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Client Engagement & Disclosure Document (DER)
Pre-contractual information notice · Ref. DTB-DER-2026 · ANACOFI-CIF
01
The Firm — DTB Wealth Management
Company Name
DTB Wealth Management S.À.R.L.
Share Capital
€1 000
EU VAT Number
FR10839728094
Registered Address
3 Rue du Clos de la Muscadelle, 81150 Lagrave, France
SIREN / RCS
839 728 094 — Commercial Registry Albi
NAF/APE Code
6619B
Principal Director
Daniel BUTCHER
ORIAS (all capacities)
n° 18004310 — www.orias.fr
Contact
d.butcher@dtbwealthmanagement.com
Personal data collected on this form is processed by DTB Wealth Management S.À.R.L. (data controller) for the purposes of financial investment advisory services, compliance with legal obligations (AML/CFT/KYC), and regulatory reporting to AMF / ANACOFI-CIF. Data is retained for the duration of the business relationship and for 5 years beyond its termination (Art. L.561-12 CMF). Recipients include the adviser, authorised staff, product partners, and supervisory authorities. In accordance with GDPR Regulation (EU) 2016/679 and Law No. 78-17 of 6 January 1978, you may exercise your rights of access, rectification, erasure, restriction, portability, and objection by contacting: d.butcher@dtbwealthmanagement.com. You may also lodge a complaint with the CNIL (www.cnil.fr). Special attention is given to data concerning minor clients in accordance with GDPR requirements.
02
Regulatory Authorisations & Supervisory Authorities
NON-INDEPENDENT Advice — Art. 325-5 RGAMF: DTB Wealth Management provides financial investment advice on a non-independent basis. The adviser may retain commissions and retrocessions paid by product issuers. This does not affect the obligation to act in the client's best interest at all times.
| Capacity | Description & Supervisory Authority | Registration | Scope |
|---|---|---|---|
| CIF | Financial Investment Adviser (CIF) — non-independent advice per Art. 325-5 RGAMF. Registered with ANACOFI-CIF, association approved by the AMF (17 place de la Bourse, 75082 Paris Cedex 02 · www.amf-france.org). Supervised by the AMF. | CIF n° E008994 | Financial instruments, SCPI, OPCI, investment advice |
| IAS — Type B | Insurance Intermediary (broker) — Type B, not bound exclusively to one insurer; analyses a broad range of contracts. Member of ANACOFI-COURTAGE. Supervised by ACPR (4 Place de Budapest, 75436 Paris Cedex 09 · acpr.banque-france.fr). Level 1 advisory. | ORIAS 18004310 | Life insurance, capitalisation contracts, protection |
| IOBSP Courtier | Credit & Payment Services Broker (IOBSP) — non-exclusive broker. Supervised by ACPR. Max remuneration 1% of loan amount or agreed brokerage fee. Does not provide independent advisory service per Art. L519-1-1 CMF. | ORIAS 18004310 | Mortgage loyrs, credit restructuring |
Additional regulated capacities (ORIAS 18004310):
| Capacity | Details | Supervisory Authority |
|---|---|---|
| Financial canvassing agent (Mandataire en démarchage) |
If acting as canvassing agent on behalf of another entity, the identity of the mandating principal(s) must be disclosed. This activity is subject to inspection by the AMF and the ACPR. | AMF / ACPR |
| Real Estate Agent (Carte T — Hoguet Law) |
In accordance with the Hoguet Law on real estate and business transactions, DTB Wealth Management holds the carte professionnelle (licence) for real estate and business transactions without holding funds — N° CPI 8101 2018 000 032 896, issued on 29/07/2021 by the CCI TARN. No third-party funds held. No financial guarantee required for non-holding of third-party funds. | DGCCRF (inspection authority) |
DTB Wealth Management is a member of ANACOFI-CIF (www.anacofi.asso.fr) and undertakes to comply fully with the ANACOFI-CIF Code of Good Conduct. DTB Wealth Management is also subject to legislation on combating money laundering and the financing of terrorism (TRACFIN measures) and undertakes to comply fully with those obligations.
DTB Wealth Management is committed to full compliance with the ANACOFI-CIF Code of Conduct, available at www.anacofi-cif.fr. Our firm integrates sustainability factors (ESG criteria: environmental, social and governance) into its product selection process, including SFDR, EU Taxonomy and PAI analysis.
03
Professional Indemnity Insurance & Financial Guarantee
For all its activities, in accordance with the law and the ANACOFI-CIF code of conduct, DTB Wealth Management is covered by MMA sis BDJ — 39 Rue Mstislav Rostropovitch — 75815 PARIS CEDEX 17 — Policy n° 114240090 — Member n° 029001. This cover complies with the requirements of the Monetary and Financial Code and the Insurance Code.
| Activities Insured (RCP — Professionnel Civil Liability) | Coverage Limit per insurance period |
|---|---|
| Asset management advice and related activities such as prospecting for banking or financial products — Financial Investment Advice / CIF (Art L.541-1 following CMF) — CJA (Appropriate Legal Competence) — Real estate agent or intermediary (without handling or holding third-party funds) | €3,000,000 per claim per year |
| Intermediation in banking and payment services without funds entrusted (IOBSP) | €2,500,000 per claim per year |
| Personal insurance brokerage (without collection of third-party funds) — Discretionary management of life insurance contracts | €3,000,000 per claim per year |
| Financial Guarantee | Guarantee Ceiling (per guarantee period) |
|---|---|
| IOBSP (without entrusted funds / sans fonds confiés) | €115,000 per insurance year |
| Personal insurance brokerage (without collection of third-party funds) | €115,000 per insurance year |
| Real estate agent or intermediary (without handling or holding third-party funds) | €115,000 per insurance year |
Likewise, Mr. Daniel BUTCHER is personally covered in Financial Guarantee and Professionnel Civil Liability by MMA sis BDJ — 39 Rue Mstislav Rostropovitch — 75815 PARIS CEDEX 17 — Policy n°114240090 — Member N°029001.
