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(1) (in relation to 131 PROD 1.3 and PROD 3) a firm which offers, recommends or sells investments or provides investment services to clients.121[Note: recital 15 to the MiFID Delegated Directive](2) (in relation to PROD 1.4 and PROD 4) a firm which advises on or proposes contracts of insurance which it does not manufacture.121

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