The policies below include:

 

1. Order Execution Policy (formerly Best Execution Policy)

2. Management of conflicts of interest

3. Complaints policy 

4. Client money notice 

5. Stewardship Code

6. Pillar 3 Disclosures

7. Candidate Privacy Policy

 

1. ORDER EXECUTION POLICY (formerly 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 sufficient steps to obtain the best possible results for their Clients when executing a Client Order.

This policy outlines all of the sufficient 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 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[1], 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.

[1] The definitions of Professional and Eligible Counterparties can be found in the FCA Handbook

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:

*FX – A stand-alone foreign exchange transaction

**OTC – Any security which needs to be traded bilaterally with a counterparty, but not conducted over an exchange.

 

 

This explains how we would normally behave when placing client orders, but of course, each order will be considered as it arrives and will be processed as market conditions and our experience dictate. 

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, those costs being all expenses incurred which are directly related to the execution of the order. 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 working days in order to complete it. Likewise, the characteristics of an order may require us to transmit an order to a counterparty to execute on our behalf, rather than dealing directly with that counterparty (for example, orders in securities traded on overseas markets).

When placing Execution only or Advisory deals which have been discussed with Clients, we will be careful to ensure that any quotes given to the Client are current, taking into account changing market conditions.

 

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 significant execution venues is attached in Appendix 1. As Members of the London Stock Exchange (LSE), a very large proportion of our trades in direct securities take place using LSE counterparts. 

The selection of counterparties and trade routing mechanisms is based on an assessment of factors such as market coverage, liquidity access, trading competitiveness and competence and operational capability, it is known as “ex-ante” selection.

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 to our terms and conditions you are also agreeing to our Order Execution Policy, and as such you are giving your express consent to this requirement.

Exposure to different financial assets can be achieved directly, by purchasing the actual securities, or indirectly, by purchasing a collective investment of these securities. The venue and method chosen will be dependent upon which of the routes is chosen.

In certain financial instruments there may only be one execution venue. Each fund manager is usually the order execution venue for transactions in their own funds, for example. 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.  We will often deal through a trading platform, such as Cofunds, since these intermediaries have access to the widest range of fund venues.  Since there are no competing venues for such trades, our obligation is to submit the required trades to the platform in a timely fashion.

Costs and Charges

We use a variety of different channels and counterparties to execute orders on behalf of Clients and to facilitate the investment of Clients’ portfolios.   RD’s own fees and commissions, where levied, are deducted from client portfolios as determined by the service to which the Client signs up (e.g., custody and execution fees for Execution only business, advisory fees for Advisory business and management fees for Discretionary business).  In addition, Clients will pay taxes (stamp duty) as they accrue, and fund management expenses embedded in the dealing prices of the collective vehicles in which we invest. 

The different channels we use to execute transactions will have different explicit costs associated with them.  But, with the exception of transactions in foreign listed securities, these costs will be absorbed by RD and are not passed on to the Client.

We do not accept any form of non-monetary benefit from routing orders through certain execution venues and do not structure charges or commission in any way that would favour or discriminate unfairly between execution venues. Gifts and hospitality may be permitted but only if they comply with both our Conflicts of Interests Policy and Gifts and Hospitality Policy.  Under FCA rules we are not allowed to receive investment research in exchange for dealing commission paid to brokers.

Order Handling

We are committed to the prompt and fair treatment of all Clients’ orders. As soon as a client order has been accepted or the manager has made a decision to deal on behalf of a discretionary client, the order will be passed immediately to a dealer to be executed as soon as reasonably practicable. However, it is acceptable to postpone execution of an order if this, is considered to be in the Client’s best interests.

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.

You are able to give us specific instructions regarding the execution of an order, or part of an order and we will execute in accordance with those instructions. 

Warning: Giving specific instructions may prevent us from following our execution policy to obtain the best possible results in respect of your instructions. We will apply our policy to all other aspects of the trade.

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 prioritise the execution factors we would usually consider except that we would have to follow market etiquette.

Unless the order is large in scale compared with normal markets, where the limit order is not immediately executed under prevailing market conditions, we are required to make your order public (i.e. show the order to the market) unless you expressly request otherwise.

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. We do not aggregate client orders with transactions undertaken for our own account.

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.

