All the extra things you should know.
Definitions and interpretations
The following definitions and interpretations shall be considered in the context of this document:
Client, Customer, You: Means any person holding an account with us.
Complaint: As defined on the FCA Handbook, means any oral or written expression of dissatisfaction, whether justified or not, from or on behalf of a person, about the provision of, or failure to provide, a financial service or a redress determination, which: 1. Alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and 2. Relates to an activity of that respondent, or of any other respondent with whom the company has some connection in marketing or providing financial services or products, which comes under the jurisdiction of the Financial Ombudsman Service.
FCA: Means the Financial Conduct Authority
FOS: Means the Financial Ombudsman Service
Us, We, The Company: Means MFM Investment Ltd, trading as MoneyFarm.
Summary of the Complaints Handling Procedure
- All complaints shall be addressed, in first instance, to the Client Relationship Management team using the contact details provided at the bottom of this document. They will deal with your complaint diligently and seek to provide an immediate resolution, no later than 3 business days after the date of your complaint.
- If your complaint cannot be dealt within 3 business days, we will send you an acknowledgement of receipt and your complaint will be dealt by the Compliance Team. We will seek to provide you with a final response within 8 weeks from the date of your complaint.
- If we cannot provide you with a final response by the 8th week from the date of your complaint, we will write to you explaining the reasons, and we will include an estimation of when we will be able to provide you with the final response.
- If more than 8 weeks have passed from the date of your complaint without us having provided you with a final response, or you remain dissatisfied with the response we will have provided you, you are entitled to refer your complaint, free of charge, to the FOS by following the steps outlined on their website at http://www.financial-ombudsman.org.uk/consumer/complaints.htm
- Upon resolution of your complaint, we will provide you with a Summary Resolution Communication in accordance with the FCA rules.
Treating Customers Fairly
Both the Client Relationship Management Team and the Compliance Team shall thoroughly examine any complaint and the relevant associated information as required to reach a fair outcome for the client, and communicate with the client in a fair and respectful manner at all times.
Treating Customers Fairly
Client Relationship Management Team: email@example.com
Compliance Team: firstname.lastname@example.org
From the UK: 0800 4334574
From abroad: +44 (0) 203 7456990
WARNING: Any specific instructions from a client may prevent us from taking the steps set out below that we have designed and implemented to obtain the best possible result for a client.
1. TREATING CUSTOMERS FAIRLY
We are dedicated to treating our clients fairly, which includes, amongst other aspects, ensuring we have and follow adequate policies and procedures to achieve Best Execution for our clients.
2. BEST EXECUTION
When executing orders for clients, we are required by the FCA’s rules relating to best execution, to take all reasonable steps to obtain the best possible result for our clients, taking into account the following execution factors: the (i) price, (ii) costs, (iii) speed, (iv) likelihood of execution and settlement, (v) size, (vi) nature or (vi) any other consideration relevant to the execution of an order.
For the purposes of delivering best execution for our retail clients in circumstances where there is more than one competing venue to execute an order, in order to assess and compare the results for the client that would be achieved by executing the order on each of the execution venues that is capable of executing that order, our own commissions and costs for executing the order on each of the eligible execution venues will be taken into account.
Our obligation to deliver best execution for a retail client where there are competing execution venues is not intended to require us to compare the results that would be achieved for our client with results that might be achieved for the same client by any other firm, on the basis of a different execution policy. Nor are we required to compare the differences between our commissions which are attributable to differences in the nature of the services we provide to clients.
We have developed this policy and procedures with our execution venues to both achieve and record that each order that has been fulfilled in accordance with the FCA’s rules relating to best execution.
This policy, and our supplementary procedures relating to the policy, will be reviewed periodically and in any event at least on an annual basis.
We will monitor the effectiveness of our best execution arrangements on a regular basis in order to identify and, where appropriate, correct any deficiencies. We will review our order execution arrangements and the contents of this policy on an annual basis.
We will notify clients of any material changes to our order execution arrangements or best execution policy.
Relevant factors will be considered by our execution venue to achieve the best execution possible for clients, including stock liquidity, ability to deal on more than one market trading system choices and any specific conditions attached to the order by the client. If these factors and any other pertinent information are duly considered, we anticipate best execution will be attained for the client. We will inform the client if any particular bargain conditions are attached which may restrict the achievement of our best execution obligations.
The principles of best execution apply equally to single orders or orders which are aggregated.
3. ORDER HANDLING
When handling orders on behalf of clients, we will take the following steps in order to comply with the FCA rules relating to order handling: (a) we will promptly and accurately record and allocate orders executed on behalf of clients; and (b) we will carry out comparable client orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable or the interests of the clients require otherwise.
