What are Assisted Living Units (ALUs)?

Assisted Living Units are residential properties leased to care providers. They are designed to provide stable income and meaningful social value for investors.

How is income typically generated from ALUs?

Income is generally generated through long-term leases with supported housing providers. Investors are not involved in daily management.

Who manages the properties?

The properties are managed by regulated providers who oversee operations, tenant care, and maintenance. Investors retain ownership without operational duties.

Why are ALUs considered resilient investments?

They are supported by long-term social needs and public sector funding, making them less sensitive to traditional market cycles.

Are these opportunities regulated?

The opportunities are not FCA regulated, but the care providers usually operate under regulatory supervision. Each is vetted as part of our due diligence.

Is there a minimum investment?

Minimum investment requirements are not disclosed publicly. They are shared privately once investor status has been confirmed.

What risks should investors be aware of?

Risks may include provider default, policy shifts, or funding changes. We mitigate this through a rigorous selection process.

Can the properties be viewed before investing?

Subject to agreement with the provider, viewings can be arranged for eligible investors. We always respect tenant privacy and operational protocols.

What are secured loan notes?

Secured loan notes are structured, fixed-term investments where capital is lent to support real asset projects. Investors receive a defined yield over the agreed term, supported by legal security.

Who are these opportunities suitable for?

They are available exclusively to High Net-Worth Individuals, Sophisticated Investors, and Professional Clients. These are not retail investments.

How is investor capital protected?

Capital is secured through a legal charge, held by an independent trustee, giving investors priority in the event of recovery.

Returns are contractually defined within the loan note terms, typically offering predictable yields. While structured for stability, capital is always at risk.

What does the investment process involve?

Once eligibility is confirmed, investors receive a due diligence overview and the loan note agreement for review. Onboarding is supported by trustee documentation, with investments commencing when cleared funds are received.

How are these different from traditional property investment?

Loan notes allow for leaner deployment of capital than direct property ownership. Instead of managing tenants or developments, investors participate in a fixed-income structure with defined returns and oversight.

What risks should investors be aware of?

Capital is at risk. Key considerations include project timelines, planning outcomes, or wider market conditions. These are reviewed carefully as part of due diligence.

How can I review full details?

Following confirmation of investor status, we provide private access to the investment overview and arrange a confidential consultation to discuss the opportunity.

What are Actively Managed Certificates (AMCs)?

AMCs are listed investment certificates that track a defined strategy, managed by professional portfolio managers. They may target fixed income, capital growth, or a blend of both.

How do AMCs generate returns?

Returns are achieved by following a clear investment strategy, with managers actively allocating capital in line with the defined mandate.

AMCs are managed by institutional professionals, with performance monitored against the stated objectives.

What makes AMCs different from traditional funds?

Unlike traditional pooled funds, AMCs are exchange-listed certificates with flexible design and direct tradability.

AMCs are listed instruments but are not retail products. Access is limited to qualified investors.

What risks should investors be aware of?

Risks include strategy underperformance, market fluctuations, and currency exposures.

Who are AMCs suitable for?

AMCs are available to High Net-Worth Individuals, Sophisticated Investors, and Professional Clients.

How can I access further details?

Once investor status is confirmed, private access to the AMC overview is provided.

What are Digital Asset Strategies?

They are proprietary trading models in cryptocurrency markets, using both spot and derivatives positions. Two core approaches are typically applied: one prioritises capital preservation in spot markets, while another captures volatility in derivatives markets with high-frequency execution.

How are returns generated?

Returns are achieved through discretionary long/short trading, risk-managed leverage, and adaptive hedging frameworks. The strategies exploit market inefficiencies, momentum shifts, and structural dislocations, aiming to generate consistent absolute returns across cycles.

What performance history supports these strategies?

The strategies have demonstrated historically strong compounding outcomes across different market cycles, showing resilience during both high-volatility and more stable periods. Full performance records, verified through on-chain and exchange-linked data, can be requested in a private overview once investor eligibility has been confirmed.

Strict risk controls are applied, including predefined stop-loss levels, hedging with perpetual futures, and dynamic position sizing. Maximum drawdowns have historically remained limited, reflecting a capital preservation-first mandate.

Are these opportunities regulated?

The strategies themselves are not FCA-regulated financial products. However, compliance protocols such as KYC and AML are applied, and performance is verified through on-chain data and exchange-linked records. Investors should always seek independent financial advice.

What are the expected returns?

Outcomes are structured according to tiered investment levels, with higher commitments providing access to enhanced structures. Specific performance targets are not published publicly, but certified investors may request access to a private overview once eligibility has been confirmed.

How liquid are these investments?