These procedures include discussions between our traders and counterparties on an order by order basis; information as published by the Execution Venues; the use of Transaction Cost Analysis tools to assess trading performance; and a formal review of counterparty financial strength and operational efficiency.

RD 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.

The firm has established a Best Execution Committee as part of its governance of the investment process.  This Committee meets monthly, receives and observes upon management information regarding our Best Execution performance, implements corrective actions where required and is responsible for the development and implementation of proper policies and procedures.

General

RD 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.

You have the right to request that RD demonstrate to you how we have executed your order in line with this policy.

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

Appendix 1

Execution Venues and Counterparties

 

 

RTS 28 Report and Summary

Top 5 Execution Venues 2019

 

 

Introduction

Rowan Dartington is an Investment Firm regulated by the Financial Conduct Authority. When executing orders on your behalf, the firm has an obligation to take all ‘sufficient’ steps to obtain the best possible result when executing, transmitting and placing orders on behalf of clients on a consistent basis. To ensure this requirement is met, Rowan Dartington has established an Order Execution Policy that sets out the steps that the firm and its employees takes to achieve Best Execution for our clients.

 

The purpose of this document is to provide Rowan Dartington’s existing and prospective clients with enough information to effectively allow for comparison between the quality of execution achieved through Rowan Dartington against other providers. This will allow you to determine whether we are providing an effective order execution service.

 

Rowan Dartington’s transactions around or below the exchange market size (EMS) for each security will generally be dealt through our Retail Service Providers. Trades that fall outside the EMS will be worked through the market where liquidity and other factors may be an issue. Where appropriate to do so, larger orders are usually aggregated with other clients’ and these will be worked through various execution venues to achieve the best possible outcome for clients.

 

Client Categorisation

Rowan Dartington & Co Ltd classifies all clients as Retail for the purposes of best execution unless you choose to opt-up to Professional or Eligible Counterparty status. Therefore, 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, those costs being all expenses incurred which are directly related to the execution of the order.

 

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 trading strategies may move the market (incur implicit costs). Alternatively, we may have to execute the order over the course of several working days in order to complete it. Likewise, the characteristics of an order may require us to transmit an order to a counterparty to execute on our behalf, rather than dealing directly with that counterparty (for example, orders in securities traded on overseas markets).

 

When executing orders which have been discussed with Clients, we will be careful to ensure that any quotes given to the you are current, and fully consider the changing market conditions

 

Specific Relationships and Arrangements

Rowan Dartington does not receive payments, discounts, rebates or non-monetary benefits in relation to its trading arrangements. In addition, the research regulations set by the Financial Conduct Authority (FCA) prohibits us from continuing portfolio management services and receiving inducements in relation to those services.

 

Any minor non-monetary benefits received must be of a scale and nature that could not be impair the judgement of Rowan Dartington’s compliance with its duty to act honestly, fairly and professionally in the best interests of the client.

 

Rowan Dartington has therefore put in place strict requirements around the acceptance of non-monetary benefits through its Policies. As a firm, Rowan Dartington also has processes in place to ensure that there is adequate pre-acceptance sign off for gifts and hospitality to ensure that Rowan Dartington and its employees are not encouraged to use one particular execution venue over another.

 

In summary, Rowan Dartington does not have any conflicts, close links or common ownerships with respect to execution venues and it does not receive any rebates, discounts, payments or non-monetary benefits for routing orders to a venue/broker. Rowan Dartington does not have any specific arrangements with brokers or venues.

 

 

 

Execution Venues

To ensure that Rowan Dartington has the best possible coverage, and in turn our clients achieved the best possible outcomes, in the asset classes in which we transact our clients' business, Rowan Dartington utilises a large and varying number of execution venues and liquidity providers to obtain the best possible execution for each transaction. A list of the most utilised venues and liquidity providers can be viewed on the Rowan Dartington website along with our current Order Execution Policy Summary.

 

Rowan Dartington did not in 2019 place significant reliance on any one liquidity provider to execute orders with the exception of Unit Trusts where reliance was placed on Aegon (CoFunds).

 

During 2019, our execution due diligence led to the removal of Knight Securities and Thomas Grant for equities whilst adding the services of Stifel Nicolaus. We also no longer use the services of Collins Stewart or BNP Paribas.

 

Execution Factors and Criteria

In order to ensure that orders executed on your behalf achieve the best possible outcome, we aim to ensure that we have formalised the best possible environment and processes to enable us to deliver on a consistent basis the best possible result for our clients.

