TrustInvest Product Terms

Part 1: TrustInvest product terms

Hello! Welcome to TrustInvest! We are excited you are here to start your investment journey – whether it is to invest in mutual funds, stocks or exchange-traded funds. These product terms tell you about TrustInvest, our responsibilities, your responsibilities and other important information.

If you invest in mutual funds, Part 1 and Part 2 of these terms apply to you. If you invest in stocks or exchange-traded funds, Part 1 and Part 3 apply to you.

Who can open an account? 🙋‍♂️🙋‍♀️

You can only open a TrustInvest account if you meet the following conditions.

  1. You are at least 18 years old.

  2. You are not a US person. (This means you are not a US citizen, do not hold a Green Card issued by the US Government, and do not meet the substantial presence test on the IRS website.)

  3. You have a savings account with us that is not suspended, frozen or considered by us to be inactive, not in good standing or cancelled.

Using your TrustInvest account 💵
  1. You can only fund your TrustInvest account (which includes the investment account and trading account) through your savings account, and can only transfer money from your TrustInvest account to your savings account.

  2. We may sometimes ask you to provide further documents before you can buy or sell investments (for example, if our appointed third parties ask us to or if we must do so by law).

  3. We can suspend or restrict the use of all or part of your TrustInvest account at any time and without giving you notice or telling you why, but only if we are acting in good faith and within the law. If we do this, we have the right to sell your investments at the price that applies at that time and add the proceeds of the sale to your investment or savings account, after deducting any taxes, fees or charges that you have to pay under these terms. We will not be responsible for any loss you suffer as a result.

  4. Your TrustInvest investments can only be sold or traded through us. This means that you cannot transfer your investments elsewhere.

Instructions and orders 📈📉
  1. We will decide whether to accept, rely on and act on any instructions you give us through the Trust app. For example, you may instruct us to buy or sell any investment (we also refer to these as orders to buy or sell), or to pay money into or withdraw money from your TrustInvest account. You agree to give us instructions that are complete and correct. You are responsible for making sure that your instructions are accurate. We will not check whether they are accurate, genuine or valid. Once you give us an instruction, we will consider it final and binding. You can only challenge it if you can clearly show that we acted negligently or fraudulently, or made a serious mistake.

  2. Although we will try to act on your instructions to buy or sell your investments as soon as possible after we receive those instructions, we, the fund manager, the exchange (for example, stock exchange), the issuer of the securities, the execution broker and any other third parties that we appoint do not have to accept or act on all or any part of your instructions. We are not responsible for any losses you suffer because of any action that we (or any of these third parties) take or fail to take.

  3. When you give us instructions to buy or sell a fund or any listed equity (together referred to as investments), you confirm that you understand what the investment is about and the risks involved. We do not make recommendations or give advice, and you acknowledge that you are not relying on any advice or recommendation from us. This means that our staff and representatives are not allowed to give you investment or financial advice and you must make your own decisions based on your personal goals and financial situation. If you’re not sure whether an investment is right for you, we recommend that you speak to an independent financial adviser or do your own research.

  4. You authorise us to deduct certain amounts from your TrustInvest account when you successfully place a buy order. These amounts may include any taxes, fees or charges that you must pay under these terms. Fees include costs related to buying, holding, or selling your investments.

  5. Prices, exchange rates, fees and other factors can change, and this may affect your returns. We will follow your instructions, but we won’t warn you if we believe it is not a good time to carry out the transaction or it could lead to a loss. Whenever you give us any instructions, you are confirming that you agree to these product terms and accept the risks that come with the investment.

  6. We do not have to act on your instructions within the same day if you provide them after the cut-off time for the fund or outside the trading hours of the exchange, including if it is a public holiday (including public holidays for the fund or the exchange). If this applies, we may act on the instructions on the next business day.

  7. You cannot consider us to have accepted your instructions until we have acknowledged them on the Trust app.

  8. For buy orders, you don’t own or have any rights to the investments until we send you a confirmation that your buy order has been completed. We will only add investments to your TrustInvest account once we receive them from the relevant party or parties.

  9. For sell orders, we or any third parties that we appoint will only deduct the investments from your TrustInvest account once we receive confirmation from the fund manager or exchange that your orders have been executed (legally completed).

  10. We may combine your order with orders from our other customers. We may allocate or distribute your investment with the investments of our other customers. This allocation or distribution may result in a lower investment than stated in your order. You accept the risk that this may result in losses to you.

