CLIENT AGREEMENT – About Us and How We Work with You

St Georges Financial Services Ltd is authorised and regulated by the Financial Conduct Authority. FCA Number 516577.  You can check this on the FCA’s Register by visiting the website https://register.fca.org.uk/ or by contacting the FCA on 0800 111 6768.

Investment

St Georges Financial Services Ltd classifies all clients as ‘retail clients’ for investment business, which means you are afforded all protections under the rules of the Financial Conduct Authority.

Should you wish to be classified differently for investment business, please discuss this with your adviser. Please note that should you wish to be considered as a different category of customer for investment business, such as a professional client or eligible counterparty you must inform us in writing. We will provide you with a new client agreement and you may lose a number of protections which will be outlined in that new agreement.

Non – investment and general insurance

St Georges Financial Services Ltd classifies all clients as ‘consumers’ for non-investment insurance business, which means you are afforded all protections under the rules of the Financial Conduct Authority.

Should we need to classify you differently we will discuss this with you, however, you should aware that you may lose a number of regulatory protections which will be outlined in a revised agreement.

Prior to providing you with any advice we will take time to understand your current needs, circumstances and attitude to risk (where applicable). Any advice provided will be confirmed to you in writing.

St Georges Financial Services Ltd takes all our regulatory responsibilities very seriously and we ensure that all our staff are required to demonstrate their competence to undertake their role and our business is structured in a manner that is designed to meet in full all the requirements set by our regulator, the Financial Conduct Authority, and under European Securities and Market Authority rules.

Unless you advise us otherwise, we will communicate with you via the following methods of communication, Face to Face, E-mail, Telephone, Letter & Fax.

Please note that all our communications and documents will be provided to you in English

St Georges Financial Services Ltd does not handle clients’ money.  We never accept a cheque made out to us (unless it is a cheque in settlement of charges or disbursements for which we have sent you an invoice) or handle cash.

We may receive a fee for making introductions to third party product or service providers. Should we receive a fee we will confirm in writing to you what that fee will be.

When acting as an introducer, marketer or promoter of a scheme, no responsibility is accepted for any matters arising from the referral to the scheme product provider. It is your responsibility to ensure that you enter into separate Terms & Conditions with the third-party advisor.

For details of our Data Protection policy, please see our Data Protection Notice, which will be provided separately to you.

St Georges Financial Services Ltd is permitted to advise on and arrange (bring about) deals in investment contracts.

Transactional Only – with regard to investments contracts which we have arranged for you, these will not be kept under review unless we agree otherwise with you; but we will advise you upon your request.

With Service Provision – we will provide services to you as more fully outlined in our ‘Service Levels, Initial Fees & Ongoing Payment of Services’ section to the rear of this document.

Investment & Pensions – Restricted Advice

We are restricted in the advice that we may offer you, as we explain below;

Having examined our firm’s clientele, we have chosen to restrict our advice to exclude advice in the following retail investment product areas as we do not feel they are suitable for the type of clients we deal with;

Unregulated Collective Investments (also known as Non-Mainstream Investment Products NMPI) / Venture Capital Trusts/ Enterprise Investment Schemes/ Exchange Traded Funds/ Structured Capital at Risk Products.

We offer both a Bespoke investment research process and a Centralised Investment Proposition that includes a range of model portfolios available via the Paradigm Nucleus Wrap Platform.

In addition, with regards to our Centralised Investment Proposition, we utilise the services of Tatton Investment Management, an investment firm who specialise in researching and managing investment products and allowing us to offer you a discretionary management service, where we believe this most suits your needs.  The Portfolios offered are available from the Paradigm Nucleus Platform.

IMPORTANT INFORMATION ABOUT ST GEORGES FINANCIAL SERVICES LTD & TATTON ASSET MANAGEMENT PLC (“TAM”)

If we think that it would be in your interests, we will:

• Invest, or recommend that you invest, in the products manufactured by Tatton Investment Management Ltd, Tatton Onshore Tax Strategies Ltd, Tatton Oak Ltd, Paradigm Partners Ltd and any other firm that TAM may acquire in the future that offers relevant products and/or services.

• Use, or recommend that you use, the services of Tatton Investment Management Ltd, Tatton Onshore Tax Strategies Ltd, Tatton Oak Ltd, Paradigm Partners Ltd and any other firm that TAM may acquire in the future that offers relevant products and/or services.

Tatton Investment Management Ltd, Tatton Onshore Tax Strategies Ltd, Tatton Oak Ltd, Paradigm Partners Ltd (the “Companies”) are wholly owned subsidiaries of TAM.