 

To ensure we have the best possible chance of executing orders favourably for our clients, we have put in place the following measures:

• a robust Order Execution Policy along with established trading procedures/controls;
• systems that provide Rowan Dartington with access to a variety of execution venues and counterparties;
• an expert Dealing team who ensure that client orders are dealt in line with our Order Execution Policy whilst giving due regard to the applicable execution factors;
• the formation of a Best Execution Committee, comprising of individuals from the investments, trading, compliance and risk teams to supervise our Order Execution process as well as our trading policies and procedures.

 

The relative importance of each execution factor is particular to the circumstances surrounding each client order. The Dealing Desk makes their assessment of the pre-trade execution factors, such as price, cost (implicit and explicit), speed, size and likelihood of execution and settlement with the objective of ensuring the best possible outcome for you as the client.

 

Additionally, when dealing for you we will consider the following as part of our order execution process:

• Your characteristics
• 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

 

* FX – A stand-alone foreign exchange transaction

** OTC – A security which needs to be traded bilaterally with a counterparty, but not conducted over an exchange.

 

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

 

This explains how we would normally behave when placing client orders, but of course, each order will be considered as it arrives and will be processed as market conditions and our experience dictate. 

 

 

 

When placing Execution only or Advisory deals which have been discussed with Clients, we will be careful to ensure that any quotes given to the Client are current considering changing market conditions.

 

Monitoring of Best Execution

Rowan Dartington currently uses the TZ Trade Surveillance system from eflow to analyse execution performance. TZ Best Execution provides analysis and reporting for all transactions executed by Rowan Dartington. The system meets the MiFID II best execution standards, complying with the latest requirements around the execution of transactions.

 

To monitor and measure execution performance, TZ benchmarks all Rowan Dartington’s client orders against the leading venues where there was an executable price at the time of trade. TZ Best Execution benchmarks include best bid/ask, implementation shortfall, consolidated BBO, moving VWAPs and reversion calculations.

 

Our post-trade monitoring also includes reviewing Transaction Cost Analysis (TCA) reports as well as exception based price/basis point monitoring reports depending on the specific class of financial instrument being traded. Trade executions that fall outside of designated tolerances are highlighted and investigated initially by the relevant trading desk, as the first line of control.

 

Tolerances are used to identify trades which have been executed outside a specific range compared to the market price / benchmark price at point of execution and arrival price for certain types of trades. The price and basis point tolerance ranges are set by the Best Execution Committee and agreed with Compliance. For timed orders other relevant pricing points, such as market close or other reference points may be used as a benchmark.

 

Alongside the daily monitoring of transactions, Rowan Dartington also conducts initial and annual assessment of   its core liquidity providers to ensure each counterparty used is providing us, and in turn you, with the desired level of service and execution. Any execution venues, market makers and systematic internalisers that the Rowan Dartington deal with are required to publish daily trading data on a quarterly basis.  This information will be used to continually assess that the providers we use are meeting both ours and your requirements.

 

 

Fixed Income

Counterparty	% of Value Traded	% of Orders Made	% of Passive Orders	% of Aggressive Orders	% of Direct Orders	Avg. less than 1 trade per business day?
WINTERFLOOD GILTS	27.17%	26.64%	n/a	n/a	0	No
PERSHING SECS. LTD.	26.19%	16.35%	n/a	n/a	0	Yes
PEEL HUNT LTD	18.03%	18.97%	n/a	n/a	0	Yes
J.P. MORGAN SECS LTD	8.84%	2.62%	n/a	n/a	0	Yes
CANACCORD ADAMS	8.71%	15.44%	n/a	n/a	0	Yes

 

Equities (0-79)

Counterparty	% of Value Traded	% of Orders Made	% of Passive Orders	% of Aggressive Orders	% of Direct Orders	Avg. less than 1 trade per business day?
PEEL HUNT LTD	23.46%	10.92%	n/a	n/a	0	No
WINTERFLOOD SECS LTD	16.64%	21.03%	n/a	n/a	0	No
NUMIS SECURITIES LTD	8.60%	7.98%	n/a	n/a	0	No
CANACCORD ADAMS	5.66%	3.36%	n/a	n/a	0	No
JEFFERIES INTERNATL.	4.85%	4.97%	n/a	n/a	0	No