We transmit client orders to our counterparties on a ‘first come, first served’ basis. In general, we aim to keep the time for the handling of orders to a minimum. After checking orders for consistency, orders are placed at a selected counterparty. We will monitor this dealing process.
We will notify clients of any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty.
We will always aggregate orders so that we ensure the same outcome for each instrument. It is unlikely that the aggregation of orders and transactions will work to the disadvantage of any client, given that we do not take orders directly from the client, but rather we execute orders on a discretionary basis.
Aggregated orders have significant benefits for the client, the main benefit being the lower cost. When aggregating orders we will make sure that: (a) they are initiated with the same set of execution instructions; (b) if they are initiated on the same day and; (c) if they will follow exactly the same order chain (e.g. same custodian). [If an aggregated order is partially executed, the order will be settled for the different clients on a pro rata basis, according to the contribution made to the aggregated order. Our order management system is specifically designed to permit only pro rata allocation whenever an aggregated order is partially executed.
The Company does not execute any orders for its own account.
Eligible investments include:
(a) Exchange Traded Funds (ETFs): orders may be transacted via electronic order books, retail service providers, agency crosses, direct telephone engagement and electronic algorithmic systems;
(b) Exchange Traded Commodities (ETCs): orders may be transacted via electronic order books, retail service providers, agency crosses, direct telephone engagement and electronic algorithmic systems.
5. EXECUTION VENUES
We select our counterparties with skill, care and diligence to ensure that they also meet the FCA rules on Best Execution, and we review our relationships with our counterparties on an annual basis.
We do not operate via Direct Market Access (DMA). Instead, we execute orders via Saxo Capital Markets Limited UK, an FCA regulated institution of sufficient reputation that provides us with a full solution from order routing to clearing, settlement and custody services, this translates into cost efficiency for both MoneyFarm and our clients.
Should you wish to know more, please contact us via e-mail at email@example.com or via phone on 0800 433 4574 (from the UK) / +44 (0) 203 745 6990 (from abroad).
We are committed to taking measures to recognise, supervise, examine and resolve conflicts of interest. We recognise that it is not possible to eliminate all sources of conflict of interest; however, safeguarding clients’ welfare remains our primary objective. This policy encompasses the relationships with clients and third party contacts.
We define a conflict of interest as being either:
(a) between us and you as a client; or
(b) between yourself and another client where your interests are materially affected.
We have identified areas where a conflict of interest may arise. They include, but are not limited to:
(a) services in different capacities at the same time;
(b) providing advice or management;
(c) acting for more than one client in a transaction;
(d) holding information on other clients that would affect you or them if it is disclosed;
(e) receiving gifts or entertainment which could conflict with our duties to you;
(f) employees pursuing activities or personal relationships potentially detrimental to you; and
(g) personal account holdings in companies or other investments being recommended by us.
Our protocols are noted below and we consider them satisfactory to allow us to act without bias to prohibit damage to your interests. At all times stringent criteria to address and resolve conflicts is followed. Protocols have been developed and introduced to manage conflicts of interest. Our employees are provided with relevant training about the protocols and standards of conduct expected thereafter. Our management remains responsible for ensuring the protocols and resources are sufficient to identify and attend to a conflict as it may arise.
We maintain an internal log of conflicts that arise, listing how each conflict was monitored and any solution which was developed and applied to resolve the problem and to prevent the client’s interests from being disadvantaged. The effectiveness of our protocols is assessed by internal audit staff members who execute their duties in a wholly independent capacity.
We have in place protocols to prevent unauthorised access or inappropriate dissemination of information.
Where our functions could create an internal conflict our duty lines are kept separate and individual management and reporting structures are established. The operations functions are maintained and conducted separately from the front office functions and in both an appropriate level of qualification, expertise and supervision is applied.
Staff remuneration is by means of a basic salary which is not linked to the underlying performance of the company. A remuneration committee agrees and monitors awards to achieve consistency and equitability and does not lead to conditions which may foster conflict.
Inducements from third parties are acceptable with respect to a service we provide to you if it is disclosed to you and if it is the payment of a normal fee.
Personal account dealing rules are in place for all staff.
A register of all gifts to staff and valued in excess of £150 is maintained and approved by a senior manager.
Where we are unable to resolve a conflict of interest we will notify you formally in writing. This disclosure will permit you to evaluate whether it is appropriate to continue using our services in respect of the pertinent conflict.
Where we have examined the conflict of interest and its cause it may inform you of its decision not to act on your behalf if it determines no other course of action is possible.