Fleet Insurance for the Care Sector: The Complete UK Guide
Care sector fleet insurance covers the vehicles used by domiciliary care agencies, residential care homes, supported living providers, day centres, and NHS transport contractors to transport service users and staff. The policy must reflect the actual use class for each vehicle type: business use for staff travel, hire and reward for any service where passengers are charged, and Section 19 or Section 22 permit cover for non-profit minibus operations. Getting the use class wrong is the most common reason care sector vehicle claims are declined. Employers’ liability insurance is also a legal requirement for any care organisation with employees.
Key Takeaways
- →Care organisations using standard social, domestic and pleasure insurance for vehicles used in care work are uninsured for those journeys. Business use class cover is the minimum required for any vehicle used in the course of employment
- →Minibuses used to transport service users require specific consideration: D1 driving entitlement, Section 19 or Section 22 permit if the organisation is non-profit, and hire and reward cover if passengers are charged a fare or contribution
- →Grey fleet – care workers using their own vehicles for client visits – is an uninsured exposure that affects most domiciliary care agencies. Employers have a duty of care for grey fleet journeys and must verify that workers’ personal policies include business use
- →Employers’ liability insurance at a minimum of £5 million is a legal requirement under the Employers’ Liability (Compulsory Insurance) Act 1969 for any care organisation with employees. Failure to hold it carries a fine of up to £2,500 per day
- →Wheelchair-accessible vehicles (WAVs) and adapted vehicles require declared specialist values and confirmed cover for mobility equipment. Standard fleet policies often exclude or under-insure conversion costs
- →CQC (Care Quality Commission) registration and compliance history is increasingly used by specialist underwriters as a proxy for risk management quality in the care sector. A good CQC rating supports better fleet premium terms
💬 From the MMC Fleet Team | FCA Reg. 916241
“Care sector fleet is one of the most consistently under-insured commercial fleet categories in the UK. The typical scenario we see is a domiciliary care agency with 15 staff vehicles on a business use class 1 policy and 60 carers using their own cars for client visits with no verified business use add-on. One serious accident involving a carer’s personal vehicle on a client visit and the agency faces both a claim the insurer declines and a health and safety enforcement action for failing to manage grey fleet risk. The grey fleet issue alone is worth an entire policy audit for any care organisation.”
Quick Facts
- ✓There are over 17,000 registered domiciliary care providers in England, the majority of which have staff making client visits by vehicle. Most employ a mix of organisation-owned vehicles and staff using personal cars
- ✓Under the Health and Safety at Work Act 1974 and the Management of Health and Safety at Work Regulations 1999, care employers have a legal duty of care for all work-related road journeys, including those made in employees’ own vehicles
- ✓A Section 19 permit allows a non-profit organisation (including registered charities and community interest companies) to carry passengers in a minibus of up to 16 seats without a hire and reward licence, provided no profit is made from fares. The permit is issued by a traffic commissioner or an approved body
- ✓Care fleet insurance cannot be quoted through standard online comparison platforms. The combination of vulnerable passenger exposure, grey fleet, WAV valuations, and sector-specific liability requires specialist underwriting placed through a broker
No two care sector fleet risks are the same. A domiciliary care agency with 20 staff vehicles and 80 carers using personal cars has completely different insurance needs to a residential care home running two minibuses for day trips and hospital appointments, or an NHS transport contractor operating 40 adapted vehicles across a county. What all of them share is that getting the insurance wrong creates gaps that can end a business: a declined claim after a service user is injured in a vehicle, an enforcement notice for operating a minibus without the correct permit, or a health and safety prosecution for failing to manage grey fleet risk.
This guide explains how fleet insurance works across the different care sector operating models, what use classes apply to different vehicle types and journeys, how to manage grey fleet exposure, what minibus permit requirements mean for insurance, and what specialist care fleet cover looks like compared to a standard commercial motor policy.
Which care sector organisations need specialist fleet insurance?
