The policies below include:

 

1. Privacy Policy 

2. Order Execution Policy (formerly Best Execution Policy)

3. Management of conflicts of interest

4. Complaints policy 

5. Client money notice 

6. Rowan Dartington and Co Ltd ("The Firm") Pillar 3 disclosures 

 

1. PRIVACY POLICY

Information collection and use

Rowan Dartington collects your personal information when you make an enquiry via the contact form of this website. We store your personal details in a secure database and use the information you submit only to respond to your enquiry.

By providing your details you acknowledge that you have read this privacy policy and consent to Rowan Dartington using your information for these purposes. All personal information will be used in accordance with the Data Protection Act 1998.

Rowan Dartington may collect the following personal information from you: name, job title, company name, email address, telephone number and fax number.

Information sharing

Rowan Dartington respects your privacy and will not sell, rent or disclose your personal information to anyone.

Keeping updated

Rowan Dartington endeavours to ensure that the information we hold is accurate and up to date. You have the right to access your personal information held by us. If at anytime you would like to see a copy of your personal information or have it updated or removed, please contact us.

Policy changes

Rowan Dartington reserves the right to amend this policy from time to time. If we make any changes to the way in which we use your personal information we will notify you by posting an announcement on our website.

Cookies

A cookie is a small data file that certain web sites write to your hard drive when you visit them. The only personal information a cookie can contain is information a user supplies himself or herself. A cookie can’t read data off your hard disk or read cookie files created by other sites. Cookies, however, enhance our website performance in a number of ways including providing a secure way for us to verify your identity during your visit to our website and personalising your experience on our site making it more convenient for you. We, therefore, use cookie technology to track or record information about visitors to our website. Your privacy and security are not compromised when you accept a cookie from our website.

You can refuse cookies by turning them off on your web browser, but please note this may cause our service not to function as intended.

Questions

If you have any questions please contact us.

 

2. ORDER EXECUTION POLICY (formally Best Execution Policy)

Introduction

The EU Markets in Financial Instruments Directive (‘MiFID’) and corresponding rules of the Financial Conduct Authority (‘FCA’) require that investment firms establish an order execution policy and take all reasonable steps to obtain the best possible results for their clients when executing a Client Order.

This policy outlines all of the reasonable steps taken by Rowan Dartington (‘RD’ or ‘we’ or ‘us’) to ensure that ‘best execution’ is achieved – that is obtaining the best possible results for you when undertaking transactions on your behalf.

We will take all reasonable steps, to achieve the best execution of client orders, subject to different factors which are dependent on the financial instrument and the type of market on which the order is executed.

Client Classification

Our Clients are classified as retail clients unless they opt-up to either Professional or Eligible Counterparty status, but regardless of classification we will treat all clients the same for the purposes of achieving best execution, or getting the best possible result for you when carrying out trades. We always aim to achieve best execution on a consistent basis as outlined in this Order Execution Policy.

Execution Factors

When dealing for you we will consider the following:-

Your characteristics (including your regulatory client categorisation as mentioned above);

The characteristics of the financial instrument concerned and of your order;

Where such orders can be carried out (i.e. the ‘execution venues’).

In assessing the most appropriate route to carry out your order we will consider the following criteria which we have ranked in order of importance:-

Execution Factor	Asset Classification
	Equities	Bonds	FX	Funds	OTC
Price of the instrument	3	3	3	2	3
Execution Venue/Broker	2	2	1	0	3
Overall cost of the transaction	3	3	3	3	3
Need for timely execution	2	2	2	3	2
Likelihood of execution	2	2	2	2	2
Size and nature of the order	2	2	1	1	2
Speed of execution and settlement	3	3	3	1	1

 

Best Execution Criteria	Rank
Critical	3
Important	2
Not important	1
Not applicable	0

 

When dealing in a financial instrument on your behalf we will exercise our discretion in assessing the criteria that we need to take into account to achieve best execution. The relative importance of these criteria will be judged on an order-by-order basis, in line with our commercial experience and with reference to market conditions. In executing orders for clients, in the absence of any specific instructions, we generally give precedence to the factors that allow us to deliver the best possible results in terms of value (total cost) to the client.