  11. We can accept all or part of your order or reject it if this is necessary to stay within any trading or position limit or restriction placed on us. You must not go beyond any limits or restrictions that apply. These limits may be set by us, the fund manager, the exchange, the issuer of securities, the execution broker or any other third parties that we appoint, and also by any market, legal or regulatory requirements. If we set the limits, they are only for our protection. We will have no responsibility for making sure you are keeping to any limits on your trading activities that are set by you or any law that applies.

  12. There may be situations in which we cannot act on your instructions. Or we may, without giving you notice or providing any reason:

    1. refuse, suspend or delay acting on any instruction;

    2. refuse to provide or allow you to use your TrustInvest account;

    3. reverse or interrupt any transaction on your TrustInvest account; or

    4. act on only some or part of any instruction you give us.

  13. We may not act on your instructions if any of the following apply. These are only examples and there may be other circumstances where we do not carry out your instructions in full.

    1. We reasonably believe that your instructions are inconsistent, shown in the wrong currency, incomplete, incorrect, unclear, fraudulent or not given in a way we accept.

    2. We think you have broken these product terms.

    3. It is unreasonable and impractical for us to do so.

    4. It would go against our business practice or any of our internal policies.

    5. It would break any law that applies (such as laws relating to money laundering, financing terrorism, tax and sanctions).

    6. We believe that the instructions may be fraudulent or unauthorised.

    7. You have not given us all the documents or information we need.

    8. You are not eligible to invest in the specifc investment.

    9. There is not enough money in your TrustInvest account.

    10. Your TrustInvest account is suspended or frozen, or cannot be accessed for any reason.

    11. In our reasonable professional opinion, it is an emergency or there are exceptional market conditions.

    12. Circumstances beyond our control prevent us from carrying out your instructions.

  14. We are not responsible for:

    1. missing any deadlines for placing orders unless the delay is directly caused by us committing fraud, being reckless or being grossly negligent;

    2. making sure that the orders you place are carried out;

    3. any loss of profit or opportunity that you may suffer due to any telecommunications or other system used to accept or process your instructions being delayed, breaking down, failing, being interrupted or not working properly (this applies whether the problem is with our or a third party’s system); and

    4. any drop in the value of your investment or your investment failing to achieve a certain level of income or profit, unless this is caused by us committing fraud, being reckless or being grossly negligent.

  15. We will never be responsible to you for any losses you suffer because of any action we take or fail to take under this section. You must indemnify us against (protect us from and compensate us for) all losses, including any taxes that apply, due to any action we take or fail to take under this section.

  16. If we (or the fund manager, the exchange or the issuer of securities) reject your instructions, we will refund your money to your TrustInvest account.

Fees 💰

When we ask you to, you must agree to pay our standard trading fees and fund management fees, if these apply, and cover any out of-pocket costs that we have to pay in meeting our responsibilities to you. Any fees that apply will be set out in the fee schedule you receive. This includes things like fees charged by companies that issue the investments, and any taxes, fees or other charges related to buying, holding or selling your investments or adding them to your TrustInvest account.

Taxes

You are responsible for paying all taxes and fees, and for meeting any related obligations (including preparing tax reports and reclaiming any deductions, if this applies) that arise from using TrustInvest. The maximum rate of withholding tax (30%) will apply to the income, interest, sale proceeds and distributions from US stocks and exchange-traded funds.

We do not have to help you with your tax matters, including preparing or submitting tax forms or reports. You are responsible for checking if you are eligible to reclaim any deductions as we do not provide any tax relief services. We, along with our agents, directors, officers and employees, will not be responsible for any tax due or losses that may arise from your investments.

Agency 👩‍💼👨‍💼

We act as your agent, and you appoint us to:

  1. carry out your instructions, orders and transactions through your TrustInvest account;

  2. buy, hold, sell or otherwise deal with your assets in your TrustInvest account in line with your instructions;

  3. do anything necessary to exercise all or any of the powers given to us or anything else we may consider necessary to deal with, hold, buy or sell your investments; and

  4. do anything which we believe is necessary for us to meet our obligations to you, such as collecting, delivering and receiving your investments or money under these terms or the law.

As your agent, we are not acting as principal (we do not hold the rights and obligations relating to your investments) or broker for any order that you place. This means that you alone are responsible for all risks that come with your investments.

No special legal duty

You agree that our relationship with you does not go beyond these product terms, and these terms do not give us any special legal duties to you.

Monitoring investments

We don’t track or manage your investments for you. For example, we won’t tell you if your investment’s credit rating changes. After you invest, our role is limited to showing you the current value of your investments (if available) and being your custodian (the organisation responsible for safekeeping your investments).