 

 

 

 

 

 

Equities (80-1999)

Counterparty	% of Value Traded	% of Orders Made	% of Passive Orders	% of Aggressive Orders	% of Direct Orders	Avg. less than 1 trade per business day?
PEEL HUNT LTD	22.79%	16.22%	n/a	n/a	0	No
WINTERFLOOD SECS LTD	19.59%	22.62%	n/a	n/a	0	No
NUMIS SECURITIES LTD	10.57%	9.96%	n/a	n/a	0	No
PERSHING SECS. LTD.	8.11%	1.64%	n/a	n/a	0	No
INVESTEC BANK UK	5.24%	5.94%	n/a	n/a	0	No

 

Equities (2000+)

Counterparty	% of Value Traded	% of Orders Made	% of Passive Orders	% of Aggressive Orders	% of Direct Orders	Avg. less than 1 trade per business day?
PEEL HUNT LTD	35.25%	16.38%	n/a	n/a	0	No
PERSHING SECS. LTD.	14.24%	4.46%	n/a	n/a	0	No
WINTERFLOOD SECS LTD	12.99%	21.26%	n/a	n/a	0	No
STIFEL NICOLAUS BANK	12.27%	14.49%	n/a	n/a	0	No
INVESTEC BANK UK	6.87%	10.24%	n/a	n/a	0	No

 

Unit Trusts

Counterparty	% of Value Traded	% of Orders Made	% of Passive Orders	% of Aggressive Orders	% of Direct Orders	Avg. less than 1 trade per business day?
COFUNDS TRADING	75.67%	81.90%	n/a	n/a	0	No
MEESPIERSON ICS LTD.	2.53%	2.56%	n/a	n/a	0	No
LEGAL & GENERAL U.T.	1.82%	2.97%	n/a	n/a	0	No
COMMERZ BANK AG	1.39%	1.69%	n/a	n/a	0	No
PEEL HUNT LTD	1.34%	0.83%	n/a	n/a	0	No

 

Other Instruments

Counterparty	% of Value Traded	% of Orders Made	% of Passive Orders	% of Aggressive Orders	% of Direct Orders	Avg. less than 1 trade per business day?
SANTANDER INVESTMENT	29.47%	1.96%	n/a	n/a	0	Yes
AXIOM INVEST MANAGM	12.13%	2.94%	n/a	n/a	0	Yes
NORTHERN TRUST	6.98%	1.96%	n/a	n/a	0	Yes
SINGER CAPITAL	4.88%	0.98%	n/a	n/a	0	Yes
THE SHARE CENTRE LTD	2.18%	1.96%	n/a	n/a	0	Yes

 

Securitised Derivatives 

Counterparty	% of Value Traded	% of Orders Made	% of Passive Orders	% of Aggressive Orders	% of Direct Orders	Avg. less than 1 trade per business day?
PEEL HUNT LTD	93.79%	80.00%	n/a	n/a	0	Yes
PERSHING SECS. LTD.	6.21%	20.00%	n/a	n/a	0	Yes

 

Structured Product

Counterparty	% of Value Traded	% of Orders Made	% of Passive Orders	% of Aggressive Orders	% of Direct Orders	Avg. less than 1 trade per business day?
PERSHING SECS. LTD.	99.86%	94.12%	n/a	n/a	0	Yes
SG OPTIONS EUROPE	0.14%	5.88%	n/a	n/a	0	Yes

 

NB. In last year’s report, we disclosed a split of trades between those classified as Passive (defined as those providing liquidity to the market, that is, within the prevailing spread) and those as Aggressive (defined as those taking liquidity from the market, outside the spread).  Our revised reading of the regulatory requirements for our particular trading model, where we trade primarily through intermediaries or on quote-driven systems, indicates that this is not a requirement and we have therefore discontinued this practice.

 

 

 

 

2019 Order Execution Performance Commentary

 

Fixed Income

Due to the variation in liquidity across fixed income instruments it is sometimes necessary in the illiquid markets to place the highest priority on likelihood of execution. It would not be appropriate to determine that this comes at the expense of price as price discovery is imperfect which naturally limits availability. Within the fixed income space execution costs are almost entirely standardised and so that is unlikely to be considered high priority. The top five execution venues utilised by Rowan Dartington for fixed income instruments are all firms with broad bond coverage, providing liquidity through a request for quote (RFQ) process.