If you are a retail client, the best possible result will normally be determined in terms of the total consideration, being the price of the instrument and the costs of the transaction. However, there may be circumstances in which this is not the primary consideration.  Where the instrument is illiquid or the size of the order unusual relative to the normal, then other factors may take precedence, although we will also have to use our judgement in assessing whether particular trading strategies may move the market (incur implicit costs). Alternatively, we may have to execute the order over the course of a number of days in order to complete it.

Execution Venues

For each instrument we execute on behalf of clients it is our policy on an ongoing basis to consider the variety of trading venues or sources of liquidity available from time to time. This enables us to obtain on a consistent basis the best possible result for the execution of transactions. In satisfying this policy, we may consider the use of one or more of the following venue types:

Regulated Markets (e.g. London Stock Exchange or overseas equivalent);

Multilateral Trading Facilities (e.g. Non-Exchange Financial Trading Venues);

Systematic Internalisers (e.g. Market Makers);

Third party investment firms and/or affiliates acting as Market Maker or other liquidity providers;

Non-EU entities performing similar functions.

We regularly assess the execution venues available and may add or delete venues in accordance with our obligation to provide you with the best possible execution result on a consistent basis. An up to date list of execution venues is attached in Appendix 1.Where we believe that best execution can be achieved on clients’ behalf outside Regulated Markets or Multilateral Trading Facilities it is our policy to do so. By agreeing the Order Execution Policy (formally Best Execution Policy) and our terms and conditions, you are giving your express consent to this requirement. In certain financial instruments there may only be one execution venue. In executing a trade in such circumstances we will presume that we have provided the best possible result in this respect for these types of instruments.

Order Handling

Rowan Dartington is committed to prompt and fair treatment of all clients’ orders. Having assessed the relevant criteria and any specific instructions provided by you, we will select the most appropriate venue(s) from those available and execute your order accordingly.

Where you give us specific instructions regarding the execution of an order, or part of an order, we are obliged to execute the order in accordance those instructions, even though this may prevent us from applying the principles stated in this policy.

Limit Orders

Typically we will deal ‘at best’, using prices at the prevailing price in the market. However, if you give us an investment instruction at a specified price limit and for a specified size (a ‘limit order’), then it may not always be possible to execute that order under the prevailing market conditions. If we receive clear instructions from you as to how to execute your order, we will not pay regard to any of the execution factors we would usually consider. We would be required to make your order public (i.e. show the order to the market) unless you agree that we need not do so. We believe it is in your best interests if we exercise our discretion as to whether or not we make your order public. By agreeing to the Order Execution Policy you agree to us not making your orders public, unless we consider it is your best interests for us to do so.

Order Aggregation

We may combine (or ‘aggregate’) an order for our clients with orders of other clients. We would only aggregate a client order if it was unlikely to work to the overall disadvantage of the client. However, the effect of aggregation may on some occasions work to the clients disadvantage and may on occasions result in our clients obtaining a less favourable price than if their order was executed separately.

If an order has been aggregated, but not been allocated in full then generally the distribution of assets will be allocated on a proportionate basis. In these circumstances, it may be more costly to the client as we have to fulfil the order over several transactions each subject to our minimum charges.

In all cases we will judge whether the action taken is in the client’s best interests.

Review and Monitoring

We will review our execution arrangements and venues on at least an annual basis or whenever a material change occurs that affects our ability to obtain the best possible result for our client orders. We will inform you of any material changes to our execution arrangements or our execution policy. We will also periodically monitor the quality of our execution against the factors detailed in this Policy to identify and, where appropriate, enhance our arrangements.