Withdrawals are structured with notice periods of 30–90 days depending on tier. This ensures tactical capital deployment while maintaining flexibility.

Who are these opportunities suitable for?

Access is strictly limited to High Net-Worth Individuals, Sophisticated Investors, and Professional Clients. These are not retail investments, and all capital is at risk.

What risks should investors consider?

Risks include market volatility, liquidity shifts, derivatives exposure, and policy or regulatory developments. Capital loss is possible, and past performance is not a guarantee of future outcomes.

What is meant by a regulated FX platform?

A regulated FX platform operates under the supervision of a recognised financial authority, such as the FCA, ASIC, or equivalent international regulators. These platforms are required to meet defined standards relating to capital adequacy, client protection, reporting, and operational conduct.

How is investor capital protected on regulated platforms?

Regulated brokers are required to hold client funds in segregated accounts, typically with Tier-1 banking institutions. This separation ensures client capital is not commingled with the broker’s operational funds and is protected from creditor claims should the firm encounter financial difficulty. In certain jurisdictions, investors may also fall under statutory compensation schemes if a broker becomes insolvent.

What safeguards exist against excessive losses?

Many regulatory frameworks require platforms to implement negative balance protection, ensuring that losses cannot exceed the capital held within an account. In addition, leverage limits are imposed by regulators to reduce exposure to extreme market volatility and prevent disproportionate risk.

How is fair execution ensured?

Regulated FX platforms are subject to best execution requirements. This obligates firms to seek the most favourable pricing and execution conditions available at the time of a trade. Brokers must also disclose how orders are routed and how potential conflicts of interest are managed.

What level of transparency can investors expect?

Investors receive standardised reporting covering trade execution, fees, and costs. These reporting obligations are defined by regulatory frameworks such as MiFID II and are designed to ensure clarity and accountability in how transactions are processed.

How are disputes handled?

If a dispute arises, regulated platforms provide access to independent dispute resolution bodies, such as a Financial Ombudsman Service or equivalent authority. These services offer an external mechanism for resolving issues without additional cost to the investor.

What compliance and security standards apply?

Regulated platforms are required to adhere to strict Know Your Customer (KYC) and Anti-Money Laundering (AML) protocols. While this can extend onboarding timelines, it provides an added layer of protection against fraud and misuse. Firms must also maintain robust cybersecurity measures, including encryption and multi-factor authentication, to safeguard personal and financial data.

Does Thomas Kelly Holdings manage or control FX accounts?

Thomas Kelly Holdings does not manage FX accounts or provide trading advice. Our role is limited to introducing suitable regulated platforms where appropriate. Any engagement with a platform is conducted directly between the investor and the provider.

Where can I find further information on platform access?

Further information on platform access and referral pathways is available within the Investment Opportunities section.

What is meant by an off-market luxury investment?

An off-market luxury investment refers to an asset that is not publicly advertised or listed on open marketplaces. These opportunities are introduced privately through established broker networks, advisers, or direct relationships, rather than through public listing platforms.

Why do sellers choose to transact off-market?

Sellers often prioritise privacy, certainty, and discretion over broad exposure. Off-market transactions allow owners to control who has visibility of the asset, limit speculative interest, and avoid the disruption that public marketing can create, particularly for high-value or lifestyle-sensitive assets.

How does off-market access benefit investors?

By operating outside public marketplaces, investors avoid competitive bidding environments and the price inflation often driven by public demand. This can create space for more measured negotiation, flexible structuring, and earlier engagement with assets before they are widely known.

What types of assets are typically accessed off-market?

Off-market luxury opportunities may include high-end residential property, boutique hotels, commercial portfolios, super yachts, and rare or collectible assets such as prestige vehicles. These assets are often introduced privately to maintain value, confidentiality, and operational stability.

How is discretion maintained throughout the process?

Transactions are handled within a closed network of trusted counterparties. Information is shared selectively, documentation is exchanged through secure channels, and public visibility of ownership or transaction details is minimised wherever possible.

Does off-market mean higher risk?

Off-market does not imply lower standards. Each opportunity is assessed on its own merits, including asset quality, legal structure, and counterparties involved. Privacy relates to how the opportunity is introduced, not to the level of scrutiny applied.

How does Thomas Kelly Holdings participate in these transactions?

Thomas Kelly Holdings acts as an introducer, facilitating access to suitable off-market opportunities through established relationships. We do not act as brokers or agents for the underlying assets, nor do we manage the assets on behalf of investors.

Are these opportunities suitable for all investors?

Off-market luxury assets are typically appropriate for experienced investors who understand the nature of illiquid, high-value acquisitions and who place importance on discretion and long-term positioning rather than short-term liquidity.