04
Principal Business Partners, Companies & Suppliers
DTB Wealth Management operates under non-independent advice (Choice 3 — broad analysis). The following partners represent the full range of product providers and platforms with which DTB has formal commercial relationships. Arrangements take the form of brokerage agreements, distribution agreements or platform agreements. Third-party remuneration (trail commissions / recurring rebates) is fully disclosed under Section 05 and in the Ex-Ante Costs Disclosure.
| Name | Nature | Agreement type | Remuneration |
|---|---|---|---|
| INSURANCE COMPANIES | |||
| AFER EUROPE | Insurance company | Brokerage agreement | Commission |
| AXA FRANCE | Insurance company | Brokerage agreement | Commission |
| AXA Théma | Insurance company | Brokerage agreement | Commission |
| CARDIF (BNP Paribas) | Insurance company | Brokerage agreement | Commission |
| GENERALI | Insurance company | Brokerage agreement | Commission |
| INTENCIAL | Insurance company | Brokerage agreement | Commission |
| METLIFE | Insurance company | Brokerage agreement | Commission |
| NORTIA | Insurance company / platform | Brokerage agreement | Commission |
| CRYSTAL | Insurance company / platform | Brokerage agreement | Commission |
| SOLUTIONS BY SWISS LIFE | Insurance company | Brokerage agreement | Commission |
| UTMOST WEALTH SOLUTIONS | Insurer (international bonds) | Terms of business | Commission |
| UTMOST Luxembourg S.A. | Insurer (Luxembourg) | Terms of business | Commission |
| ONE LIFE by APICIL | Insurer (Luxembourg) | Terms of business | Commission |
| WEALINS S.A. | Insurer (Luxembourg) | Terms of business | Commission |
| SOGELIFE (UK Portfolio Bond) | Insurer (Luxembourg — UK PCP) | Terms of business | Commission |
| UTMOST ex LOMBARD I.A. (UK PCP) | Insurer (Luxembourg — UK PCP) | Terms of business | Commission |
| PRU International by M&G | Insurer (international bonds) | Terms of business | Commission |
| FRIENDS PROVIDENT INTERNATIONAL | Insurer (international bonds) | Terms of business | Commission |
| OLD MUTUAL INTERNATIONAL | Insurer | Terms of business | Commission |
| RL360 | Insurer | Terms of business | Commission |
| MANAGEMENT COMPANIES (SCPI / OPCI / FUNDS) | |||
| AMUNDI | Management company | Terms of business | Commission |
| BLACKROCK | Management company | Terms of business | Commission |
| CORUM ASSET MANAGEMENT | Management company (SCPI) | Terms of business | Commission |
| FONCIA PIERRE MANAGEMENT | Management company | Terms of business | Commission |
| GUINNESS (Acorn) funds | Management company | Terms of business | Commission |
| IROKO | Management company (SCPI) | Terms of business | Commission |
| LA FRANÇAISE | Management company (SCPI) | Terms of business | Commission |
| MARLBOROUGH Ireland funds | Management company (funds) | Terms of business | Commission |
| PERIAL | Management company (SCPI) | Terms of business | Commission |
| REMAKE | Management company (SCPI) | Terms of business | Commission |
| SOGENIAL | Management company (SCPI) | Terms of business | Commission |
| SWISS LIFE ASSET MANAGERS | Management company | Terms of business | Commission |
| IDAD International | Issuer of Structured Notes | Terms of business | Commission |
| BANKING & CUSTODY | |||
| ALLIANZ BANQUE | Bank | Terms of business | Commission |
| BNP PARIBAS WEALTH MANAGEMENT | Bank | Terms of business | Commission |
| CACEIS | Custodian bank | Terms of business | Commission |
| SOCIETE GENERALE | Bank | Terms of business | Commission |
| REAL ESTATE DEVELOPERS | |||
| ICADE PROMOTION | Real estate developer | Commercial agreement | Commission |
| NEXITY | Real estate developer | Commercial agreement | Commission |
| BOUYGUES IMMOBILIER | Real estate developer | Commercial agreement | Commission |
| TRUSTEES & QROPS / INTERNATIONAL PENSIONS | |||
| SOVEREIGN MALTA | Trustee & QROPS | Terms of business | Commission |
| AZURE PENSIONS SOVEREIGN | Trustee & QROPS | Terms of business | Commission |
| BOAL & CO (MALTA) | Trustee (QROPS) | Terms of business | Commission |
| STM GROUP | Trustee & QROPS | Terms of business | Commission |
| THE IFGL TRUSTEES (IOM) | Trustee (Isle of Man) | Terms of business | Commission |
| DFM / DAM / PLATFORMS | |||
| NOVIA GLOBAL (UK) | Adviser platform (UK) | Terms of business | Commission / fee |
| NOVIA GLOBAL EUROPE | Adviser platform (Europe) | Terms of business | Commission / fee |
| QUILTER CHEVIOT | Asset management company (DAM) | Terms of business | Commission |
| RAYMOND JAMES | Asset management company (DAM) | Terms of business | Commission |
| ROTHSCHILD & CO WEALTH MANAGEMENT | Asset management company (DFM) | Terms of business | Commission |
| CAPITAL INTERNATIONAL GROUP (IOM) | Asset management company (DFM/DAM) | Terms of business | Commission |
| MORNINGSTAR (Praemium Guernsey) | Adviser platform (Guernsey) | Terms of business | Commission / fee |
| SANLAM PRIVATE WEALTH | Asset management company (DAM/DFM) | Terms of business | Commission |
| OTHER SPECIALIST PROVIDERS | |||
| ALPHEYS | Financial engineering platform | Terms of business | Commission / fee |
| CRYSTAL BLOCKCHAIN / DIGITAL ASSETS | Digital asset specialist | Terms of business | Commission / fee |
| ZENITH FINANCIAL | Specialist provider | Terms of business | Commission |
05
Billing & Remuneration Policy
As a non-independent CIF adviser (ANACOFI Option 3): The adviser provides advice in the client's best interest, defined as non-independent, and may retain commissions paid by financial product issuers (commission retrocessions, max. 50% of management fees). The adviser's analysis covers a broad range of financial instruments available on the market, sufficiently diversified by type, issuer and provider.