Rowan Dartington will actively monitor compliance with the Order Execution Policy and annually review the Order Execution Policy against the FCA’s rules and guidance annually and ad-hoc driven by regulatory requirements/changes.

General

Rowan Dartington operates on the basis that all Retail clients would be legitimately relying on the firm to deliver best execution for all transactions, regardless of how they arise.

By signing or agreeing to the declaration in the account opening form, you (or your authorised intermediary) consent to our Order Execution Policy including those sections that require your prior express consent.

Please note that if you do not provide your consent to our Order Execution Policy you may be limiting our ability to execute your orders on the most advantageous terms for you. Accordingly, if you do not consent to this Order Execution Policy we will be unable to open an account for you.

From 2018, Rowan Dartington will publish execution quality information on its top 5 executions venues and brokers.

 

Instrument	Main Venues Used	Main Constituents (N.B. these lists are not exhaustive)
UK Stocks and Shares/Warrants	London Stock Exchange, ISDX/PLUS and approved member firms of these venues. We may also use Multilateral Trading Facilities and Dark Pools.	Winterfloods, Peel Hunt, Knight Securities, Investec Bank, Numis Securities, Cenkos, Canaccord, Shore Capital, Singer Capital, Thomas Grant.
Foreign Stocks, Warrants and Depositary Receipts	Regulated exchanges	Knight Securities, Winterfloods, Peel Hunt, Cannacord, Nomura, ICAP, Kaupthing, C Hoare & Co , Liberum Capital.
Investment Trusts	London Stock Exchange	Cantor Fitzgerald, Panmure Gordon, Winterfloods, Collins Stewart, Cenkos, Cannacord Adams, Invesco, Investec, Numis Securities.
Fixed Interest/Bonds (non-UK Government and Corporate)	Major liquidity providers and brokers	Winterfloods GILTS, Bridport, BNP Paribas, Barclays, Investec, Morgan Stanley, Peel Hunt, Rabobank, UBS, Societe Generale, Numis Securities.
Unit Trusts/Exchange Traded Fund’s (ETF’s)	Managers of the funds, Cofunds or regulated markets for exchange traded funds.
UK Treasury Bonds	London Stock Exchange	Winterflood GILTS, Cantor Fitzgerald

 

Asset Classes	Method
Cash	Direct/Indirect
Bonds	Direct/Indirect
Equities	Direct/Indirect
Property	Indirect
Multi-asset	Indirect
Ethical investments	Direct/Indirect

 

3. MANAGEMENT OF CONFLICTS OF INTEREST 

 

What are conflicts of interest?

Legally, a conflict of interest is where a firm puts itself in a position where its own interests conflict with the duty owed to its clients. However, the FCA uses the term to cover all conflicts inherent in and arising from performance of fiduciary duties. Our policy therefore covers:

• Conflicts of interest – where our interests conflict with our clients’
• Conflicts of duty – where our duties to one client conflict with our duty to another
• Duty of confidentiality – which we owe to our clients

FCA Requirements

FCA Principle 8 – ‘A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client’. The SYSC Rules also require us to have adequate systems and controls to manage risks. The new MiFID Rules require us to formally document this. It is not sufficient that we rely solely on disclosure of conflicts in customer agreements etc.

Conflicts of Interest Policy

In accordance with our regulatory requirements it is our policy to identify all potential material conflicts inherent in our business and have adequate systems and controls to avoid or mitigate their impact on customers, including disclosure to customers as appropriate.

It is incumbent on our Board to consider and all our staff to escalate any matter that they consider may conflict with our policy. The Risk Management Committee regularly reviews any issues raised in this manner or by virtue of any other business development.

