms and in such manner as may be agreed between the
Scheme Administrators and the Authority.

Annex C: Complaints to be dealt with by the Ombudsman

C.1 This annex applies only where:



C.1.1 a complaint is referred to the Ombudsman by or on behalf of a Scheme Creditor

(whether or not the Scheme Creditor has made a claim under the Scheme of
Arrangement);

C.1.2 the complaint is referred to the Ombudsman on or after the Requirement Date; and

C.1.3 within 14 days of the Ombudsman telling the Firm in writing that the complaint has

been referred to the Ombudsman, the Firm tells the Ombudsman in writing that the
complaint (or part of the complaint) is covered by the Redress Scheme.

C.2 Subject to paragraph C.1 above, this annex applies where a Scheme Creditor:


C.2.1 makes a complaint to the Ombudsman in respect of an act or omission of the Firm

and, at the time the complaint is made, the subject matter of the complaint is within
the Subject Matter of the Redress Scheme and therefore falls to be dealt with (or has
been dealt with) under the Redress Scheme;

C.2.2. is not satisfied with the Redress Determination issued by the Firm under the Redress

Scheme; or

C.2.3 considers that the Firm has failed to make and issue a Redress Determination in

accordance with the Redress Scheme.

C.3 The Ombudsman is required to determine the complaint under section 404B of the Act and

the provisions of DISP as if the Redress Scheme were a "consumer redress scheme" under
section 404 of the Act.

C.4 The Ombudsman will usually determine a complaint only by reference to what is, in his

opinion, fair and reasonable in all the circumstances of the case. However, in these
circumstances the Ombudsman is required to determine the complaint by reference to what,
in the opinion of the Ombudsman, the determination under the Redress Scheme should be or
should have been.

C.6. Where a complaint is made to the Ombudsman and only part of the complaint is a complaint

falling within this annex, the Ombudsman will deal with that part of the complaint in
accordance with this annex and will deal with the remainder of the complaint in the usual way
in accordance with DISP.