CIF Activity — Advisory fees
Upon quote — confirmed in Engagement Letter
CIF Activity — Commissions
Product retrocessions — max 50% of management fees
IAS Activity — Commissions
Insurer commission — disclosed in Engagement Letter
IOBSP Activity — Brokerage fees
Max 1% of loan amount, or agreed fee
TVA
Fees subject to 20% VAT (unless exempt)
Note
The Engagement Letter finalises the remuneration level
Remuneration disclosure — ANACOFI CIF requirement: DTB Wealth Management makes its money in two different ways; one or both methods may apply to your engagement:
Option 1 — Independent advice: Fees paid by client
Where advice is provided on an independent basis, remuneration is paid directly by the client. The adviser undertakes not to retain any commission from product providers and to rebate any such sums to the client as promptly as possible. The adviser evaluates a sufficient range of instruments diversified by type, issuer and provider, with no close links that could compromise independence.
Option 2 — Non-independent advice: Commissions ✓ DTB default
Where advice is provided on a non-independent basis, or where an intermediation, savings or investment solution is arranged, the adviser is remunerated by a share of the entry charges levied by the product promoter and/or intermediaries. The adviser may retain such commissions. The adviser evaluates a broad range of financial instruments available on the market.
Invoicing of consulting fees for intellectual services (wealth assessments, legal or tax consultations, annual subscription for monitoring and support) may also apply. Our hourly rate is £150 / €180 excl. VAT. All fees are confirmed in the Engagement Letter prior to the service being rendered.
06
PEP Declaration — Politically Exposed Persons (AML/CFT)
In accordance with Directives 2015/849/EC (4AMLD) and 2018/843/EU (5AMLD), we are required to verify whether the client or a close family member holds or has held a prominent public function within the last 3 years.
| Position / Function | Client — Yes / No | Spouse/Associates — Yes / No |
|---|---|---|
| Head of State, Head of Government, member of a national government or the European Commission, member of parliament, political party official | Yes No | Yes No |
| Member of the Constitutional Council, Council of State, Supreme Court, or the Court of Auditors | Yes No | Yes No |
| Ambassador, senior military officer, central bank governor, director of an international organisation established by treaty | Yes No | Yes No |
| Director or board member of a state-owned enterprise | Yes No | Yes No |
07
Communication Methods
08
Complaints Procedure — Art. 325-23 RGAMF · ACPR Recommendation 9 May 2022
Complaints Contact
Daniel BUTCHER · 3 Rue du Clos de la Muscadelle, 81150 Lagrave
Email : d.butcher@dtbwealthmanagement.com
Email : d.butcher@dtbwealthmanagement.com
Acknowledgement Deadline
Maximum 10 working days from receipt of complaint
Full Response Deadline
Maximum 2 months between complaint submission and response
How to Submit
By post or email — with acknowledgement of receipt
Mediation — Competent Mediators:
| Mediator | Jurisdiction | Address & Contact |
|---|---|---|
| Médiateur ANACOFI | Business-to-business disputes and corporate client disputes | 92 Rue d'Amsterdam, 75009 Paris · www.anacofi.asso.fr |
| M. Rémi BOUCHEZ — AMF Mediator | CIF disputes with retail consumers | Autorité des Marchés Financiers, 17 Place de la Bourse, 75082 Paris Cedex 02 · www.amf-france.org |
| La Médiation de l'Assurance | Insurance activity (IAS) disputes | TSA 50110 — 75441 Paris Cedex 09 · www.mediation-assurance.org |
| ANM Conso — Médiation consommation | IOBSP & miscellaneous activity disputes | 25 Allée Rose Dieng Kuntz, 75019 Paris · www.anm-conso.com |
Acknowledgement of Receipt & Signature — DER
Client / Subscriber 1
Marital status:
Date : Lieu :
Sign above
Co-Subscriber 2
Date : Lieu :
DTB Wealth Management
Daniel BUTCHER — Directeur
ORIAS 18004310 · CIF E008994
ORIAS 18004310 · CIF E008994
Date :
DTB Wealth Management S.À.R.L. · RCS Albi 839 728 094 · ORIAS 18004310 · CIF E008994 · Non-independent advice Art. 325-5 RGAMF · ANACOFI-CIF
DER — Page 1 / 4
Engagement Letter
Ref. DTB-LM-2026 · MiFID II Art. 24 — Ex-ante fee disclosure
01
Parties to the Agreement
The Client
Name:
Address:
Email:
Address:
Email:
The Adviser
DTB Wealth Management S.À.R.L.