In the interests of full disclosure, the Directors of St Georges Financial Services Ltd currently hold Ordinary Shares in TAM (amongst other investments) via their pension arrangements and these pensions may receive dividend payments each year. The value of these shares and any dividends the pension may receive depends, at least in part, on how profitable the Companies are, and how profitable they are expected to be.  Please note however that the volume of these holdings are considered to be a minority shareholding.

We have systems and controls in place to make sure that our shares in TAM do not create any possible disadvantage for you.

We have a legal and regulatory obligation to take all appropriate steps to identify and to prevent or manage conflicts of interest from arising.  In the event of any of our business interests or activities creating a potential conflict of interest we will ensure that we take all appropriate steps to manage the potential conflict by maintaining robust systems, controls and staff training.  In the unlikely event that we are unable to prevent the potential conflict, we will fully disclose to you, the general nature and/or sources of conflicts of interest and the steps taken to mitigate those risks.  Further details of our conflict of interest policy are available upon request.

It is our policy to transact your business in order to achieve the best possible results in terms of the:

• Price of products, providers and services
• Cost of advice
• Speed
• Size and Nature of the transaction

• Effectiveness of the Platform/ Provider/ Service Provider

We will not receive any financial inducement or gift that will in any way compromise our ability to provide you with suitable advice.

We advise on a range of products from a variety of firms; on occasion, some of these firms may provide us with training, which allows us to offer you a better service. Further information regarding these arrangements is available on request.

St Georges Financial Services Ltd is permitted to advise on and arrange (bring about) deals in non-investment and General insurance contracts.  We are an insurance intermediary and act on behalf of our clients and not insurers.

We offer a personal recommendation for products from a range of insurers on the basis of a fair analysis of the market, for example; for Term Assurance, Critical Illness and Income Protection Policies.

We will advise and make a personal recommendation for you after we have assessed your needs.

Usually we will be paid commission by the provider. However, should this fall below our minimum £800 adviser remuneration, an additional fee will be payable.  We will provide details of the total remuneration payable, including any fees, commissions, charges, expenses and benefits to you in our fee agreement / client engagement letter.

You will also receive a Client Specific Illustration which will detail any other fees relating to your particular insurance policy.

We will forward to you any documents we receive in relation to business transacted as soon as practicable; where a number of documents relating to a series of transactions is involved, we will normally hold each document until the series is complete and then forward them to you.

If you wish to register a complaint, please contact us in writing at address at the front of this agreement or telephone us on 01425 653654

If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service. http://www.financial-ombudsman.org.uk.

We have briefly set out some information about the Financial Services Compensation Scheme (FSCS) below. If you would like further information about compensation scheme arrangements, details are available at www.fscs.org.uk or call 0800 678 1100.

Most of the products we advise on are covered by the Financial Services Compensation Scheme (FSCS). You may be entitled to compensation from the scheme if product providers or we cannot meet our obligations. This depends on the type of business and the circumstances of the claim.

The actual level of compensation you receive will depend on the basis of your claim. The FSCS only pays compensation for financial loss. Compensation limits are per person per firm, and per claim category (listed below).

Investment

Most types of investment business are covered for 100% of the first £85,000 per person per firm, so the maximum compensation is £85,000 per person per firm.

Deposits

Money in accounts like current and savings accounts, including cash Individual Savings Accounts (ISAs) are covered up to £85,000 per authorised firm (£170,000 for a joint account). It should be noted that ‘authorised firms may have different brands.  The FSCS will provide a £1million protection limit for temporary high balances held with your bank, building society or credit union if it fails.  A temporary high balance would apply when payments have been received in respect of specified life events, details of which can be obtained from FSCS.

Protection, non-Investment Insurance mediation.

Protection is at 100%, where:

(1) The claim is in respect of a liability subject to compulsory insurance:

(2) The claim is in respect of:

• A relevant omission; and
• A professional indemnity insurance contract, or would be in respect of a professional indemnity insurance contract if the insurance contract had been effected:

(3) The claim is:

• In respect of a relevant omission;
• In respect of a relevant general insurance contract or would be in respect of a relevant general insurance contract if the insurance contract had been effected; and
• Arises from the death or incapacity of the policyholder owing to injury, sickness or infirmity:

(4) The claim is in respect of:

• A relevant omission; and
• A pure protection contract, or would be in respect of a pure protection contract if the insurance contract had been effected

(5) In all other cases: 90% of claim

Before making any recommendation, we will make suitability checks to ascertain your relevant knowledge, experience, objectives, financial situation and your ability to bear losses.

Prior to any transaction we will provide you with a suitability report outlining any recommendations we have made including the selling, holding or buying of investments.