Any care organisation that operates vehicles for care delivery, service user transport, or staff travel in the course of their work needs commercial fleet insurance rated for that use. Standard personal motor insurance is invalid for work-related journeys. The specific type of care fleet cover needed depends on the organisation type, vehicle types, how passengers are carried, and whether the organisation is commercial or non-profit.
| Organisation Type | Typical Vehicle Use | Key Insurance Requirement |
|---|---|---|
| Domiciliary care agency | Staff vehicles for client visits; supervisors’ cars; sometimes a small pool of company cars. High grey fleet exposure | Business use class 2 or 3 on all staff vehicles. Grey fleet management policy and verified employee vehicle business use add-ons. Employers’ liability (legal requirement) |
| Residential care home | Minibus for day trips, outings, and hospital appointments. Pool cars for staff. Sometimes a dedicated transport co-ordinator vehicle | Minibus: Section 19 permit (if non-profit) or hire and reward cover. D1 driver entitlement check. WAV specialist value if adapted. Passenger liability |
| Day centre / community day service | Multiple minibuses running regular routes collecting and returning service users. Often the largest vehicle operation in the care sector | Section 19 or Section 22 permit depending on organisation type. Hire and reward if any charge is made. Route-based operation requires declared operating area. Passenger liability standard |
| Supported living provider | Small vehicles (cars, MPVs) for service user activities, appointments, and community access. High ratio of one-to-one support journeys | Business use class covering passenger-carrying journeys. Clarity on whether service user is considered a passenger or participant affects liability structure. Carer’s own vehicle grey fleet risk if not using company vehicles |
| NHS Patient Transport contractor / CCG transport provider | Adapted vehicles and WAVs carrying patients to and from NHS appointments. High-frequency, route-based operation | Hire and reward use class (NHS contract constitutes a charge for services). Stringent passenger liability requirements. WAV agreed value cover. DBS checks as underwriting condition. Driver training records |
| Charity / CIC providing transport to vulnerable adults or children | Minibuses or adapted vehicles. Often volunteer drivers in addition to employed drivers. May receive grant funding for transport operations | Section 19 permit if non-profit minibus. Volunteer driver cover – must be specifically included on the policy. Enhanced DBS checks as a licence condition for most permit issuers. Trustee and officer liability consideration |
What use class does a care sector vehicle need?
The use class declared on a motor insurance policy defines which journeys are covered. Care organisations frequently make the mistake of insuring vehicles under social, domestic and pleasure use (SDP), which covers personal travel only. The moment a vehicle is used for any work-related purpose, SDP cover is invalid and any claim on that journey will be declined.
| Use Class | What It Covers | Typical Care Sector Application | What It Does NOT Cover |
|---|---|---|---|
| Social, domestic and pleasure (SDP) | Personal travel, shopping, leisure, commuting to a single regular workplace | Not suitable for care sector work. Commuting cover only ends at the fixed workplace address; any travel thereafter is uninsured | Client visits, travelling between sites, carrying service users, any journey made in the course of employment |
| Business use class 1 | SDP plus business travel by the policyholder to multiple sites and locations in connection with their occupation | Suitable for managers, supervisors, and admin staff using their own or a company vehicle to travel between office and care sites. Not suitable for carrying service users | Carrying passengers for hire or reward. Transporting service users as part of a care package. Other named drivers doing the same journeys unless separately covered |
| Business use class 2 | Class 1 plus use by other named drivers for business purposes | Company pool vehicles used by multiple care staff for site visits and travel between clients. The most common class for care agency staff vehicles | Hire and reward use. Carrying passengers where a fare or charge is made |
| Business use class 3 (commercial travel) | Full business use including door-to-door and multi-client visiting. The broadest business use class | Domiciliary carers making multiple client visits in a day. Community nurses and support workers. Any care professional whose primary activity is travelling between service user locations | Hire and reward. Carrying service users who are paying for the journey independently of the care contract |
| Hire and reward (H&R) | Transporting passengers for payment. Required where the transport element is separately charged, contracted, or constitutes a public or quasi-public service | NHS patient transport contractors. Local authority contracted transport. Any operation where service users or local authorities pay specifically for the journey | Not required if transport is incidental to a care package with no separate charge. The boundary between business use and hire and reward in care is frequently disputed – always clarify with the insurer |
The SDP Trap: The Most Common Care Fleet Claim Declination
The most frequent claims dispute in care sector fleet insurance involves a carer who was involved in an accident while travelling between client visits, insured under SDP cover or their personal policy with no business use add-on. The insurer declines the claim on the basis that the journey was business use, not personal use. The care organisation is then exposed to the third-party claim directly, without any insurance backstop.