3 Rue du Clos de la Muscadelle, 81150 Lagrave
ORIAS 18004310 · CIF E008994
d.butcher@dtbwealthmanagement.com
3 Rue du Clos de la Muscadelle, 81150 Lagrave
ORIAS 18004310 · CIF E008994
d.butcher@dtbwealthmanagement.com
Upon entering the relationship, the client was provided with the Pre-Contractual Information Document (DER) setting out the adviser's legal status in accordance with Article 325-5 of the AMF General Regulation.
02
Nature of the Primary Engagement — Art. 325-5 RGAMF
Investment placement assistance including:
- Insurance (IAS)
- Financial investment advice (CIF)
- Patrimonial audit
- Advice on miscellaneous assets
- Advice relating to the provision of investment services
- Other — specify:
03
Client Objectives — Ranked by Priority
Objective 1 (primary)
Objective 2
Objective 3
Objective 4
Objective 5
Objective 6 (optional)
04
Client Profile — Risk Profile & MiFID II Classification
Risk profile (scale 1 to 7)
MiFID II classification
Investment horizon
ESG Preferences: Indicate the client's wishes regarding investments with ESG characteristics or environmental objectives:
ESG appetite
Desired proportion of sustainable investment
ESG policy available at the firm
PAI (Principal Adverse Impacts)
05
Details: Complementary / Secondary Engagements
- Real estate acquisition advisory
- Business / corporate patrimonial advice
- Pension transfer / QROPS assessment
- Cross-border tax structuring
- Insurance needs analysis
- Structured products advisory
- Digital assets advisory (if regulated)
- Other:
06
Conduct of the Engagement, Terms of Service & Duration
The adviser sets out below their working method, the planned phases and timescales for each phase, as well as the applicable legal and regulatory requirements binding on CIFs:
Following delivery of the Client Engagement & Disclosure Document, the adviser is required to gather information about the client's situation and determine their risk profile. The CIF prepares this Engagement Letter, which formalises the relationship between the parties. Finally, the CIF provides a Suitability Report justifying the suitability of the advice given, delivered before any subscription.
Duration of the engagement
If fixed term — specify
Principal communication method
Notice period for termination
8 days by registered letter with AR
Terms of service:
07
Termination of the Engagement
This agreement may be terminated at any time by the client by registered letter with acknowledgment of receipt, with eight (8) days' notice from receipt. The agreement may also be subject to amendments, particularly in the event of changes in applicable law. Tacit renewal applies unless terminated as set out above.
08
Client Information & Monitoring Arrangements
The Suitability Report will formalise the advisory service.
In the case of a continuing relationship: the CIF will inform the client of any change to its structure (in particular the nature of advice and the identity of partners) by sending an updated DER or legal information sheet. The CIF must provide regular information relating to its advisory activities.
Where a monitoring commitment is made: suitability will be reviewed at least once per year to assess over time whether the products remain suitable for the client's profile and situation; the suitability assessment aims to enable the CIF to act in the client's best interests.
Review frequency
Review method
09
Scope of Engagement & Products / Services Offered
DTB Wealth Management S.À.R.L. is engaged to provide non-independent investment advisory services (broad analysis — Choice 3, Art. 325-5 RGAMF). The scope of products and services that may be recommended is described below. Tick applicable services:
ANACOFI 2026: The CIF must provide general information on what it may offer. The table below summarises DTB's product and service offering, adapted to the target market, with appropriate risk warnings. Clients may request more detailed information on any product category at any time.
| ✓ | Product / Service | SRRI | Indicative charges | Key risks / notes | ESG |
|---|---|---|---|---|---|
| Life insurance / capitalisation bonds (French law — Assurance-vie) | 1–7 | 0–5% entry; 0.5–1% p.a. | Unit-linked: capital not guaranteed. Euro fund: capital generally guaranteed but not legally required. | SFDR Art. 8 & 9 available | |
| International portfolio bonds / cross-border life wrappers | 1–7 | 0–5% entry; 0.5–1.5% p.a. | Currency risk; issuer / jurisdiction risk | Available | |
| SCPI / OPCI (real estate investment trust units — CIF regulated) | 2–5 | 0–12% subscription; 0.5–1% p.a. | Illiquid. Min. 8–10 year horizon recommended. Capital not guaranteed. Separate ex-ante disclosure required per product. | SFDR Art. 8 & 9 available | |
| Collective investment schemes — UCITS / AIFs | 1–7 | 0–3% entry; 0.5–2% p.a. | Market risk; capital not guaranteed | SFDR Art. 6/8/9 | |
| Structured products / capital-protected notes | 2–5 | 0–3% entry; 0.5–1.5% p.a. | Issuer risk; liquidity risk; complex instruments | Limited | |
| QROPS / international pension transfers | 2–6 | Fee schedule — see Section 07 | Regulatory complexity; tax risk; jurisdiction risk | Available | |
| Mandate management — DAM / DFM platforms | 1–7 | Via platform agreement | Market risk; manager risk | Available | |
| Financial planning & patrimonial engineering | N/A | Fees horaires ou forfaitaires | Advisory only — no execution | N/A | |
| Insurance brokerage (IAS) | N/A | Commission (provider-paid) | Product-specific | N/A | |
| Other: | — | — | — | — |
General risk warning (MiFID II): All investments carry risk. Past performance is not a reliable indicator of future results. The value of investments and any income may fall as well as rise; and you may get back less than you invest. Where investments are denominated in foreign currencies, exchange rate changes may affect their value. Tax treatment depends on individual circumstances and may change. DTB Wealth Management does not provide tax advice.