To ensure that you are always fully aware of our advice & transaction costs as well as how and when you are going to be asked to pay for this, we will always confirm this verbally and in writing asking for your consent by signing a Client Engagement & Fee Agreement letter (in which we will confirm the exact amount and your preferred payment method.

Generally, we will ask you to pay for our services at the end of the advice process and we will confirm this to you in the Client Engagement & Fee Agreement letter

What You Can Expect from Us

We will provide with the following service, the cost of which is covered by our Initial Advice & implementation fee.

• Listen to your objectives, plans and timescales for your planning needs.
• Provide a full explanation of our company, how we work and a written explanation of the services that our company offers, so that you will fully understand the level of services and advice you can expect from us
• Provide the option of a ‘Full Financial Review’ or ‘Focused Advise’ in order to understand and agree with you; your needs and objectives based on a comprehensive review of your current financial position.
• Complete a detailed risk analysis assessment to fully understand your tolerance to risk and capacity for loss.
• Research the marketplace to ensure the most appropriate provider/solution is recommended
• All our advice will be confirmed in writing
• We will aid you in the completion of any documentation and forward any policy documents(s) to you as required.

Full Financial Review or Focused Advice

The more time we spend researching & documenting information the more expensive it can become. This can be deemed to be unsuitable where you are merely seeking advice on a specific area or for a smaller investment.

As an alternative to a Full Financial Review, you can request focused advice where we will obtain limited information from you in order to concentrate on a specific area of financial planning need, you should however be aware that the advice you receive may be different from advice given using the Full Financial Review approach.

St Georges Financial Services offer 2 types of Initial service: Transactional Service, or Initial Advice & Ongoing Service

We will agree with you which level of service is most appropriate to meet your needs and we will confirm this in our ‘Client Engagement & Fee Agreement’ letter.

For Transaction Only Service clients:

• The above process is undertaken, but your arrangements will not be kept under review, and we will not provide any ongoing advice. This service is suitable for clients that simply wish us to ‘set up an arrangement and walk away’ in order that the arrangement can be self-managed.
• Should you select this service, you will receive no ongoing service or reviews, and that as a result the investment funds could suffer ‘Portfolio Drift’ which means that the risk rating of the funds invested may move out of your actual attitude to risk and capacity for loss.

For Initial Advice and Ongoing Service clients:

• The above process will still also form the backbone of any initial advice provision, but will also include ongoing administration, monitoring, and reporting services, to ensure your investment portfolio continues to be optimised & rebalanced on a regular basis (maintaining the agreed risk profile & meeting any change in needs as time passes). Ongoing advice is also usually provided unless specific circumstances dictate the temporary removal of this element.

Initial Advice & Ongoing Service Investment Proposition Options 

We have constructed a ‘Centralised Investment Proposition’ that has been designed over time to meet many of our client’s needs. Often our clients share common characteristics in terms of their Financial circumstances and objectives.

Where our ‘Centralised investment Proposition’ is not going to be suitable to meet your needs, we will look outside of this to our ‘Bespoke Investment Process’ to find a bespoke solution that will.

• ‘Centralised Investment Process‘ – Provides a cost-effective researched platform solution with a range of outsourced, risk rated portfolios. These diversified investments are researched from the whole of investment fund market and are rebalanced and optimised via discretionary investment management on an ongoing basis.  The proposition includes strategic and tactical investment processes, quarterly updates, and online access to account valuations anytime.  Portfolios can be invested across ISA’s Pensions, Bonds and/or General accounts depending upon the individual tax wrapper requirements.  We offer a variety of risk rated portfolios targeting investments that are Active or Passively Managed, Blended Solutions and Ethically Managed.

• ‘Bespoke Investment Process’ – Provides an individually researched investment solution from the whole of market should our Centralised Investment Proposition be unsuitable

Bespoke Services

Bespoke Services are outside of our Centralised Investment & Review Services Programme, and available for those clients who prefer a service completely personalised to their own requirements. The services may include the facilities of a Discretionary Fund Manager, either recommended by St Georges Financial Services Ltd or via an existing arrangement already engaged by the client or via a specific Product Provider.

Payment for Services

St Georges Financial Services Ltd provide an initial meeting to understand in broad terms, your needs and objectives and to agree with you what services are right for you going forward. This meeting usually lasts for around one hour, the cost of which is met by our firm.

Assuming a need is then established, to ensure that you are always fully aware of our advice costs and how and when you are going to be asked to pay for them, we will always confirm this verbally and in writing to you and ask for your consent by the signing of our ‘Client Engagement & Fee Agreement’ letter before proceeding with investment business (or non-investment insurance where a supplementary fee is required).