Conflict of interest

Sometimes, we (or people we work with) might have a personal or financial interest in a transaction, or there may be a conflict between your interests and those of other people. If that happens, we’ll take reasonable steps to treat you fairly. However, we may choose not to act for you in those situations and, if so, we don’t have to explain why or accept any responsibility if we decide not to.

Please note that we may still exercise our rights under these terms even if there is or may be a conflict of interest.

Important confirmations 🫡
  1. You confirm that the following statements are true and will remain true at all times.

    1. You are the legal and beneficial owner of the TrustInvest account (that is, you own the account and you have all the benefits of ownership).

    2. You have the legal right to open and make transactions using the TrustInvest account, to give us instructions and to meet your obligations under these terms.

    3. You are not a US person and the federal income tax system of the US does not apply to you.

    4. You accept the risks connected with accessing and using the TrustInvest account, and any investments bought, sold or held in it.

    5. You have the experience needed to independently evaluate and understand the risks involved in your investments, and to independently monitor the performance of your investments.

    6. You can afford to bear all economic consequences and risks of your investments and, if necessary, have consulted your own tax, legal, financial and other advisers about this.

    7. You are not the subject of any investigation, legal action or criminal proceedings.

    8. You acknowledge and accept your responsibility to keep to the market conduct rules (as set out in Part 3 of these terms) when using the TrustInvest account.

    9. You can meet your financial obligations, and no bankruptcy or similar proceedings, or legal action, arbitration, administrative or other proceedings have been started in relation to your assets (and you do not expect any to be started).

    10. You will not, either alone or together with anyone else, use TrustInvest to create or help run any unauthorised market for trading stocks and exchange-traded funds.

  2. If we find that any of the above statements do not apply to you, we have the right to sell your investments at the price that applies at the time. We do not need to tell you why and we will not be responsible for any loss you suffer as a result.

Third parties 3️⃣🎉

We may use third parties, such as execution brokers and custodians, to help us buy and hold your investments. We also use third parties, such as market data providers, to provide market-related information on the Trust app. As long as we use reasonable care and act in good faith when selecting a third party, we will not be responsible for their action, failure to act, insolvency, negligence or failure. We will not be responsible for any other parties that the third party appoints, or for how the third parties select those other parties.

You must also keep to the terms and conditions of these third parties when using TrustInvest.

Intellectual property belonging to third parties

Third-party logos, trademarks and other branding you see on the Trust app are for reference only and belong to the relevant third party (not us). You must not use, copy or use them (including for business purposes without first getting written permission from the owner. We are not responsible if logos, trademarks and other branding are incorrect or out of date.

Rights to and security interest in your investments 📃
  1. We have rights to and security interest in your investments and money that we hold for you. This is known as a first and general lien in favour of us. We can sell your investments at any time and use the money from the sale, or money we are holding for you, to recover any amount you owe us or to meet any other obligations you owe us.

  2. You must not transfer your rights (whether legal or otherwise) in your investments and money in your TrustInvest account, or grant a security interest over them (that is, use the investments or money as security), to a third party.

  3. No-one other than us has any claim, right or charge over your investments and money in your TrustInvest account. This includes anyone trying to claim your investments during legal or financial proceedings.

Relying on information ℹ️

  1. We may share information such as news, research, market trends, analysis or ratings about certain investments or markets. However, you agree that this information:

    1. is not a recommendation or financial advice;

    2. does not mean we’ve reviewed or approved the investment;

    3. should not be seen as us acting as your adviser;

    4. should not be relied on when making your investment decisions; and

    5. may not be complete, accurate or up to date.

  2. The information we provide is for your personal use only. You must not share it with any person or company unless you get written permission from us, the fund manager or our market data provider. If you're not sure about how you can use the information, please contact us. We'll be happy to help.

  3. Any projections or forward-looking statements in the Trust app or on our website are not an indication of future or likely performance, events or the financial performance of products, countries, markets or companies. Actual results may be different.

  4. We are not responsible for any losses you suffer as a result of relying or acting on information in the Trust app or on our website, or any missing or delayed information.

Your money in your TrustInvest account 💰℀
  1. We hold the following in your TrustInvest account.

    1. All cash we receive from you for the purpose of buying investments

    2. All cash we receive from selling your investments

    3. All income (if this applies) and other payments we received in connection with your investments

  2. We will hold your money in accounts separate from our own money. These accounts will also contain money belonging to our other customers and we hold these accounts on behalf of you and our other customers. These accounts will be held either with us or with a third party who is licensed by the relevant authority to hold investors’ money. There are risks when your money is mixed with our other customers’ money. One risk is that you may not get your money back if we (or the third parties we use) become insolvent (unable to meet financial obligations).