The employer’s insurer may also step in for the third-party minimum under the Road Traffic Act 1988, but will pursue the employee and the employer for recovery. The practical outcome is an uninsured claim that hits the organisation’s operating budget and triggers a Health and Safety Executive (HSE) investigation for failing to manage occupational road risk.
What is grey fleet and why does it matter for care organisations?
Grey fleet refers to employees using their own privately owned vehicles for work purposes. In domiciliary care, grey fleet is not an edge case – it is the norm. Most domiciliary care agencies have more carers using personal vehicles for client visits than they have company vehicles. This creates a significant compliance and insurance gap that many care organisations have never formally addressed.
Under the Health and Safety at Work Act 1974, an employer is responsible for the health and safety of employees during work-related road journeys regardless of whether the vehicle is owned by the employer or the employee. This means a care organisation has a legal duty to ensure every carer using their personal vehicle for client visits holds adequate insurance cover for that use. Relying on the employee to have sorted it themselves is not a compliant position. For more detail on how grey fleet works within a fleet policy structure, see our grey fleet insurance guide.
| Grey Fleet Requirement | What the Employer Must Do | Frequency |
|---|---|---|
| Motor insurance verification | Obtain and record a copy of each grey fleet driver’s motor insurance certificate. Confirm it includes business use for work-related driving. SDP-only cover is not acceptable | At appointment and at every annual renewal of the employee’s policy |
| DVLA licence check | Check the employee’s DVLA driving licence for endorsements, disqualifications, and validity. A care worker driving on a disqualified licence on a client visit creates uninsured exposure | At appointment and at least annually. Ideally quarterly for high-mileage grey fleet drivers |
| MOT and vehicle roadworthiness | Verify the vehicle has a current MOT. An accident in a vehicle with an expired MOT can complicate claims and attract enforcement action. Check via GOV.UK MOT history service | At appointment. Annual check thereafter. Employees should report any vehicle defects to the organisation |
| Mileage recording | Record work-related mileage for every grey fleet driver. This supports HMRC mileage reimbursement compliance and provides evidence of business use in the event of a claim investigation | Every journey. Care scheduling systems should capture journey data automatically where possible |
| Grey fleet risk assessment | Document a formal grey fleet risk assessment as part of the organisation’s road risk management policy. This is expected by the HSE and by care sector regulators. Absence of a risk assessment is an aggravating factor in any enforcement action following a grey fleet incident | On adoption and following any significant incident or change to working practices |
Pro Tip: Add Grey Fleet to Your Fleet Policy, Not Just Your Compliance Records
Some care fleet insurers offer a grey fleet management extension that sits alongside the main fleet policy and provides contingent cover for situations where a grey fleet driver’s own insurance proves inadequate. This is not a substitute for the employee having proper business use cover, but it closes the gap between what the employee’s personal insurer may argue and what the care organisation actually needs covered. Ask your broker specifically whether grey fleet contingency cover is available as an endorsement – not all standard fleet policies offer it and it is worth requesting at renewal for any care organisation with significant grey fleet exposure.
Minibus insurance and permit requirements in the care sector
Minibuses (9 to 16 passenger seats, excluding the driver) are the most legally complex vehicle type in care sector fleet operations. Running a minibus for service user transport without the correct combination of permit, driver licence entitlement, and insurance use class is a criminal offence under the Public Passenger Vehicles Act 1981, regardless of whether the organisation is commercial or charitable.