Where can I find further detail on current off-market luxury opportunities?

Further detail on current off-market luxury opportunities is available within the Investment Opportunities section.

Privacy Policy - Thomas Kelly Holdings

Thomas Kelly Holdings Limited

Last updated: December 2025

1. Scope of this Policy

This Privacy Policy explains how Thomas Kelly Holdings Limited (“we”, “us”, or “our”) collects, uses, stores, and protects personal data when users (“you”) access or use our website, services, or related platforms.

This Policy applies to all access and use of the Website, regardless of device, operating system, platform, or geographic location, where such access is legally permitted.

Where our Website contains links to third-party websites, platforms, or services, those third parties operate under their own terms and privacy policies. We do not control, endorse, or accept responsibility for the content, practices, or data handling of any external websites or service providers. We encourage users to review the relevant policies of any third-party sites they choose to access.

This Privacy Policy applies to all natural or legal persons who access the Website from any jurisdiction where such access is lawful.

2. Legal Basis and Consent

We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and, where applicable, the EU General Data Protection Regulation (EU GDPR).

Depending on the nature of the interaction, we process personal data on one or more of the following lawful bases:

Your consent
The performance of a contract or pre-contractual steps
Compliance with legal and regulatory obligations
Our legitimate interests, where those interests are not overridden by your rights

By continuing to use the Website, you acknowledge that you have read and understood this Privacy Policy. Where consent is required, your continued use of the Website or submission of information constitutes valid consent under applicable data protection laws.

If you do not agree with this Privacy Policy, you should discontinue use of the Website.

3. Personal Data We Collect

We may collect personal data when you:

Visit or use the Website
Submit an enquiry or complete a form
Register an account or request access to information
Communicate with us directly

The types of personal data we may collect include:

Identity and contact information (such as name, email address, postal address, telephone number)
Technical data (such as IP address, browser type, device information, and usage data)
Communication records and correspondence
Any information you voluntarily provide through forms or enquiries

Certain information may be collected automatically through cookies and similar technologies. Please refer to our Cookie Policy for further details.

4. Regulatory, AML, and KYC Information

In order to comply with legal, regulatory, and compliance obligations, including Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements, we may request additional personal information and supporting documentation.

This may include, where appropriate:

Date of birth
Government-issued identification (such as passport or driving licence)
Proof of address (such as utility bills)
Tax identification numbers
Source of funds or wealth declarations
Sworn statements or affidavits

Such information may be provided electronically, in writing, or through secure online submission, as deemed appropriate.

We reserve the right to restrict or refuse access to certain services where required verification has not been completed, in accordance with our legal obligations.

5. Use of Personal Data

We use personal data for purposes including:

Operating and maintaining the Website
Responding to enquiries and communications
Providing access to services and information
Meeting regulatory, compliance, and legal obligations
Improving our Website, services, and user experience

Where necessary to deliver services or comply with legal requirements, personal data may be shared with:

Affiliated or group companies
Professional advisers and service providers
Financial institutions and counterparties
Regulatory authorities and law enforcement agencies

Such disclosures are made only where lawful, necessary, and proportionate.

6. Third-Party Partners and Affiliates

If you choose to engage with third-party partners or affiliates via our Website, those parties may collect and process personal data independently under their own privacy policies. We do not control how third parties store or use your data and accept no responsibility for their data practices.

We recommend that users review the privacy policies of any third-party service providers before engaging with them.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations.

In some cases, we may be required to retain certain information even where a request for deletion has been made, particularly where retention is necessary to comply with AML, KYC, or other regulatory requirements.

8. Your Rights

Subject to applicable law, you have the right to:

Access your personal data
Request correction of inaccurate or incomplete data
Request erasure of personal data, where legally permissible
Object to or restrict certain processing activities

Requests may be made using the contact details provided on the Website. All requests will be assessed in accordance with our legal and regulatory obligations.

9. Data Security

We take reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or disclosure. However, no system can be guaranteed to be completely secure.

10. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements or our practices. Any updates will be published on this page, with the “Last updated” date revised accordingly.

11. Contact

If you have any questions regarding this Privacy Policy or how your personal data is handled, please contact us using the details provided on the Website.

Privacy Policy

1. Scope of this Policy

2. Legal Basis and Consent

3. Personal Data We Collect

4. Regulatory, AML, and KYC Information

5. Use of Personal Data

6. Third-Party Partners and Affiliates

7. Data Retention

8. Your Rights

9. Data Security

10. Changes to this Policy

11. Contact

Access to selected opportunities, approached with discretion

If you would like to discuss eligibility, certification, or a specific opportunity in confidence, our team is available for a private consultation.