  3. You agree that we can make payments from your account without needing further instructions from you in the following situations.

    1. When you place an order to buy investments (including any payments needed to register the investments).

    2. To cover any taxes, fees, charges or other costs that are related to buying, holding or selling your investments. This also includes any currency conversion costs.

  4. We will follow the laws and regulations that apply to customers’ money.

  5. We may place the money that we hold in your TrustInvest account into accounts that pay interest. If we do this, we will keep the interest, and you will not be entitled to it.

How we hold your investments (custodian services) 🔏
  1. We will make arrangements for holding your investments. We may register your investments:

    1. in our name as your custodian (the organisation responsible for protecting your investments); or

    2. in the name of a third party we have appointed to hold your investments as your custodian. The third party that we appoint can also appoint someone else (known as a subcustodian) to hold your investments.

  2. If we hold your investments on your behalf, we will do so in line with Regulations 27 and 27A of the Securities and Futures (Licensing and Conduct of Business) Regulations. If we appoint a third party to act as your custodian, they will be licensed by the relevant authority to hold investments. This means your investments may be registered in our name, the name of a third party that we use, or the name of another party who the third party appoints.

  3. We will not charge a fee for custodian services.

  4. We may hold your investments in an omnibus account (an account where your investments are mixed with the investments of our other customers). If so, we will keep records of your investments and how they have been mixed with other customers’ investments.

  5. There are risks when your investments are mixed with our other customers’ investments. One risk is that you may not get your money or investments back if we or the third parties we use become insolvent. Another risk is that you may be affected by the losses of our other customers.

  6. The investments we return to you may not be identical to the investments we were holding for you. However, we will return assets that are of the same class and value as those your buy order was for.

  7. If any dividends, interests, rights, benefits or other payments received relating to your investments are a result of mixing your investments with our other customers’ investments, we will decide how to divide these between you, us and our other customers.

  8. If your investments are held in a foreign currency, they may be held in an omnibus account outside Singapore. We may use a third party who is licensed to act as a custodian in that country to hold your investments. The laws relating to the account may be different from the laws in Singapore. This means that your investments may not have the same level of protection as they would have if they were held in Singapore. For example, it may be harder to get these investments back than it would be if they were held in Singapore.

  9. We do not have to return any specific investments to you and may instead sell the investments, at your expense, and transfer the money made from the sale to your TrustInvest or savings account.

Dividends and other corporate actions 💰
  1. If you are entitled to them, we will pay dividends from your investments in mutual funds, stocks and exchange-traded funds into your TrustInvest account after we receive them from the fund manager or execution broker (as the case may be).

  2. We do not have to tell you about any matter, deadline, corporate action or lawsuit relating to your investments. However, if we decide to, we will send you any letters, notices or announcements about corporate actions related to your investments as soon as reasonably possible. (A corporate action is any event or decision that has a significant effect on shareholders, such as splitting stock, mergers and takeovers.)

  3. You allow us to exercise as we see fit all voting or corporate action rights that come with your investments. This means that we may decide not to exercise those rights. We do not have to provide related materials such as notices, proxies (documents which allow you to vote without being physically present at meetings) or agendas. We may tell you (but do not have to) if we exercise any of these rights relating to your investments.

  4. We are not responsible for any losses you suffer if we take (or do not take) any action as a result of these rights.

  5. If a corporate action gives you new benefits or entitlements (such as extra shares or units of mutual funds), we’ll divide these fairly based on how much of the investment you own. If the result includes fractions of shares, we will let you have the fractional share (to the nearest 4 decimal points) if fractions of shares are available and supported for that security. We will sell any leftover amounts and share the money from the sale fairly between the affected customers.

Legal action 👨‍⚖️
  1. We do not have to take part in legal proceedings on your behalf, in Singapore or overseas. We also do not have to provide information or advice on legal matters. If we agree to represent or co-operate with you, you must pay any costs and accept any risks involved. You must pay any losses we suffer in connection with any legal proceedings, including any legal or professional fees.

  2. By using TrustInvest, you agree not to take legal action against us or any third parties we use to provide any services to you, unless the losses arise as a result of gross negligence, deliberate misconduct, fraud or seriously (materially) breaking our obligations to you.

  3. As far as is allowed by law, we will not be responsible for any losses, damages or liability arising out of you using TrustInvest or any third parties we rely on to carry out or perform any of the services we provide to you.

Statements and notices 📑
  1. We will send you a ‘trade confirmation’ after the fund manager or execution broker (as the case may be) has carried out (executed) your order.