 

Equities

The prominence placed on each of the execution factors within our dealing process will vary depending upon a number of criteria, mainly:

1. The characteristics of financial instruments that are the subject of that order;
2. Either, the investment strategy being implemented by the investment manager who created the order, or the details of the order provided by you as the client; and
3. The characteristics of the execution venues to which that order can be directed

 

Every client order executed by our traders is characteristically unique and conditions within the markets we execute through are constantly changing. The relative importance of the execution factors is therefore variable. The most important factors for cash equities are price, cost and speed/likelihood of execution according to the investment manager’s intent and/or the liquidity of the instrument. We therefore monitor against the overall consideration paid for the equity instrument in order to assess the quality of our executions.

 

Our selection of execution venues utilised was made in accordance with the factors described above.

 

Unit Trusts

Rowan Dartington primarily placed reliance on the services of Aegon (CoFunds) in order to execute orders in Unit Trusts placed on your behalf. Due to the nature of the instrument and its characteristics, we do not consider this would disadvantage clients as we are only able to execute the trade at the usual daily valuation point. It would therefore be inappropriate to consider that this comes at the expense of price as all Unit Trust executions are dealt at one daily valuation point. We therefore consider that the timeliness of execution is the primary factor to be considered when considering the quality of execution for Unit Trusts.

 

Other Instruments

Included within the data would be non-EU Equities which are not characterised by ESMA’s liquidity tick bands. The relative importance of each of the execution factors within our dealing process will vary depending upon a number of criteria, namely:

1. The characteristics of financial instruments that are the subject of that order;
2. Either, the investment strategy being implemented by the investment manager who created the order, or the details of the order provided by you as the client; and
3. The characteristics of the execution venues to which that order can be directed

 

Every client order executed by our traders is characteristically unique and conditions within the markets we execute through are constantly changing. The relative importance of the execution factors is therefore variable. The most important factors for cash equities are price, cost and speed/likelihood of execution according to the in-vestment manager’s intent and/or the liquidity of the instrument.

 

It is possible that due to the nature of instruments which would be classified within this category, markets dictate that there may be only one execution venue in order to complete the order. Outside of this, the selection of the Counterparty was made in accordance with the factors described above.

 

Securitised Derivatives

The relative importance of each of the execution factors within our dealing process will vary depending upon a number of criteria, namely:

1. Either, the investment strategy being implemented by the investment manager who created the order, or the details of the order provided by you as the client
2. The characteristics of financial instruments that are the subject of that order; and
3. The characteristics of the execution venues to which that order can be directed

 

Each client order that is transacted by our traders is inherently unique in its characteristics and market conditions are never constant. The relative importance of the execution factors is therefore variable.

 

Each Order is handled on its own merit and transacted in line with our Best Execution Policy.

 

Structured Deposits

Due to the nature of the instrument, Rowan Dartington placed reliance on the provider of the Structured Product for execution where no other execution venue could be utilised.

 

Glossary

 

Instrument classification – the type of instrument as classified by ESMA/FCA.

 

% of Value Traded – the percentage split of all trades completed in that asset class during the reporting period (2018).

 

% of Orders Made – the percentage split of all client orders by the total number of orders executed during the period, in the specified asset classed.

 

% of Passive Orders – where liquidity is provided to the market, i.e. where a bid price is achieved below the offer (purchase) price (within the spread) for a purchase, or an offer below the bid (sale) price for a sale.

 

% of Aggressive Orders – where liquidity is taken from the market, i.e. where a bid price is achieved above the offer price (outside spread) for a purchase or an offer below the bid price for a sale.

 

% of Directed Orders – percentage split of orders that were directed to a specific market maker upon request of the client.

 

 

 

2. MANAGEMENT OF CONFLICTS OF INTEREST 

 

What are conflicts of interest?

A conflict occurs where:

• our (or any subsidiary /representatives of Rowan Dartington)  interests conflict with the duty owed to you; or

•  where our duties to another client conflicts with our duty to you

In accordance with the requirements of the FCA (our regulator) we aim to treat you fairly by implementing adequate systems and controls to identify, monitor and manage these risks or any potential risks.

As the fair treatment of our clients is paramount to the ethical standard of Rowan Dartington it is incumbent on our Board and staff to consider and escalate any matter that they consider may conflict with our policies. The Risk Committee will review any new conflicts that have been identified.  