Conflicts Inventory

 

Potential Conflicts

Management Arrangements

Dealing with customers	What we do
Promotional material That financial promotions including non-independent investment research promotions, are unfair, unclear and/or misleading.	All such material is approved by individuals assessed as competent and formally apportioned responsibility and is independently signed off by a qualified person other than the preparer
Third party marketers That inappropriately licensed or disreputable firms with undisclosed remuneration arrangements are involved in attracting new clients.	Rowan Dartington has no third party marketers.
Preferential arrangements That arrangements are established providing advantages for certain investors that disadvantage others.	Rowan Dartington has not entered into any arrangements with particular clients that could disadvantage any other clients and ensures all research issued is distributed to clients fairly.
Interests in issuers Recommendations are made to clients where we have a material or other commercial interests and the objectivity of the recommendation is compromised.	Rowan Dartington does not make research recommendations on the securities of issuers where it has had material or other commercial interests in the previous 12 months. Where it does, it will disclose such information to clients on a case-by-case basis. Materials issued to promote the shares of issuers with whom we have a relationship are clearly marked as promotional material.
Portfolios May be managed on behalf of persons who in turn introduce other clients	All portfolios are managed on a commercial arms-length basis. Our relationships with introducers are documented and transparent.

 

Execution of Transactions	What we do
Suitability That suitability requirements are not adhered to and that excessive transactions are undertaken.	Rowan Dartington establishes its clients’ understanding of risk, their ability to withstand losses and their investment objectives prior to commencement of business and on an ongoing basis. Rowan Dartington’s internal procedures outline how these factors should be taken into account and are independently monitored.
Confidentiality That commercial or private information is not sufficiently protected	The standards relating to the imperative of client and commercial confidentiality are clearly laid out in our internal procedures.
Appropriateness That the appropriateness of relevant transactions is not established and our interests as a firm are put before those of clients.	During the client classification process Rowan Dartington establishes clients’ understanding of risk and endeavours to highlight where clients’ instructions appear uncorrelated to this understanding.
Activity Levels That client transaction activity levels are either less or more than the level appropriate to meet its investment objectives.	Activity levels are reviewed by business and risk management on a regular basis to identify patterns of activity outside normal parameters.
Transaction Order Handling That customer orders are not handled fairly in relation to other customers or the firm.	Transactions are either handled in accordance with customers specific instructions or in accordance with procedures requiring fair treatment for all customers and are independently monitored.
Best Execution That transaction quality or counterpart relationships are negligently managed.	Rowan Dartington has established a Best Execution Policy which is communicated to all staff and clients.
Market Abuse That we undertake activities that constitute market abuse, including market timing, that compromise the integrity of our investment process or product.	Rowan Dartington has in place practices and policies to ensure awareness amongst all staff of its, and their, obligations and actively trains its staff to reinforce and administer its Market Abuse prevention regime.
Trade Errors That the costs of client trading errors are inappropriately picked up.	Rowan Dartington’s trade error resolution policy is to make good any errors arising from its own errors. Rowan Dartington does not pick up the costs of errors made by clients.
Principal Trading That the interests of the firm are put before those of clients e.g. front running.	Rowan Dartington makes clear where it, or an affiliate, may have an interest in certain securities and its internal procedures are designed to ensure customers’ interests are given the highest priority.
PA Dealing That the interests of staff are put before those of clients e.g. front running	The standards expected of staff in relation to their PA deals are clearly laid out and communicated via internal procedures. All deals must be independently approved prior to execution and retrospectively reviewed.

 