  2. We will provide statements, information or reports relating to your investments. We will decide how often to send these. In these documents, we will tell you the investments that belong to you and are held by us (or custodians we have appointed) and the transaction history of your TrustInvest account. We call these documents ‘statements’.

  3. As soon as you receive a trade confirmation or statement, you must check it carefully to make sure it is accurate. If you notice any mistakes, you must report these to us within seven days. If you do not report any mistake or inaccuracy, you will be considered to have confirmed that the trade confirmation or statement is correct.

  4. If we find a mistake in a trade confirmation or statement, we will send you an updated version to replace the previous version.

  5. When we receive any communication about your investments, we will take reasonable steps to forward it to you (if necessary). However, we will not be responsible for any losses that arise if we fail to send you any notice or communication correctly or quickly, unless this was due to our gross negligence, fraud or recklessness.

Best-execution policy😇
  1. We carry out (execute) your orders in line with our best-execution policy, as set out in this section.

  2. ‘Best execution’ means that we place and carry out your orders on the best available terms, after taking into account a range of factors. The factors we consider are price, cost, speed, how successful the order is likely to be, size and nature of the order, the settlement process and any other factors we find relevant.

  3. We use execution brokers that are licensed or regulated by the relevant authorities to deal in capital market products such as shares and ETFs.

  4. Certain financial instruments, such as mutual funds, can only be bought and sold in one venue (with the fund manager) and at one price (the net asset value of the mutual fund), so there are no best available terms when it comes to placing orders for mutual funds, as we cannot choose the venue or price.

Closing your TrustInvest account 🥺
  1. You can close your TrustInvest account through the Trust app by sending us a message in our in-app chat. Before you do this, you must sell all the investments in your account and transfer all the money to your savings account. Once your TrustInvest account is closed, you will not be entitled to benefit from any corporate actions (for example, dividend declarations).

  2. We can close your TrustInvest account at any time, for any reason and without giving you notice. For example, we may close your TrustInvest account if you close your savings account, the relevant authorities say we must, or it is necessary to close your account in order to keep to the law or our own policies.

  3. Before closing your TrustInvest account, we also have the right to sell your investments at the price that applies at that time and transfer the cash balance from your TrustInvest account to your savings account.

  4. If we are told that you cannot exercise your rights to your investments (for example, because you have died, have been declared bankrupt or no longer have the mental capacity to make financial decisions), we will also have the right to sell your investments at the price that applies at that time, in line with our internal procedures, and transfer the cash balance from your TrustInvest account to your savings account.

  5. If you do not sell your investments or withdraw your money before your account is closed, we may sell your investments and transfer the cash balance from your TrustInvest account to your savings account.

  6. You agree to pay any costs involved in closing your account and we will not be responsible for any losses you suffer as a result.

Part 2: TrustInvest product terms (for mutual funds only)

This section will only apply to you if you use TrustInvest to buy and sell mutual funds. You’ll need to read our general terms and conditions and the following documents (which, together, are referred to as the fund documents).

  • Prospectus

  • Product highlight sheet

  • Key fact sheet

  • Fund accounts

  • Any other fund documents we tell you apply to you

If there are any differences in the information given in these documents, these product terms will take priority, then the general terms and conditions, then any other documents (in the order listed above).

We have five mutual funds, four of which are only available to the public through the Trust app. They are the Income+, Wealth+ Cautious, Wealth+ Moderate and Wealth+ Growth mutual funds.

Instructions and orders
  1. The cut-off times shown in the fund documents apply to buy or sell orders. If we receive your order after the cut-off time, it will be considered to have been received on the next business day. Business days are defined in the fund documents.

  2. The buy and sell prices are set by the fund manager in line with the fund documents. This means that any buy or sell price we tell you is not final until the fund manager confirms it. You agree that the final buy or sell price when you place the order may be different from the prices we told you (if any), and we are not responsible for any losses that you may suffer as a result.

  3. We are not responsible for making sure that the fund manager sets aside the fund units for you or sells your units in the fund (depending on your instructions).

  4. We, the fund manager or any third parties that we appoint may sometimes suspend your right to sell your investments. For example, the fund manager may suspend your right in difficult investment conditions.

  5. You can sell up to 75% of the value of your investments in a fund. If you want to sell more, you must sell all your investments in the fund.

Cancelling an order 🙅‍♀️

  1. Important: You have the right to cancel your buy order for a particular fund after you submit it. This right continues until you exercise the right or until you sell your units in the fund.