About us

Rowan Dartington provide Wealth Management Services, including investment advice and management as well as dealing and custodian services.  We are part of the St. James’s Place Wealth Management Group.

We have an Independent Financial Adviser (Stafford House Investments) who provide financial planning advice on an independent basis.   A C Mole is also independent financial planning advisers, who are a trading name of Stafford House Investments.  The advice these companies provide may or may not involve referring clients to Rowan Dartington.

Purpose of this information

To explain to you what policies we have in place to manage conflicts and highlight what principle conflicts exist and what is in place to mitigate them.  Should you wish to discuss anything further, please contact your Investment Manager.

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 Inventory

Principal Conflicts	Management Arrangements
Conflict Risk	What we do
Suitability i.e. Staff recommend services or transactions which are not appropriate for the client	We have a robust training programme in place for our advice processes to ensure that our Investment Managers and Advisers provide appropriate advice.  Our monitoring programme provides a control mechanism to ensure processes are being consistently deployed and advice is suitable.   There are internal policies in place to deal with scenario’s that may cause conflict in advice processes, such as; Commissions receive from third parties; Staff having power of authority over an account i.e. Trustee, Executor, Director or Power of Attorney; Interest payments All staff are expected to disclose outside business interested.
Dealing and Trading i.e. our staff may delay investments	We have a best execution policy which Investment Managers and Financial Advisers are expected to adhere to ensure that we act in your best interest. Rowan Dartington have a transactional monitoring programme to review trades which have been completed to ensure best execution principles have been achieved.
Aggregation of orders i.e. one client may be treated more favourably than an other	To mitigate this we may combine one client’s orders with another clients order.   The intention is to ensure fairness to all clients when placing particular trades, particularly for discretionary clients.  This could result in a less favourable price or increased trading costs. When undertaking trades of this nature we will ensure our clients best interests are considered.
Placings and new issues i.e. one client may be treated more favourably than an other	Where we agree to take part in a new issue or placing, we will do this in combination with other client orders.  If the allocation is scaled back it will be applied pro rata across all participating clients. Sometimes staff may take part in these trades also. Where they do and where the allocation is scaled back, we will scale back staff orders before applying any scaling to our clients.
Personal Account (staff) Dealing (PA) i.e. Staff may deal on their own account ahead of clients and obtain better prices	All staff and connected parties are expected to comply with our Personal Account Dealing policy.  This requires staff to obtain prior approval for trading. The prior approval means that checks can be made to ensure that staff do not; Trade ahead of clients Trade ahead of any public announcements about the stock being traded
Staff remuneration i.e. bonus and salary structures may entice staff to act inappropriately when managing client assets	We aim through our remuneration package to consider the long-term interests of our staff.  These are designed to correlate with the interests and financial wellbeing of our clients, so to discourage inappropriate behaviour or excessive trading.  Therefore, activities are overseen and monitored.
Gifts and Hospitality (Inducements) i.e. The integrity of either staff or suppliers is compromised by excessive inducements.	We have enforced internal policies, through training and monitoring, to ensure that gifts or hospitality received from or provided to clients, supplier, company and other are not excessive. Staff are required to disclose where they receive or give gifts or hospitality when they are over a notional value.  Where the triggers are met pre-approval will be required, via our Compliance and Risk Department, to accept or provide a benefit like this. In all cases, there needs to be a business motive for the gift or hospitality which aim is to enhance the quality of service we provide to you. We also maintain a register or gifts and hospitality received or provided which is overseen by the Compliance and Risk Department.
Research i.e. our research team may be un-duly influenced to place stock or funds on to our core lists	Our research team are independent from other teams in the business.  The remuneration package for these staff is designed not to influence their decision making process. Any additions or deletions from the core list are discussed at either the Asset Allocation Committee or Investment Management Committee before the changes are made to the core list.  This information will not be disclosed to staff ahead of formal announcement of the core stock list changes.

Disclosure

If we are unable to manage a conflict, or where we believe our measures and controls are not sufficient to protect your interest we will disclose the conflict to you.  The aim of this is to allow you to make up your own mind as to whether to continue our business relationship with regard to the service or advice we provide you.

 

3. COMPLAINTS POLICY 

Procedures

We are sorry you have cause to complain to Rowan Dartington.