| Permit/Licence Type | Who Can Use It | Conditions | Insurance Implication |
|---|---|---|---|
| Section 19 Permit | Non-profit bodies only: registered charities, community interest companies, educational bodies, and similar organisations | Passengers must be members, employees, or service users of the body. No profit from fares. Vehicle up to 16 passenger seats. Driver must hold D1 entitlement (or be exempt under small vehicle provisions). Issued by traffic commissioner or approved body | Policy must be rated for Section 19 permit use. Some insurers require the permit number to be declared. Hire and reward cover is NOT required where Section 19 applies – but this must be confirmed explicitly with the insurer |
| Section 22 Permit | Community bus services operated by non-profit bodies for the general public or defined community | Permits the carriage of the public on a defined route. Restricted to non-profit operators. Less common in pure care sector operations but relevant for community transport organisations running care-adjacent services | Requires specific insurance declaration. Insurer must be aware the vehicle is operating as a community bus service |
| PSV Operator Licence | Required for any commercial operator carrying passengers for hire or reward in a vehicle with 9 or more passenger seats | NHS transport contractors and LA-contracted transport providers typically require this. Involves compliance with operator licence conditions including maintenance records, driver hours, and tachograph requirements in some cases | Hire and reward cover required. Policy must reference PSV operator licence. Standard fleet cover is insufficient. Passenger liability at minimum levels required by licence |
| D1 Driving Entitlement | Driver entitlement category D1 allows driving minibuses with 9-16 passenger seats. Most UK licences issued before 1997 include D1 automatically. Licences issued after 1997 require D1 to be obtained separately via a test | D1 ‘not for hire or reward’ restriction applies to most post-1997 D1 entitlements. This means the driver can only drive under a Section 19 permit or for non-commercial purposes | A driver without D1 entitlement operating a minibus is driving without a valid licence for that vehicle category. This voids insurance for that vehicle and driver and creates a criminal driving without a licence offence. Always verify D1 entitlement before any care worker drives a minibus |
What does care sector fleet insurance cover?
A specialist care fleet policy combines standard motor fleet cover with care-specific extensions that reflect the vulnerability of service users, the legal obligations of registered care providers, and the multi-vehicle, multi-use-class nature of most care operations. The policy must be structured to cover all vehicle types and use classes within the single organisation.
| Cover Element | What It Covers | Standard or Optional |
|---|---|---|
| Third-party liability (fleet) | Injury to third parties and damage to their property caused by any vehicle on the fleet. Minimum required by law under the Road Traffic Act 1988 | Standard (statutory minimum) |
| Comprehensive vehicle cover | Accidental damage, fire, theft, and vandalism for each vehicle on the fleet. Essential for WAVs and minibuses where replacement costs are high and vehicles are essential to service delivery | Standard on most care fleet policies |
| Passenger liability | Injury to service users and other passengers transported in fleet vehicles. Covers legal costs and compensation. Essential for any care vehicle carrying service users. Vulnerability of passengers in the care sector makes this a high-exposure cover | Standard on care fleet policies |
| Public liability | Injury to members of the public or damage to their property arising from care operations not directly involving a moving vehicle (e.g. a service user falls while being assisted from a vehicle). Minimum £2m, typically £5m or £10m for larger care organisations. See our public liability insurance guide | Standard on care fleet policies |
| Employers’ liability | Injury or illness to employees arising from their work, including road-related injuries. Minimum £5m under the Employers’ Liability (Compulsory Insurance) Act 1969. Almost every care organisation employs staff and therefore requires this cover. See our employers’ liability insurance guide | Legally required |
| WAV and adaptation cover | Agreed value cover for the adapted elements of WAVs (ramps, hoists, restraints, raised roofs). Standard market value clauses undervalue WAV conversions by 20-40%. Mobility equipment inside the vehicle should be separately confirmed as included | Optional (essential if WAVs on fleet) |
| Replacement vehicle | Temporary hire vehicle while a fleet vehicle is under repair. For care organisations, a replacement vehicle must be capable of carrying service users where the original vehicle was an adapted or specialist vehicle | Optional (strongly recommended) |
| Grey fleet contingency | Contingent cover bridging situations where an employee’s own policy proves inadequate for a work-related journey. Not a substitute for the employee having proper business use cover but provides a safety net for the organisation | Optional – not all insurers offer it |
| Legal expenses | Costs of defending regulatory investigations (CQC, HSE, traffic commissioner), pursuing uninsured third parties, or handling service user compensation disputes. Typically £50,000-£100,000. See our broader fleet insurance guide for how legal expenses sit within fleet policies | Optional |
| Breakdown assistance | Roadside recovery. For care fleets carrying service users, recovery vehicles must be able to handle adapted vehicles and the practical needs of potentially distressed or vulnerable passengers | Optional |
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How is care fleet insurance rated and what drives the premium?