It is our company policy to offer you a choice on how we are paid any Initial Advice & Implementation Fee on any lump sum investment business.

These fees can be deducted from the amount upon investment or paid directly by the client. Please note if you pay our fee by way of a separate Bacs payment, 100% of the investment amount will be invested.  However, should you subsequently cancel the policy within the statutory cooling off period, we will not refund the fee received.

If we advise you to transfer from one product to another, in order to treat our customers fairly there may be times, where we voluntarily suggest and agree to delay the deduction of our fees for improved tax efficiency e.g. an Income Drawdown. In all cases, we will confirm the timing of any deduction/s for our fees.

Investment & Pensions Lump Sum Investment

Example of our implementation fee as a percentage of the funds invested

Regular Premium Investment Fee

It is our company policy to arrange for the Implementation Fee for regular premium investment business to be paid by way of a direct fee of £1,200.

Transactional Services

Example of our focused advice fees for Existing Transactional clients

1. Where applicable, travel costs are charged at 45p per mile

Please note that the above fees are for guidance only. You may be asked to pay more or less depending on our assessment of the work involved.

Termination of Our Services (Initial Advice)

You or we may terminate our authority to act on your behalf at any time.  You will be liable to pay for any advice or services that you have received prior to the date of termination. This means that where we have agreed the advice and services that we will provide for you and we have agreed to receive payment for these, either by means of a fee for investment business or by receiving commission from a provider for non-investment business you will have to pay us for any work we have completed up to the date of termination.

Once you have decided to implement your Financial Arrangements, it is recommended to benefit from on-going monitoring’ optimisation & review.  Our default ‘Ongoing Advice’ service incorporates a periodic review of your arrangements at least annually and an annual suitability review of any ‘Centralised Investment Proposition’ or ‘Bespoke’ investments arranged.  This is important to ensure your plans remain appropriate and in line with any changing needs as time passes.  However, should a situation arise that prevents us from being able to annually assess and reconfirm suitability, this may result in a temporary adjustment to provide a reduced ‘Ongoing Administration Only’ service which still continues to provide all other features including ongoing monitoring, quarterly updates annual reporting of your investment and periodic ad hoc guidance requests via post, phone or email.

For Clients adopting our Centralised Investment Proposition we have created the following Ongoing Service to assist you towards achieving your identified goals, subject to our minimum annual servicing fees as laid out over the page:

• Ongoing Administration and Document Processing
• Quarterly Portfolio Changes Communication
• Ongoing Postal, Telephone and Email Support
• Ensure daily online valuation access and quarterly updates of your portfolio valuations and progress
• Provide Trust Advice (Where Applicable)
• Referral to other professionals
• Issue of Annual Review to include an examination & assessment of your portfolio, its performance & costs
• Ongoing Investment Advice (Does not apply to the Administration Only Service)
• Assessment of and Confirmation Suitability Statement (Does not apply to the Administration Only Service)
• An offer of one face to face or telephone annual review meeting to cover the following: (Does not apply to the Administration Only Service)
  • Update your standing data (Personal Details only)
  • Identify any changes to your personal circumstances or objectives
  • Establish whether your current insurances and protection cover remains appropriate (if applicable)
  • Identify tax changes that may affect your investments
  • Discuss your investment strategy and ‘Risk Profile’, in line with your current circumstances, investment experience and financial objectives – we will recommend changes where necessary
  • Carry out any retirement planning (if applicable)
  • Examine and make recommendations regarding your estate planning arrangements (please note that the Financial Conduct Authority does not regulate taxation and trust advice).
  • Provide any information required for your accountant or other professionals
  • Confirm ongoing Suitability or recommend amendments where appropriate

Should you have opted for a Bespoke service, once we have agreed the level of service you will receive, we will also aim to outline and confirm this in our ‘Client Engagement & Fee Agreement’ Letter.

Example of ongoing advice & administration only charges

The actual fee charged will vary depending upon how the investment performs and it will increase as the fund grows.

We will provide you with information regarding the costs at least annually to help you understand the overall cost and the cumulative effect on the return of the investment.

Termination of our services (Ongoing Advice & Administration Only)

You, or we, have the right to cancel payment for our ongoing services at any time, we would give you 14 working days’ notice, and upon request, could signpost you to alternative sources of financial advice.  We will terminate any on-going payments to be received from product or service providers at the end of the notice period.

You are asked to give us 14 working days’ notice and we will terminate any on-going payments to be received from product or service providers at the end of this period.