10
Nature of Advice & Scope of Analysis (Art. 325-5 RGAMF)
Select ONE applicable nature of advice for this engagement (delete the other two in the final version provided to the client):
Note: the DER (Client Engagement & Disclosure Document (DER)) and this Engagement Letter must specify the same nature and scope of analysis — they must be consistent (ANACOFI 2026 requirement).
11
Risk & Reward Profile — SRRI Scale (ANACOFI 2026)
The risk profile must be consistent with the KYC data gathered. The scale below uses the same 7-level SRRI used for financial products, ensuring compatibility. The adviser may use more granular levels, provided compatibility with the SRRI product scale is maintained.
Click a number to select · The SRRI is not a guaranteed indicator of future risk · Must be consistent with KYC profile
Selected risk level (SRRI)
Risk label
Loss capacity acknowledged
12
Sustainability Factors — ESG (ANACOFI 2026 · SFDR · EU Taxonomy)
ANACOFI 2026 requirement: ESG criteria (Environmental, Social and Governance) enable the measurement of long-term sustainability commitments. They are assessed against the EU Taxonomy, SFDR Regulation, and Principal Adverse Impacts (PAI) framework.
🌿 Environmental (E)
Carbon footprint · Emissions reduction strategy · Energy consumption · Waste management & recycling · Biodiversity impact (pollution prevention) · Circular economy transition
🤝 Social (S)
Gender equality & minority inclusion · Disability inclusion · Labour law compliance · Stakeholder dialogue · Employee training & safety · Human rights
🏛️ Governance (G)
Stakeholder input in governance · Third-party audit · Board diversity · Pay transparency · Anti-corruption · Executive accountability
EU Taxonomy (Regulation 2020/852): An activity is considered environmentally sustainable if it contributes to at least one of six objectives — (1) climate change mitigation, (2) climate change adaptation, (3) sustainable use of water & marine resources, (4) transition to a circular economy, (5) pollution prevention, (6) protection of biodiversity — while not significantly harming any other, and meeting minimum social safeguards.
SFDR (Regulation EU 2019/2088): Art. 6 — no ESG objective; Art. 8 — promotes ESG characteristics; Art. 9 — sustainable investment objective. PAI (Art. 4 SFDR) refers to the negative impacts of investment decisions on the environment, society and governance — the CIF must indicate how these impacts are considered and mitigated.
Client ESG interest
Desired sustainable investment proportion (%)
PAI consideration
EU Taxonomy minimum share desired
Acceptance of lower returns for ESG compliance:
13
Costs and Charges — Ex-Ante Disclosure MiFID II Art. 24(4)
Regulatory requirement: All costs and charges are expressed as a percentage and in euros based on the amount invested. These figures are estimates. An annual ex-post statement will be provided. The table below presents all charges that may be levied.
Investment amount (€):
→ amounts calculated automatically in €, £ and $
Nature of remuneration:
□ Fees (direct billing)
Amount excl. VAT: Incl. VAT:
VAT: First payment date:
☑ Commissions (product retrocessions)
Maximum % that may be charged:
Estimated excl. VAT: Incl. VAT:
A — ONE-OFF CHARGES (levied at subscription) One-time only
Fee item
% Rate
€ / £ / $ Amt
Entry advisory fee (DTB)
Insurer / issuer subscription commission (retrocession)
Structuring / file fees
TOTAL ENTRY CHARGES
—
—
B — ANNUAL RECURRING CHARGES (on advised portfolio) Each year
Fee item
% / yr
€ / £ / $ yr
Annual advisory fee — Adviser (DTB)
Additional portfolio management fee (Adviser)
Annual provider management fee (AMC insurer / manager)
Annual custody / depositary fee
Switching / rebalancing fee (per transaction — Adviser)
Additional services (reporting, legal liaison, etc.)
TOTAL RECURRING CHARGES (p.a.)
—
—
Ex-ante costs disclosure (Art. 24(4) MiFID II): The information on costs and charges includes a description of the various categories of costs and charges relating to the investments, and the way in which the client may bear them. This includes: (a) costs linked to the financial instrument (management costs, production costs); (b) costs linked to the service provided (cost of investment advice, RTO service); (c) third-party payments received by the adviser (retrocessions, commissions), presented separately. Upon request, the client may require a more detailed breakdown of costs. A final statement will be provided after execution.
14
SCPI / OPCI — Ex-Ante Disclosure per Product (if applicable)
For each recommended SCPI or OPCI, a separate ex-ante disclosure is mandatory (PRIIPs KID / MiFID II Art. 24(4)). Click the button below to add a disclosure block for each SCPI the client wishes to invest in. You may add as many as required.