  2. You can exercise your right to cancel a buy order through the Trust app. You can only complete the cancellation after your buy order has settled and if you have not sold the fund. You cannot withdraw any valid cancellation request once you have submitted it.

  3. If you exercise your right to cancel before the cut-off time on any business day, the relevant selling price is the net asset value of the fund on the next business day.

  4. If you exercise your right to cancel after the cut-off time on any business day, the relevant selling price is the net asset value of the fund in the next two business days.

  5. If you choose to cancel your buy order, you will receive the market value of the investment, regardless of whether this is higher or lower than the original amount you paid. This also applies if you choose to sell your investments.

  6. You cannot cancel only part of an order.

  7. You may choose to sell your investments after buying them instead of cancelling the buy order before the transaction completes. You acknowledge that:

    • the prices may change during the period between you giving us the sell order and us processing it; and

    • you won’t receive a refund of any sales charge that applies if you choose to sell your investments instead of cancelling them, and you may receive less from selling the investments than you would have if you had cancelled the sell order if the increase in the value of the investments is less than the initial sales charge (if any).

Fund information
  1. The fund manager provides the information about the mutual funds. We are not responsible for checking that the information is accurate, adequate, reasonable or reliable. We are also not responsible for any mistake or missing information in any fund document or for any losses you suffer as a result of relying on the fund documents.

  2. You can inspect copies of the trust deeds referred to in the fund documents, free of charge, during business hours (9am to 6pm) at the fund manager’s registered office (7 Straits View, #23-04, Marina One East Tower, Singapore 018936). There is no charge for inspecting copies of the trust deeds. Or, for a fee of S$50 per copy, you can ask the fund manager for a copy of the trust deed.

Risks you agree to when investing in funds ⚠️
  1. Risk to your original investment amount: An investment is not money in a bank account, so it is not insured by the Singapore Deposit Insurance Corporation. We do not guarantee or have any obligation to return your investments in funds. Investment involves risks, and you could lose all or part of your original investment amount.

  2. Market risk: The price of the funds will move up and down. As a result, the value of your investment may increase or decrease. Past performance is not a guide to how investments will perform in the future.

  3. Interest-rate risk: If a fund's underlying investments are in bonds, there is a risk that changes to the interest rate may affect the value of your investment. For instance, bond prices generally fall when interest rates rise.

  4. Risk relating to your cash not being readily available (liquidity risk): As the fund is not listed on a public exchange (for example, a stock exchange), you can only sell your investments on business days.

  5. Risk of not being able to sell your investments: The fund manager may sometimes decide to limit or suspend the sale of a fund for a period of time. This is to prevent too many investors from selling their investments at the same time in difficult investment markets. If this happens, it may be difficult or impossible to cash in your investment.

  6. Foreign-exchange risk: If a fund’s underlying investments are in a currency that is different from the currency of the fund, changes in currency values can affect the value of your investment.

  7. Concentration risk: If you invest in a fund that focuses on a single sector, industry, theme or geographic area, the risk is generally higher than if you invest in a fund that focuses on several sectors, industries, themes or geographic areas.

  8. Third-party risk: Transactions will be carried out through third parties (for example, a broker, a custodian and a fund manager) appointed, in good faith, by us or by our nominees or custodians. There is a risk that these third parties cannot meet their obligations. If this happens, orders may not be sent or carried out. Instructions from the fund manager may not be provided to the custodian, broker or dealer, and outstanding trades made through the custodian, broker or dealer may not settle. This could affect the way the fund performs and cause the value of your investments to fall.

  9. Counterparty risk: A fund may invest in financial products that are issued by different organisations. If so, the fund will be exposed to any risks that affect the issuer of these underlying financial products.

  10. Trading facilities and electronic trading: Our trading facilities are supported by computer-based component systems for order-routing (directing buy and sell orders to the appropriate trading venue) and carrying out, matching, registering or clearing trades. As with all facilities and computer systems, there is a risk associated with using these systems – including hardware or software failure. The result of any system failure may be that your order is either not carried out according to your instructions or is not carried out at all. You should also be aware that the internet is not completely reliable, and there may be delays in providing a service.

Acknowledging that you have received this risk warning statement

When you agree to the product terms, you are considered to have read, understood and agreed to the risks set out above.

Part 3: TrustInvest product terms (for stocks and exchange-traded funds (ETFs) only)

This section applies to you if you use TrustInvest to buy and sell stocks (also defined as shares in the Companies Act 1967) and shares in exchange-traded funds (ETFs) on the Trust app. For trading in stocks and ETFs, the following documents will also apply to you.