Infrastructure Arrangements	What we do
Firm remuneration That the firms remuneration arrangements are undisclosed.	Rowan Dartington’s client agreements set out the basis of our remuneration in full.
Staff remuneration That staff are remunerated to act in a manner that conflicts with clients objectives.	The long-term interests of our staff are designed to correlate with the interests and financial wellbeing of our clients and their activities are overseen and monitored.
Recruitment and development That inappropriate staff are hired or that staff are not adequately developed.	Rowan Dartington aims to hire experienced professionals and has in place a rigorous referencing and recruitment process. This is complemented with a formal appraisal and personal development programme.
Key Man Risk That reasonable arrangements to minimise the likelihood of losing key staff are not established.	Key individuals are identified on an ongoing basis and succession plans and development arrangements are adopted as appropriate.
Insufficient Resources That insufficient financial or human resources are in place to ensure delivery of contractual obligations and that sufficient segregation of duties is maintained to manage risk.	Rowan Dartington carries excess capital in accordance with its regulatory requirements. During its annual budgeting processes it has full regard to the need to maintain adequate resources to fulfil its contractual obligations and the maintenance of segregation of duties in key areas.
Gifts and entertainment (Inducements) That the integrity of either staff or suppliers is compromised by excessive largess.	The standards expected and the internal approval and disclosure requirements with regard to inducements are clearly set out in our internal procedures.
Business Continuity That inadequate arrangements are established to ensure continuance of the business in the event of a disaster.	Rowan Dartington regularly tests the adequacy of key components of its plans.

 

 

4. COMPLAINTS POLICY 

Procedures

Rowan Dartington & Co Ltd always aims to provide the highest standard of service to its clients but on occasions we may fall short of this goal and a client may express dissatisfaction.

When we receive any letter, fax, email, telephone call or personal communication which expresses dissatisfaction about services which we have provided or failed to provide, we will attempt to resolve the matter promptly and fairly.

Acknowledgement of Complaints

Whether you complain during a telephone conversation or meeting, in a letter, email or other communication, we will record your concerns and pass the details to our Compliance Department for investigation. You will receive an acknowledgement from us within five business days, detailing our understanding of your concerns and confirming the ‘next steps’.

Investigation and Resolution

The Compliance Department will investigate your complaint and attempt to resolve it as quickly as possible. You may be asked to provide additional information to assist in this process.

We aim always to resolve complaints within eight weeks and we will attempt to issue you with a final response during this time. If we are unable to resolve your concerns within 8 weeks, a letter explaining why we are not in a position to make a final response and when this can be expected will be sent to you. This letter will also inform you of your right to refer your complaint to the Financial Ombudsman Service, if applicable.

The final response will set out the facts that have been established during the investigation and any resolution to be offered (which may include financial compensation), if any, taking into consideration:

• Fair compensation for actual or potential financial loss;
• Any reasonable costs you have claimed; and
• Lost Interest which could have accrued since the date on which the loss was suffered.

Your rights

An eligible complainant (who has not been classed as an “Opted Up Professional Client or Eligible Counterparty”) has a right to refer a complaint directly to the Financial Ombudsman Service but only after we have had an opportunity to consider it and/or eight weeks have elapsed since the date of the complaint. An eligible complainant is defined as:

More information on the Financial Ombudsmen Service can be found here: http://www.financial-ombudsman.org.uk

 

5. CLIENT MONEY NOTICE 

 

As a firm which is both authorised and regulated by the Financial Conduct Authority (FCA), Rowan Dartington is required to comply with the rules prescribed in the FCA Handbook. The handbook details rules on handling both client assets and client money.

Depositing client money & Interest Rates on deposit balances

FCA rules (CASS 7.13.3) also state that client monies need to be deposited with an approved bank of the firm’s choosing.

The current rate of interest paid by Rowan Dartington is:

• Holding under £1m - 0.00%
• Holdings over £1m - 0.25%

The above rates apply to individual cash balances held in each of your cash accounts at Rowan Dartington which may include separate Deposit, Income, ISA Deposit and ISA Income balances. These balances are not aggregated at a client level for calculation of interest paid. The interest rate band within which the individual cash balance falls is applicable to the entire balance.

Any interest due will be calculated daily and be paid quarterly in arrears.

Rate change with effect from 1 July 2017

With effect from 1 July 2017, the rate of interest paid by Rowan Dartington will reduce to nil.