15
Governing Law, Disputes & Mediation
The Parties agree to apply French law. In the event of a dispute, the Client may submit a complaint in accordance with the procedure set out in the Client Engagement & Disclosure Document (DER). If the dispute persists after complaints handling, the Client may refer the matter, free of charge, to the AMF Mediator (Autorité des Marchés Financiers) prior to any legal proceedings. The adviser is bound by professional secrecy.
16
Personal Data Protection — GDPR (Regulation EU 2016/679)
The use of personal data by DTB Wealth Management is governed by Regulation (EU) 2016/679 (GDPR) and Law No. 78-17 of 6 January 1978 as amended. Data collected is processed by DTB Wealth Management S.À.R.L., as data controller, for the purposes of financial advisory, AML/CFT/KYC compliance, and regulatory reporting.
Data controller
DTB Wealth Management S.À.R.L.
DPO contact
d.butcher@dtbwealthmanagement.com
Retention period
Relationship duration + 5 years (Art. L.561-12 CMF)
Recipients
Adviser, authorised staff, product partners, AMF, ANACOFI-CIF, supervisory authorities
Your rights under the GDPR: access, rectification, erasure (subject to legal obligations), restriction, portability, objection. Contact: d.butcher@dtbwealthmanagement.com. You may also lodge a complaint with the CNIL (www.cnil.fr). Special attention is given to data concerning minor clients.
17
Right of Withdrawal — Art. L.341-16 CMF (Canvassing / Démarchage)
Where this Engagement Letter results from a canvassing act (Art. L.341-1 CMF), the client has 14 calendar days from the date of conclusion (or from receipt of contractual terms, if later) to exercise the right of withdrawal, without penalty and without needing to state reasons (Art. L.341-16 I CMF). This right does not apply to RTO / order execution services or to contracts fully executed at the client's express request.
WITHDRAWAL FORM (ART. L.341-16 CMF) — SECTION 5.3
Art. D.341-8 CMF: This form must be sent by recorded delivery with acknowledgment of receipt no later than 14 days from contract conclusion. The right of withdrawal is only valid if duly completed, legible, and sent within this period (Art. D.341-8 CMF).
To (adviser / firm):
DTB Wealth Management S.À.R.L.
ORIAS No. 18004310 · CIF No. E008994 (ANACOFI-CIF)
Address: [DTB registered address]
ORIAS No. 18004310 · CIF No. E008994 (ANACOFI-CIF)
Address: [DTB registered address]
From (withdrawing person):
Name:
Address:
Address:
I/We hereby declare that I/we exercise my/our right of withdrawal from the Engagement Letter (financial investment advisory service — CIF) concluded with DTB Wealth Management S.À.R.L. on:
Date of contract:
Service / product:
Client / Subscriber 1 — Signature & Date
Date:
Co-Subscriber / Subscriber 2 — Signature (if applicable)
Date:
Signatures — Engagement Letter · I acknowledge and accept all fees disclosed above
Client / Subscriber 1
Date : Lieu :
Co-Subscriber 2
Date : Lieu :
DTB Wealth Management
Daniel BUTCHER — Directeur · ORIAS 18004310
Date :
DTB Wealth Management S.À.R.L. · ORIAS 18004310 · Non-independent Art. 325-5 RGAMF · MiFID II Art. 24(4) — Ex-ante disclosure of costs and charges
Engagement Letter — Page 2 / 4
Order Reception & Transmission Agreement (RTO)
Ref. DTB-RTO-2026 · Art. L.541-1 II CMF · Art. 325-32 RGAMF
Warning: An RTO agreement must be concluded for any subscription to a collective investment scheme (UCITS / AIF) ancillary to a CIF advisory mission, even where the transaction is a one-off or occasional operation.
01
Parties to the Agreement — Between the Undersigned
The Adviser (CIF) — "The Adviser"
DTB Wealth Management S.À.R.L.
3 Rue du Clos de la Muscadelle, 81150 Lagrave, France
RCS Albi 839 728 094
ORIAS n° 18004310
Registered as CIF with ANACOFI-CIF (AMF-approved association)
CIF n° E008994
Represented by: Daniel BUTCHER, Director
3 Rue du Clos de la Muscadelle, 81150 Lagrave, France
RCS Albi 839 728 094
ORIAS n° 18004310
Registered as CIF with ANACOFI-CIF (AMF-approved association)
CIF n° E008994
Represented by: Daniel BUTCHER, Director
The Client — "The Client"
Name / surname:
Address:
The Adviser and the Client are hereinafter collectively referred to as "the Parties"
Address:
The Adviser and the Client are hereinafter collectively referred to as "the Parties"
02
Background — Preliminary Recitals
It is agreed that this agreement is entered into in accordance with the legislative and regulatory provisions in force, in particular those provided for in Articles L.541-1 II of the Monetary and Financial Code and 325-32 of the General Regulation of the Autorité des Marchés Financiers (AMF).
The Adviser is authorised to carry out an order reception and transmission mission within the legal and regulatory limits and conditions. The Client remains free and autonomous in the personal management of their portfolio. The Adviser carries out no management act on behalf of the Client or on behalf of third parties.
Account-holding establishment (existing clients)
Client account reference
Note: account / policy details are not required for initial account-opening transactions.
03
Article 1 — Object of the Agreement
This agreement defines the conditions under which the Adviser may provide the Client with the order reception and transmission service. This service is necessarily ancillary to a prior advisory service; it may only be exercised to collect an order resulting from advice given. The RTO activity, as it may be exercised, may only cover units of collective investment schemes (UCITS, AIF).