  • Offering documents

  • Constitutive documents

  • Information documents (also known as information memoranda)

  • Prospectuses

  • Information prepared by or on behalf of the company that issues the securities

  • Documents which contain statistics to show how the securities have performed in the past (we may produce these documents)

You’ll also need to read our general terms and conditions. If there are any differences in the information given in these documents, these product terms will take priority, then the general terms and conditions, then any other documents (in the order listed above).

Instructions and orders for stocks and ETFs
  1. If we carry out your orders, this cannot be reversed.

  2. We may carry out your orders in more than one transaction, and you authorise us to combine those transactions on a single trade confirmation and show the volume-weighted average price (the average price those stocks and ETFs have sold for during the relevant trading day) for those market transactions.

  3. When selling your stocks and ETFs, we’ll credit your TrustInvest account with the money we receive from the sale, after deducting any fees, charges, taxes or other related expenses that apply.

  4. We can refuse to accept your orders at any time without giving any reason, explanation or notice. Here are some situations when we may not carry out your order in full. (These situations apply in addition to the other situations mentioned anywhere else in our terms.)

    1. The information any quotation for the relevant stocks and ETFs was based on has changed and you have not reconfirmed the order.

    2. The stock or ETF is put on a trading halt or you have not reconfirmed the order.

    3. The broker has removed the order from its system.

    4. We believe the order could relate to market conduct that is not allowed (for example, by making it look like there’s more trading activity or interest in a security than there really is) or could be considered market misconduct in any country. (See the ‘Market conduct’ section below.)

  5. We may cancel or reverse your order without telling you if the exchange’s rules allow it and: (a) the exchange asked us to do so; or (b) there was an error in how the market was operating.

  6. If we believe that there is a dispute about your order (for example, the number of shares, the price or whether you have enough shares in your account to sell), we may (but do not have to) take steps to settle the dispute. This could happen, for example, if there’s a delay in updating your holdings due to a corporate action. The steps we may take include, for example, selling or buying back the securities on your behalf. We may do this without telling you first.

Important confirmations for stocks and ETFs

You confirm that the following statements apply to you.

  1. You are buying stocks or ETFs for investment, not to resell or distribute. You don’t plan to (and will not) offer or sell them in a way that would break any securities laws, including the Securities Act of 1933 of the USA (the Securities Act). You agree not to use these securities for hedging (a type of investment strategy used to limit risk) unless this is allowed under the Securities Act.

  2. The gains from your investments in stocks and ETFs are not connected to any business you have or plan to have in the United States during the year.

How we hold your stocks and ETFs

If you invest in stocks or ETFs, we may hold your investments in an omnibus account at a central securities depository. This applies in addition to the information provided in Part 1, under the heading ‘How we hold your investments (custodian services)’.

Currency conversion
  1. If a payment to or from your TrustInvest account needs to be made in a different currency, we may convert it using exchange rates we consider appropriate.

  2. Any exchange rate that we show you is just for reference and we don’t guarantee it. The actual rate we use will be decided at the time we accept your instruction and may be different due to, for example, liquidity (whether the other currency is readily available), market conditions and other factors. We will let you know what the rate is after converting the payment. We are not responsible for any differences in the rates we show you and the actual rates used.

  3. We may also deduct our usual fees and costs for the conversion.

  4. If we cannot carry out the conversion (due to exchange controls, government restrictions, market conditions or other factors), we may refuse to act on your instructions, or carry out the conversion by selling any of your existing investments, or transferring funds from your savings account to your TrustInvest account.

Market conduct

All transactions you enter into are covered by the following.

  1. The rules and decisions of the relevant regulators, stock exchanges and clearing houses for the securities related to certain market abuse transactions that are not allowed such as trades or actions in the financial markets that are unfair, dishonest or illegal, forms of market manipulation, insider dealing, unlawfully sharing inside information, and spreading false or misleading information.

  2. The standard practices and customs of the market where the transaction takes place.

  3. Local and international laws relating to money laundering, financing terrorism, tax and sanctions.

Breaking any of these rules could lead to penalties or legal action against you. You are responsible for keeping to the above rules.

Market data
  1. Our market data provider provides information about stocks and ETFs. We do not prepare the information and we are not responsible for checking that it is accurate, adequate, reasonable or reliable. We and the third parties that we use are also not responsible for any mistake or missing information, or for any losses you suffer as a result of relying on the information on stocks and ETFs.

  2. There may be a delay which means that the information provided is not up to date. You are responsible for checking how long the delay is.

  3. You confirm that you are a non-professional subscriber for market data (not a subscriber for commercial purposes, as part of your job, or for business activity) under the following conditions.