 

6. ROWAN DARTINGTON & CO LTD (" THE FIRM") PILLAR 3 DISCLOSURES 

 

Overview

The Capital Requirements Directive (“CRD”) of the European Union created a revised regulatory capital framework across Europe governing how much capital financial services firms must retain. The rules are set out in the CRD under three pillars:

Pillar 1 sets out the minimum capital resource requirement firms are required to maintain to meet credit, market and operational risks.

Pillar 2 requires firms to assess firm-specific risks not covered by Pillar 1 and, where necessary, maintain additional capital.

Pillar 3 requires firms to disclose information regarding their risk assessment process and capital resources with the aim to encourage market discipline by allowing market participants to assess key information on risk exposure and the risk assessment process.

The rules in the FCA Prudential Sourcebook for Banks, Building Societies and Investment Firms (“BIPRU”) set out the provision for Pillar 3 disclosure. This document is designed to meet our Pillar 3 disclosure obligations.

Verification

These disclosures have been prepared in order to comply with regulatory requirements and provide information on risk management policies and certain capital requirements. They do not constitute financial statements and are based on unaudited financial positions and should not be relied upon in making judgements about the Firm.

Scope and application of the requirements

The Firm is authorised and regulated by the Financial Conduct Authority (“FCA”) to conduct investment business, with permission to hold and control client money.

Risk appetite and management

The Firm is exposed to a variety of risks, as analysed and quantified below. However, the Board has adopted a conservative approach to risk, resulting in a low risk profile for the Firm, for the following reasons:

• The business model is straightforward stockbroking and investment management. As principal positions are not taken, the Firm’s risk exposure is limited to counterparty risk and the impact on income;
• The recruitment of experienced personnel throughout the Firm;
• Limited exposure to credit risk;
• The corporate governance structure ensures that responsibilities within the Firm are apportioned correctly within ‘oversight’ functions staffed by experienced personnel with access to Senior Management;
• Comprehensive insurance arrangements which provide higher levels of cover than historic loss data would indicate is required.

Risk management is a fundamental part of the day to day management of the Firm, both within operational procedures to ensure that the risks associated with the provision of investment management and stockbroking services are mitigated by appropriate controls and processes and also within our fundamental approach to stock selection and daily management of the client investment portfolios, supported by our proprietary Portfolio Management System (PMS).

The Board meets Monthly, or as and when necessary, and has primary responsibility for governance and oversight of the Firm. The Director of Compliance & Risk provides independent oversight over the Firm’s risk management process and controls, and has overseen the development of the Risk Management Policy. This sets out the Firm’s processes for the management of internal and external risks arising from Market, Credit, Operational, Liquidity and other relevant risk categories, which form the basis for the risk management procedures. The Risk Management Policy is reviewed regularly.

Operational, market, credit and regulatory risks are reviewed monthly by the Risk Committee and monitored via a risk management system. A monthly management pack is produced by Compliance & Risk and reviewed by the Risk Committee, and a Board Pack is presented to the Board each month. The pack includes key risk metrics.

Capital adequacy and ICAAP

As at 31st December 2014, the Firm held regulatory capital resources that far exceeds its current requirements.

As the Firm is an IFPRU €125K firm, its capital requirements are the greatest of:

The Firm’s Pillar 1 Capital requirement for the year 2015 has been determined by reference to the Firm’s fixed overhead requirement and calculated in accordance with the FCA’s General Prudential Sourcebook (“GENPRU”). The fixed overhead capital requirement exceeded both the base capital requirement and the sum of the market risk and credit risk capital requirement.

The Firm’s overall approach to assessing the adequacy of its internal capital is set out in our Internal Capital Adequacy Assessment Process (ICAAP).

The ICAAP process involves separate consideration of risks to the Firm’s capital combined with stress testing analysis to determine whether any additional capital is required for Pillar 2.

The Firm has calculated its capital requirement in accordance with the relevant FCA rules and the final level of capital is calculated as the base capital requirement. On completion of the ICAAP process it was concluded that no additional Pillar 2 operational risk capital is required.

