Treating customers fairly policy
Aequitas Wealth Management Ltd (Aequitas) does not deal with retail clients directly but nevertheless aims to treat all of our customers fairly and this document is intended to provide a detailed understanding of what this means and the method used to achieve it. If you feel at any point that you have not been treated fairly for any reason by Aequitas, please contact us with the details and we will address your concerns.
The 11 Cornerstone Principles of the regulator in the UK (the Financial Conduct Authority (FCA) which authorises and regulates Aequitas) cover this point in Principle 6 which states ‘a firm must pay due regard to the interests of its customers and treat them fairly’.
Treating customers fairly is an expectation which reaches into every aspect of your relationship with us. This includes, but is not limited to, the outcomes listed below.
You can be confident that you are dealing with a firm where the fair treatment of customers is central to our corporate culture
Our products and services are marketed directly to you or via an intermediary with care taken that they are suitable for your needs and objectives
You are provided with clear information and are kept appropriately informed before, during and after the point of sale.
If you receive advice from us, the advice is suitable and takes account of your circumstances
You are provided with products that perform as we have led you to expect, and the associated service is both of an acceptable standard and as you have been led to expect
You do not face unreasonable post-sale barriers imposed by us to change product, switch provider, submit a claim or make a complaint
All members of staff are actively incentivised to bring any example where a procedure may not have resulted in a customer being treated fairly to the attention of senior management. Any incidents will be investigated thoroughly, and corrective action taken if appropriate.
The directors will consider the principle of treating customers fairly at each board meeting and look at complaints, identified rule breaches and any other information which they feel important to monitoring the outcomes of our clients.
Aequitas has given detailed consideration to how a TCF philosophy is delivered.
In addition to the TCF outcomes listed above there are other FCA principles which interact with TCF considerations.
Principle 1: A firm must conduct its business with integrity
Principle 2: A firm must conduct its business with due skill, care and diligence
Principle 3: A firm must take reasonable care to organise and conduct its affairs responsibly and effectively with adequate risk management systems
Principle 7: A firm must pay due regard to the information needs of its clients, and communicate information to them in a way that is clear, fair and not misleading
Principle 8: A firm must manage conflicts of interests fairly, both between itself and its customers and between a customer and another client
Principle 9: A firm must take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgement
The most important aspect to TCF is the culture within the company and the board of directors are committed to providing positive client outcomes, identifying where this is not achieved and taking appropriate remedial action.
All members of staff are positively encouraged to identify errors of their own making or their colleagues so that corrective action can be taken.
A log of errors and breaches is maintained and reviewed by compliance and at board level on a regular basis so that trends or individual instances that require investigation can be identified.
The performance of the Aequitas funds are regularly reviewed and measured against expected outcomes.
All complaints are recorded and dealt with by senior members of staff. All complaints are reported to the board of directors for further discussion if required.
All financial promotions are considered carefully against a checklist of requirements to ensure that they are accurate and provide consumers with information which is fair.
All members of staff are provided with computer-based training in respect of TCF requirements.
TCF considerations are identified by management in response to any significant business change.