Where you hold assets within a WRAP, you need to be aware that there will be terms and conditions applicable, such as your agreement with the wrap provider in respect to facilitating our fees, which means you may need to instruct the wrap provider directly and arrange for the removal of assets from the WRAP or appoint another adviser who will be able to access your assets and provide further ongoing advice to you. We will be pleased to assist you at this time in cancelling our service to you, making sure that any WRAP provider is informed of this cancellation.

Withdrawal from or Cancellation of a Product

We will inform you in writing of your right to withdraw from, or cancel, a product you have purchased. If no such right exists, we will advise you accordingly.

If we have agreed to accept payment in full, or part, by commission, in respect of a non-investment insurance product, and you subsequently cease to pay premiums into the contract, we may be obliged to refund to the product provider some, or all, of the commission that has previously been paid to us. In such circumstances we reserve the right to reclaim from you the amount of commission we have been obliged to return to the provider.

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Once you have decided to implement your Financial Arrangements, it is recommended to benefit from on-going monitoring’ optimisation & review.  Our default ‘Ongoing Advice’ service incorporates a periodic review of your arrangements at least annually and an annual suitability review of any ‘Centralised Investment Proposition’ or ‘Bespoke’ investments arranged.  This is important to ensure your plans remain appropriate and in line with any changing needs as time passes.  However, should a situation arise that prevents us from being able to annually assess and reconfirm suitability, this may result in a temporary adjustment to provide a reduced ‘Ongoing Administration Only’ service which still continues to provide all other features including ongoing monitoring, quarterly updates annual reporting of your investment and periodic ad hoc guidance requests via post, phone or email.

For Clients adopting our Centralised Investment Proposition we have created the following Ongoing Service to assist you towards achieving your identified goals, subject to our minimum annual servicing fees as laid out over the page:

• Ongoing Administration and Document Processing
• Quarterly Portfolio Changes Communication
• Ongoing Postal, Telephone and Email Support
• Ensure daily online valuation access and quarterly updates of your portfolio valuations and progress
• Provide Trust Advice (Where Applicable)
• Referral to other professionals
• Issue of Annual Review to include an examination & assessment of your portfolio, its performance & costs
• Ongoing Investment Advice (Does not apply to the Administration Only Service)
• Assessment of and Confirmation Suitability Statement (Does not apply to the Administration Only Service)
• An offer of one face to face or telephone annual review meeting to cover the following: (Does not apply to the Administration Only Service)
  • Update your standing data (Personal Details only)
  • Identify any changes to your personal circumstances or objectives
  • Establish whether your current insurances and protection cover remains appropriate (if applicable)
  • Identify tax changes that may affect your investments
  • Discuss your investment strategy and ‘Risk Profile’, in line with your current circumstances, investment experience and financial objectives – we will recommend changes where necessary
  • Carry out any retirement planning (if applicable)
  • Examine and make recommendations regarding your estate planning arrangements (please note that the Financial Conduct Authority does not regulate taxation and trust advice).
  • Provide any information required for your accountant or other professionals
  • Confirm ongoing Suitability or recommend amendments where appropriate

Should you have opted for a Bespoke service, once we have agreed the level of service you will receive, we will also aim to outline and confirm this in our ‘Client Engagement & Fee Agreement’ Letter.

Example of ongoing advice & administration only charges

The actual fee charged will vary depending upon how the investment performs and it will increase as the fund grows.

We will provide you with information regarding the costs at least annually to help you understand the overall cost and the cumulative effect on the return of the investment.

Termination of our services (Ongoing Advice & Administration Only)

You, or we, have the right to cancel payment for our ongoing services at any time, we would give you 14 working days’ notice, and upon request, could signpost you to alternative sources of financial advice.  We will terminate any on-going payments to be received from product or service providers at the end of the notice period.

You are asked to give us 14 working days’ notice and we will terminate any on-going payments to be received from product or service providers at the end of this period.

Where you hold assets within a WRAP, you need to be aware that there will be terms and conditions applicable, such as your agreement with the wrap provider in respect to facilitating our fees, which means you may need to instruct the wrap provider directly and arrange for the removal of assets from the WRAP or appoint another adviser who will be able to access your assets and provide further ongoing advice to you. We will be pleased to assist you at this time in cancelling our service to you, making sure that any WRAP provider is informed of this cancellation.

Withdrawal from or Cancellation of a Product

We will inform you in writing of your right to withdraw from, or cancel, a product you have purchased. If no such right exists, we will advise you accordingly.

If we have agreed to accept payment in full, or part, by commission, in respect of a non-investment insurance product, and you subsequently cease to pay premiums into the contract, we may be obliged to refund to the product provider some, or all, of the commission that has previously been paid to us. In such circumstances we reserve the right to reclaim from you the amount of commission we have been obliged to return to the provider.