04
Article 2 — Reception and Processing of Orders
The Client must address their orders in writing exclusively to the Adviser (post, fax or email), indicating their identity and account number at the account-holding establishment (does not apply to the first account-opening transaction). The Client must:
- Identify the financial instrument concerned (type of UCITS or AIF, name and references);
- Specify the transaction they wish to carry out (purchase, sale or other);
- Indicate the quantity of financial instruments or, failing that, the value in £ / € / $.
The Adviser reserves the right to request confirmation of the order from the Client. The Adviser will time-stamp the order upon receipt. The time-stamp records the acceptance of the order.
Custodian / account holder
Client account / policy reference
05
Article 3 — Transmission of Orders
Upon receipt of the order from the Client and in any event within 2 (two) business days of receipt, the Adviser shall transmit the order to the account-holding establishment. The Adviser shall not be held liable for any fault or breach committed by the establishment in the performance of its mission, and accordingly its liability may not be engaged in this regard.
The Client is expressly informed that the transmission of the order does not prejudge its execution. The order is only executed (i) if market conditions allow, and (ii) if it satisfies all applicable legal, regulatory and contractual conditions. If the order cannot be executed for any reason, the Adviser shall notify the Client as soon as possible by post, fax or telephone (in the latter case the information shall be confirmed in writing). The unexecuted order shall be cancelled. It will be the Client's responsibility to issue a new order.
06
Article 4 — Client Information on Executed Orders
The account-holding establishment shall send the Client a trade confirmation as soon as possible. The Adviser also informs the Client within 48 hours of execution of the orders carried out, by post, fax, email or telephone (in the latter case confirmed in writing). In the event of any dispute regarding the execution of an order, the written and reasoned dispute must be addressed to both the establishment and the service provider within 8 days of the Client's receipt of the trade confirmation.
07
Article 5 — Obligations of the Adviser
The Adviser acts in accordance with professional standards. The Adviser shall not be held responsible for any loss or breach in the performance of its obligations caused by a force majeure event or resulting from a breach by the account-holding establishment. In particular, the Adviser shall not be held liable for any consequence that may result from a disruption in the order transmission means used.
08
Article 6 — Obligations of the Client
The Client undertakes to comply with the Adviser's order reception and transmission procedure as described in Article 2 of this agreement.
- I confirm I have read and understood the terms of this RTO agreement.
- I acknowledge that orders must be submitted in writing.
- I have read the DER and the Engagement Letter prior to signing this agreement.
- I understand that DTB Wealth Management does not hold or manage my assets directly.
09
Article 7 — Remuneration
The Client shall incur no additional charges from passing their orders through the Adviser. Any remuneration received by the Adviser is disclosed in the Engagement Letter and in the annual ex-post statement, in accordance with MiFID II Art. 24(4).
10
Article 8 — Termination of the Agreement
This agreement is concluded for an indefinite period. It may be terminated at any time by registered letter with acknowledgement of receipt by the Client, with eight (8) days' notice from receipt of said letter. Where the Client requests termination of this agreement, the Client shall simultaneously notify the account-holding establishment.
11
Article 9 — Disputes & Mediation
The retail-consumer Client is informed that in the event of a dispute arising in connection with the interpretation or execution of this agreement, they have the right to refer the matter free of charge to the AMF Mediator prior to any legal proceedings. Where no amicable solution can be reached during the mediation phase, the Parties agree to submit any dispute to the competent court, to which jurisdiction is hereby conferred.
12
Article 10 — Governing Law
This agreement is governed by French law. Done in two copies, one for each Party.
Governing law
French law — Commercial Court of Albi
Place of signing
Note on personal data (GDPR): No separate GDPR clause is included in this RTO agreement as it is necessarily concluded concurrently with the Engagement Letter, which already contains the full GDPR data protection clause.
Signatures — RTO Agreement · Done in two originals, one for each Party
The Client
Date : Place :
Co-Subscriber 2 (if applicable)
Date : Place :
The Adviser — DTB Wealth Management
Daniel BUTCHER · Director · CIF E008994 · ORIAS 18004310
Date :
DTB Wealth Management S.À.R.L. · CIF E008994 · ORIAS 18004310 · Art. L.541-1 II CMF · Art. 325-32 RGAMF
RTO Agreement — Page 3 / 4
Suitability Report
Ref. DTB-RA-2026 · MiFID II Art. 25(2) · ESMA Guidelines 2018/EBA/1229 · Art. 325-12 RGAMF
01
Client Details & Profile Summary
The Client
Surname:
First name:
Address:
Email:
First name:
Address:
Email:
The Adviser
Surname: BUTCHER
First name: Daniel
Firm: DTB Wealth Management S.À.R.L.
CIF E008994 · ORIAS 18004310
First name: Daniel
Firm: DTB Wealth Management S.À.R.L.
CIF E008994 · ORIAS 18004310
▸
Client Situation — Minimum Data Required (ANACOFI 2026)
The elements below represent the minimum required. It is recommended to record all available patrimonial data.