Care fleet premiums are driven by the vulnerability of the people being transported, the mix of vehicle types, driver profiles, and the claims history of the organisation. A care fleet with no WAVs, experienced drivers, clean claims history, and a documented grey fleet management policy will be rated significantly differently to one with multiple adapted vehicles, younger drivers, and unmanaged grey fleet exposure.
| Rating Factor | How It Affects Premium | Operator Action |
|---|---|---|
| Claims history | The most significant rating factor. A high frequency of passenger liability claims or grey fleet incidents is a major loading trigger. Care organisations with formal risk management, incident reporting, and post-claim reviews demonstrate lower ongoing risk | Maintain detailed claims records. Investigate and document root cause of every incident. Use claims data to justify risk improvements to the underwriter at renewal |
| Vehicle type mix | WAVs, minibuses, and adapted vehicles attract higher premiums than standard cars due to repair cost, passenger capacity, and incident severity. A fleet that is 60% WAVs will be rated more expensively than one that is 60% standard saloons | Declare each vehicle type accurately with agreed values for all adapted vehicles. Do not undervalue WAV conversions |
| Driver age and experience | Younger drivers (under 25) and newly qualified drivers attract loadings. Care sector staff turnover can be high, meaning new, unproven drivers are regularly added to the fleet. High turnover itself is a rating factor some underwriters apply | Implement driver induction training. Consider a minimum age or minimum experience threshold for minibus driving. Provide DVLA licence data to support driver profile at renewal. See our fleet telematics guide for how monitoring can offset young driver loadings |
| CQC registration and rating | Specialist care fleet underwriters increasingly use CQC inspection ratings as a risk proxy. A care organisation rated ‘Good’ or ‘Outstanding’ by CQC demonstrates documented quality management that reduces the likelihood of care-related incidents feeding into liability claims. An ‘Inadequate’ or ‘Requires Improvement’ rating can restrict market access or trigger loadings | Provide CQC certificate and most recent inspection report to broker at renewal. A strong CQC rating is a genuine premium-reduction tool in the specialist care fleet market |
| Grey fleet management | Organisations with documented grey fleet policies, verified driver business use insurance, and regular licence checks are rated more favourably than those with unmanaged grey fleet exposure. Unmanaged grey fleet is a material risk factor that some underwriters decline to cover at all | Provide the grey fleet management policy to your broker. Document grey fleet driver checks and present the register to the underwriter as evidence of control |
| DBS check compliance | Insurers covering care fleets expect enhanced DBS checks for all drivers transporting vulnerable adults or children. A driver without a current DBS check driving a care vehicle is a condition breach that can affect cover validity for incidents involving that driver | Maintain a DBS register with renewal dates. DBS checks should be refreshed every 3 years as a minimum for care sector drivers. Some licensing authorities and contracts require annual refreshes |
| Operating area | Urban care fleets (particularly in London and major cities) attract higher premiums due to incident frequency. Rural fleets often have lower frequency but higher severity claims due to driving distances and response times | Declare the primary operating area accurately. Multi-region care organisations should provide a geographic breakdown of vehicle allocation |
Electric vehicles and technology in care fleet insurance
Care fleet operators are increasingly transitioning to electric vehicles, driven by Clean Air Zone requirements, NHS decarbonisation targets for contracted providers, and local authority fleet sustainability requirements in transport contracts. EV adoption in the care sector brings the same insurance considerations as other fleet classes – higher repair costs, battery cover terms, and charging infrastructure risk – but with additional complexity around adapted vehicle conversions.
For care fleets already running WAVs, the move to EV-based WAV conversions adds a further layer of value and complexity. An electric wheelchair-accessible vehicle conversion can cost £70,000-£90,000. Without agreed value cover confirmed in writing at inception, a total loss following a minor incident could be settled at depreciated market value – which may be half the replacement cost. For broader guidance on EV fleet insurance terms, see our electric vehicle fleet insurance guide.