Material risks

The material risks for the Firm are as follows:

Credit & Settlement Risk

Credit risk is the risk that unexpected losses may arise as a result of the Firm’s clients and counterparties failing to meet their obligations to settle transactions.

The Firm’s Credit risk is limited. The only material credit exposures are amounts receivable from market and client counterparties, including bank deposits. Since the great majority of business is carried out on a delivery verses payment basis, exposure to unsettled market and client positions is limited to the extent of market movements between trade date and settlement date. UK market counterparties are members of the London Stock Exchange and / or are FCA regulated, hence credit risk is significantly reduced. The Firm has a small number of overseas market counterparties which are reviewed on a regular basis.

Capital is set aside to mitigate the risk in accordance with the Pillar 1 Counterparty Credit Risk Requirement.

Liquidity Risk

Liquidity risk is the risk that the Firm will not be able to meet its financial obligations as they fall due.

Working capital ratios are considered adequate given the nature of trade settlement and the stable nature of administrative expenses.

The Firm operates and reviews its Liquidity Risk Framework to ensure the Liquidity Position is acceptable. This is reviewed on a regular basis, and at times of material change in the business. The Board is satisfied that there is no specific risk arising from liquidity and, in the unlikely event of requiring additional capital, the Firm has contingency funding arrangement in place with the major shareholders.

Business Risk

The key business risk is a reduction in funds under management, following a market downturn or loss of clients, resulting in lower management fees and trade commission. Management carry out stress-testing in order to assess the impact on profit and loss from various scenarios where funds under management fall.

Market Risk

The Firm has a small exposure to foreign exchange risk through its foreign currency trade receivables and payables. Foreign exchange positions are held on an intra-day basis only and purely for settlement purposes. In the opinion of the Directors, the residual foreign exchange risk is adequately addressed through the Pillar 1 market risk capital requirement for this risk.

Operational Risk

Operational risk is the risk of loss to the Firm resulting from failed or inappropriate internal procedures, people and systems, or from external events.

The Directors consider the Firm’s arrangements for monitoring, recording and mitigating operational risk to be appropriate to the size, nature and complexity of the business. Extensive management information is prepared on a monthly basis by the Finance and Compliance & Risk departments and there are clear lines of escalation within the Firm.

The Firm employs experienced staff in the management of operational risk, together with clear segregation of duties and robust documented operational procedures.

The management and monitoring of outsourcing relationships is a key control. The Firm monitors qualitative performance of functions outsourced to third party service providers to ensure adherence to contractual obligations.

Business continuity risk is the risk of interruption to the business due to the unavailability of systems or office space. The Firm has a comprehensive business continuity strategy.

The Firm also mitigates its operational risk by means of a comprehensive Professional Indemnity insurance policy providing cover of up to £10m per annum.

The Board of Directors recognise that not all of the risks to which the Firm is exposed can be mitigated by the addition of incremental capital, hence those other risks, such as reputation and legal risks, are managed by internal policies and procedures and monitored by management on an on-going basis.

Additional risks identified within the overall Pillar 2 rule have been assessed and evaluated by the Directors, and are not considered to be material to the Firm.

Remuneration

The Firm has been subject to the Remuneration Code (the “Code”) since 1 January 2011. The Code governs the remuneration policies of regulated firms and aims to ensure that firms establish, implement and maintain remuneration policies, procedures and practices that promote effective risk management.

The Firm provides discretionary, advisory and execution only services on an agency basis and does not trade on its own account. It is conservative in its approach to risk taking and has a comprehensive framework of systems and controls in place.

The remuneration policies of the Firm are managed and reviewed by the Remuneration Committee which has established and implemented policies which meet the requirements of the Code as applicable to a Tier 4 firm and are considered to be appropriate given the nature and scope of the business.

Overall remuneration in terms of salaries costs and bonus levels are reviewed annually by the Board.