Our aim is to resolve any client concerns fairly, effectively and promptly.

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 leaving clients and potential clients dissatisfied.

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. Consumers will also be able to tell us at any point that they don’t want to take their complaint any further.

Where possible, please include the following details with your complaint:

• Your full name, address, account reference and your telephone number to contact you on;
• A full description of your complaint and any details you can provide on what you feel would be appropriate in order to resolve your complaint, and;
• Any relevant documentation you wish us to consider as part of the complaint investigation

If complaining on behalf of another person, you must be authorised to do so and we reserve the right to contact the individual who you are complaining on behalf of to confirm.

How to make a complaint

You can refer your complaint to Rowan Dartington via any form of communication, but where possible, please use the following contact details:

Address: Complaints Team, Rowan Dartington, Temple Point, Redcliffe Way, Bristol, BS1 6NL

Email: complaints@rowan-dartington.co.uk

Telephone: 0117 933 0050

Expressions of Dissatisfaction

Where possible, we will look to resolve the issue by close of business 3 days after receipt of your complaint and we will write out to you confirming resolution. You still have the right to refer your complaint to the Financial Ombudsman Service (details below) and/or the alternative dispute resolution (ADR) service should you not be happy with the outcome.

Acknowledgment of Complaints

Where it is not possible to resolve the issue within 3 business days, our Complaints department will complete an investigation.

If this applies, we aim to issue an acknowledgement to you within 5 business days, detailing our understanding of your concerns and confirming the next steps.

Complaint Resolution

We will collate all the documentary evidence relevant to your complaint and, where applicable, ask for the comments of any individual involved. It may also be necessary for us to contact third parties for information. 

During the investigation

Once we have done this, we will review the evidence, make our assessment and let you know the outcome of our investigation in writing.

• If we are unable to resolve your complaint within 4 weeks of receipt we will send you a letter explaining why we need more time to complete our investigation and let you know when to expect our response.
• If our investigation is going to take longer than 8 weeks, we will write to you again to explain why and let you know when we expect to be able to conclude matters. This letter will also inform you of your right to refer your complaint to the Financial Ombudsman Service (see ‘Your Rights’ below), if applicable.

At the end of the investigation

When we have finished our investigation we will write to you with our full response to the concerns you raised.

Our final response will set out;

• the facts which have been established during the investigation; and
• any resolution to be offered.

This resolution will consider;

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

Your Rights

If you are not completely happy with the outcome and resolution of your compliant, you have additional rights to independent review or assistance.  These additional rights are set out below:

Financial Ombudsmen Service

You have the right to refer a complaint directly to the Financial Ombudsman Service if we have had an opportunity to consider it and have either:

• Supplied you with a final response; or
• 8 weeks have elapsed since we have received your complaint and a final response has not been issued.

More information on the Financial Ombudsmen Service can be found here: http://www.financial-ombudsman.org.uk or you can contact them using the below details:

Address: The Financial Ombudsman Service, Exchange Tower, London, E14 9SR

Email: complaint.info@financial-ombudsman.org.uk

Telephone (from within the UK): 0800 023 4567

Telephone (from outside the UK): +44207 964 0500

We will also issue you with a leaflet providing these details with our formal responses to your complaint.

Time limits for referral to the Ombudsman

In line with current rules, you will have six months from the date of our final reply to refer your complaint to the Financial Ombudsman Service if you remain unhappy with our response.

The Financial Ombudsman Service might not be able to consider your complaint if:

• What you are complaining about happened more than 6 years ago; and
• You are complaining more than three years after you realised (or should have realised) there was a problem.

If you do not refer your complaint in time, the Ombudsman will not have our permission to consider your complaint and will only be able to do so in very limited circumstances.  For example, if the Ombudsman believes that the delay was as a result of exceptional circumstances.

Alternative 

If you remain unhappy and do not agree with the Financial Ombudsman’s final decision, you are able to:

• Utilise an alternative dispute resolution (ADR) entity (this gives you access to an independent professional to review or assist with your complaint); or 
• Potentially able to take civil action.

More information on ADR can be found on the Citizens Advice website:

www.citizensadvice.org.uk

 

4. 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.

 

Rate change with effect from 1 July 2017

With effect from 1 July 2017, the rate of interest paid by Rowan Dartington on any cash balances held reduced to nil.

 

5. INVESTEE ENGAGEMENT POLICY