EV and Technology in Care Fleet: Key Considerations
Agreed value on EV WAVs
An EV WAV conversion (e.g. Volkswagen ID. Buzz Accessible) can cost £75,000-£90,000. Standard indemnity cover at depreciated market value will significantly under-pay on a total loss. Agreed value must be confirmed in the policy schedule
Dashcams and telematics
Telematics in care fleet vehicles provides journey data useful for both insurance and care quality audits. Some specialist care fleet underwriters offer premium reductions for fleets with full telematics. Dashcam footage is increasingly important in disputed passenger liability claims
Charging infrastructure cover
Charging equipment at a care home depot or supported living site is not covered by the fleet motor policy. It requires cover under the property or business insurance for the premises. EV battery fire at a care home or supported living property is a specific risk to assess separately
Longer off-road periods
EV repair lead times are longer than ICE vehicles due to specialist technician requirements and battery parts availability. For care fleets where each vehicle is essential to service delivery, replacement vehicle cover becomes more important as EVs are adopted
Five Mistakes That Void Care Fleet Claims
- ✗Using SDP-only insurance for client visit journeys. The moment a vehicle is used for any work-related purpose, SDP cover ends. Any claim on that journey is declined and the employer faces direct liability
- ✗Allowing a driver without D1 entitlement to drive a minibus. A driver without the correct driving licence entitlement for the vehicle class is uninsured. This also constitutes a criminal driving without a licence offence for both the driver and potentially the employer if they permitted it
- ✗Operating a minibus without a Section 19 permit or PSV licence. Carrying service users in a minibus without the correct permit is a criminal offence under the Public Passenger Vehicles Act 1981, regardless of whether any charge is made. The fleet insurer can decline cover for any incident involving a vehicle being operated illegally
- ✗Failing to verify grey fleet driver business use cover. An employee who has an accident in their personal vehicle on a client visit with no business use extension on their personal policy creates an uninsured loss. The care employer is exposed directly and potentially faces HSE enforcement for failing to manage occupational road risk
- ✗Undervaluing WAV and adapted vehicles. A WAV insured at the standard market value of the base vehicle (rather than the full conversion cost) will be significantly under-insured. Under-insurance triggers the average clause, reducing every claim proportionally. See our guide to fleet composition for how adapted vehicle values should be declared
What cover does each type of care fleet operation need?
The right policy structure depends entirely on the organisation’s mix of vehicle types, how service users are transported, whether the operation is commercial or non-profit, and the scale of grey fleet exposure. There is no single “care fleet policy” – the cover must be built to match the specific operation.
| Care Organisation | Recommended Fleet Structure | Critical Cover Requirements |
|---|---|---|
| Domiciliary care agency, 10-50 vehicles, mixed company and grey fleet | Fleet policy (business use class 3) for company vehicles. Grey fleet management policy with verified business use add-ons for all grey fleet drivers. Consider grey fleet contingency endorsement. For smaller operations, see our mini fleet insurance guide | Business use class 3 (multi-client visiting). Passenger liability if any service users are ever transported. Employers’ liability (mandatory). Grey fleet compliance programme documented. Public liability at minimum £2m, preferably £5m |
| Residential care home, 1-3 minibuses, no staff cars | Dedicated care/minibus fleet policy or stand-alone minibus policy if very small. Section 19 permit cover if non-profit. Section 19 permit from traffic commissioner or approved body must be obtained separately | Section 19 permit declared to insurer. D1 entitlement confirmed for all drivers. WAV agreed value if any adapted vehicles. Passenger liability. Employers’ liability (mandatory). Breakdown cover with passenger assistance capability |
| Day centre, 5-15 minibuses running regular service user routes | Specialist care fleet policy covering all minibuses under a single fleet programme. Section 19 or Section 22 permit as appropriate. Route-based operation declared | Permit type declared to insurer. Driver hours and roster records available. All drivers D1 checked. High passenger liability limits (multiple passengers at risk simultaneously). Regular route declared. Telematics recommended. See our fleet premium reduction guide |
| NHS patient transport contractor, 20-100 adapted vehicles | Full specialist fleet policy, hire and reward rated, PSV operator licence declared. Placed through specialist broker with NHS transport underwriting capacity | Hire and reward use class. PSV operator licence compliance. Agreed value on all WAVs. Passenger liability at NHS contract specification (often £10m or above). Employers’ liability. DBS compliance programme. Telematics and dashcams as standard. See our fleet insurance and van fleet insurance guides for comparable policy structures |
Frequently Asked Questions
Disclaimer: This article is for informational purposes only and does not constitute legal, insurance, or regulatory advice. Licensing, permit, and insurance requirements for care sector vehicles vary by organisation type, vehicle type, and operating context. The information reflects general UK practice as of 2026. Always consult an FCA-regulated specialist broker and, where minibus permits or operator licences are involved, seek advice from a traffic law specialist. MyMoneyComparison.com Ltd is authorised and regulated by the Financial Conduct Authority (FCA), registration number 916241.
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