    1. You are subscribing to market data for personal, non-commercial use only.

    2. You are not registered or qualified as a professional trader, investment adviser or any similar financial professional.

    3. You do not act on behalf of any institution (including financial institutions), firm or other third party in making trading decisions.

    4. You do not receive compensation for trading activities or using market data.

    5. You will let us know immediately if any of these details change.

  4. Our market data provider, Refinitiv Holdings Limited, requires you to agree to the following notice.

"Copyright © 2025, Refinitiv. All rights reserved. Refinitiv Holdings Limited and its affiliates are referred to below as "Refinitiv".

The “Information Product”, which is any data or service provided by Refinitiv, is the intellectual property of Refinitiv and its Third Party Providers. Any copying, republication or redistribution of Refinitiv content, including by caching, framing or similar means, is expressly prohibited without the prior written consent of Refinitiv. To the extent that the Information Product contains any third party data referred to in the General Restrictions/Notices page set forth on http://www.thomsonreuters.com/datause, the terms set forth on such General Restrictions / Notices page shall apply to user.

User may use the Information Product for internal purposes only. User may copy, paste and distribute internally only an insubstantial amount of the data contained in the Information Product provided that: (a) the distribution is incidental to or supports user's business purpose; (b) the data is not distributed by user in connection with information vending or commercial publishing (in any manner or format whatsoever), not reproduced through the press or mass media or on the Internet; and (c) where practicable, clearly identifies Refinitiv or its third party providers as the source of the data. Data will be considered in "insubstantial amount" if such amount (a) has no independent commercial value; or (b) could not be used by the recipient as a substitute for any product or service (including any download service) provided by Refinitiv or a substantial part of it.

Neither Refinitiv nor its Third Party Providers shall be liable for any loss, damage or cost, including without limitation, direct or indirect, special, incidental, or consequential, arising in connection with the information, content or materials provided or as a result of actions taken in reliance thereon. You expressly agree that your use of Refinitiv’s information, content or materials is at your sole risk. Refinitiv and the Refinitiv Logo are trademarks and registered trademarks of Refinitiv companies around the world.”

What we are not responsible for

You acknowledge the following.

  1. TrustInvest may not always be available to you when you want to trade stocks or ETFs.

  2. We are not responsible for any loss of profit or opportunity if the company which issued the stocks or ETF fails to meet any of its obligations to you.

Fractional stocks and ETFs trading
  1. We may allow you to buy or sell part of a share or an ETF (what we call a fractional share or ETF). We will decide whether to allow this and may apply certain conditions or limits, such as restrictions on the types of orders you can place. We will let you know on the Trust app which shares and ETFs are eligible for fractional trading.

  2. When you place an order, this may result in buying or selling both whole shares or ETFs and fractional shares or ETFs. We will treat your order as two separate orders – one for the whole number of shares or ETFs and one for the fractional shares or ETFs. You agree that these two separate orders may be processed at different times and at different prices. It is also possible that one order is completed but the other is not.

  3. The fees which apply to trading whole shares and ETFs also apply to trading fractional shares and ETFs.

  4. The prices we show you are based on the market for whole shares or ETFs. Fractional shares and ETFs may be traded at different prices because the market for fractional shares or ETFs is usually smaller and less liquid (more difficult to convert to cash). This means that the price you get when buying or selling a fractional share or ETF may be different from the price shown for a whole share or ETF.

  5. The value of fractional shares and ETFs and any manufactured dividends from them will be rounded to the nearest cent. This rounding may affect things like the amount of dividend you receive or how share or ETF splits are applied to your holdings. We refer to ‘manufactured dividends’ here because we are not passing on the dividend direct from the issuer of the share or ETF. Instead, we calculate and pay you a value that is proportionate to the dividend you are entitled to.

  6. You will receive dividends, but you won’t:

    1. have voting rights for fractional shares or ETFs;

    2. be able to take part in voluntary corporate actions for fractional shares or ETFs; or

    3. receive communications or documents from the issuer of the fractional shares or ETFs.

  7. If the share or ETF is no longer eligible for fractional trading, you will not be able to buy or sell the share or ETF if your order includes a fractional amount. The only exception is if you sell that share or ETF which consists of a fractional component.

  8. Unless we say otherwise in this section, all other terms apply equally to fractional shares or ETFs in the same way they apply to stocks and ETFs.

  9. You confirm that you understand the unique risks, features and limits of trading fractional shares or ETFs, including those set out in the risk disclosure document.

Last updated on: 4 Nov 2025, Version: 2