MiFID II classification
Age
Tax residence
Marital status
Number of dependent children
Annual net income
Tax rate / marginal tax band
Number of tax shares (parts fiscales)
▸
Patrimonial Situation
Primary residence (value)
Secondary / rental property (value + income)
Liquid financial assets — securities / funds
Precautionary savings / cash reserves
Total liabilities / debts outstanding
Amount to be invested (this engagement)
▸
Risk Profile & Investment Parameters
Risk profile (SRRI 1–7)
Investment horizon
Financial experience / knowledge
ESG / sustainability preference
Other material factors
02
Client Objectives & Mission Recap
Nature of advice
Primary objective recalled
Recall of client request and objectives:
Recall of questions asked and answers provided (the adviser must ensure responses are clear, accurate, non-misleading and comprehensible):
03
Analysis of Client Situation & Recommended Investment Proposal
ANACOFI 2026: The adviser must analyse the client's situation and explain objectively, fairly, clearly and accurately the advantages, risks and disadvantages of the recommended asset class and financial instruments.
Analysis of client situation:
Recommended product / solution — advantages and disadvantages:
Product / solution name
Provider / issuer
Recommended amount
Target asset allocation
Recommended sub-funds / instruments (names, ISIN, SCPI units)
04
Remuneration & Ex-Ante Costs Disclosure — MiFID II Art. 24(4)
Regulatory requirement: Charges are expressed as a percentage and in absolute amount. Where a precise figure cannot be provided at this stage, a reasonable estimate is given and corrected at subscription. The CIF provides clients with an illustration of the cumulative effect of costs on investment returns (ex-ante and ex-post). The client may request a more detailed breakdown of charges.
| Fee category | % Rate | € Estimated | £ Estimated | Frequency |
|---|---|---|---|---|
| Service costs (adviser fees / retrocessions) | — | — | — | Per arrangement |
| Product costs (management charges — AMC) | — | — | — | Annual |
| Total entry charges (one-off) | — | — | — | One-time at subscription |
| Total annual recurring charges | — | — | — | Annual |
| Estimated total cost over 5 years | — | — | — | 5 years |
Third-party payments received by DTB (retrocessions / trail commissions): £ / €. These are fully disclosed and do not affect the obligation to act in the client's best interests.
For insurance-wrapper products (IAS activity): the adviser discloses fee levels in accordance with the Insurance Distribution Directive (IDD / DDA). Full details are available on request from the insurance provider.
05
Suitability Justification — Adequacy Declaration (Art. 325-12 RGAMF · MiFID II Art. 25(2))
ANACOFI 2026: The adviser must justify the choice of the recommended instrument, explaining in detail how the recommendation is suited to the client's specific situation, objectives, knowledge/experience, risk tolerance and loss capacity.
Suitability to declared objectives
Consistency with risk profile & loss tolerance
Consistency with investment horizon
Client knowledge, experience & financial capacity
Product risk rating (SRI / SRRI)
Client risk profile (from KYC)
06
Periodic Suitability Review — ANACOFI 2026 Requirement
The receipt of ongoing retrocessions / trail commissions is justified by the provision of an additional service to the client. The periodic suitability test and monitoring reports confirm this ongoing service commitment.
Periodic review to be carried out?
Review frequency (if applicable)
Where the CIF provides ongoing advice, suitability is reviewed at least once per year. The frequency is increased based on the client's risk profile and the type of instruments recommended. The client may at any time request a periodic review. Where the client requests subscription to a product not in line with their objectives and needs, the CIF must warn of the unsuitability and retain evidence of this warning.
07
ESG Suitability — Sustainability Factors (Art. 9 SFDR · EU Taxonomy · PAI)
Does the recommended product meet the client's ESG preferences?
SFDR classification of recommended product
If YES — explanation of how ESG criteria are integrated in the recommended solution:
If NO — reason why an ESG-compliant product was not recommended:
08
Principal Risks Disclosed to the Client
09
Adviser's Suitability Declaration — Art. 325-12 RGAMF · MiFID II Art. 25(2)
I, the undersigned, Daniel BUTCHER, Director of DTB Wealth Management S.À.R.L. (CIF E008994 · ORIAS 18004310), declare that the recommendation contained in this report has been formulated on the basis of the client's situation and objectives as gathered through the KYC process, and is in line with their risk profile, knowledge, experience and investment horizon as described above.
I declare that the recommendations are suitable for the situation and objectives of:
Mr / Ms (full name)
Date of this suitability report
☐ The client acknowledges having received the commercial documentation: KID / PRIIPs, Prospectus, and where applicable SFDR pre-contractual disclosure — and confirms they have had sufficient time to review them prior to any subscription.
Signatures — Suitability Report · Acknowledgement of receipt prior to subscription
Client / Subscriber 1 — I have received and read this report
Date : Place :
Co-Subscriber 2 — I have received and read this report
Date : Place :
DTB Wealth Management — Adviser
Daniel BUTCHER · CIF E008994 · ORIAS 18004310
Date :
This Suitability Report is issued in accordance with Art. 25(2) MiFID II, Art. 325-12 RGAMF and the ESMA Suitability Guidelines (2018/EBA/1229). It constitutes a personalised recommendation and does not represent a guarantee of performance or capital protection. Strictly confidential — intended exclusively for the named client above. DTB Wealth Management S.À.R.L. · CIF E008994 · ORIAS 18004310 · MMA BDJ policy 114240090 · Non-independent advice Art. 325-5 RGAMF.
DTB Wealth Management S.À.R.L. · ORIAS 18004310 · CIF E008994 · Suitability Report MiFID II Art. 25(2) · Art. 325-12 RGAMF
Suitability Report — Page 4 / 4