Terms of Engagement
Alexander House Financial Services Ltd, Financial Conduct Authority (FCA) number 601371 is an Appointed Representative of CAERUS Financial Limited. CAERUS Financial Limited is part of the CAERUS Capital Group, which is wholly owned by Intrinsic Financial Services Limited. Old Mutual Wealth Holdings Limited owns 89% of the share capital of Intrinsic Financial Services Limited with the remaining 11% being owned by minority shareholders.
CAERUS Financial Limited is authorised and regulated by the Financial Conduct Authority 25 The North Colonnade, Canary Wharf, London, E14 5HS. You can check the registration on the FCA’s Register by visiting the website https://register.fca.org.uk/ or by contacting the FCA on 0800 111 6768. Their Financial Conduct Authority number is 497604.
CAERUS Financial Limited is a limited company registered in England and Wales, registered number 06784783, registered office, Wiltshire Court, Farnsby Street, Swindon, SN1 5AH.
CAERUS Financial Limited’s permitted business is Investments, Pensions, Life Insurance, Protection and Mortgages.
The provisions of this client agreement will take effect immediately. They are provided to you and will continue in force until they are cancelled by you or us, or they are replaced by an updated client agreement.
This document is aimed at providing you with a brief overview of our firm and to introduce our services to you in more detail, from which you may then select the service and remuneration package that best suits your needs. We will discuss this with you so that you fully understand what is offered and how it will benefit you. Should you have any questions on any element of this, please do not hesitate to ask us.
It is critical you take the time to review this document in full, particularly the sections entitled:
Watch this presentation for the Client Agreement in Plain English.
- Advice Services
- Our Services
- How we Charge
- Communicating with You
- Client Classification
- Conflicts of Interest
- Client Money
- Record Keeping
- Data Protection and Direct Marketing
You will have already been sent a short Presentation covering these points or it can be found on our website http://www.alexanderhousefs.co.uk/about-us/terms-fees/
The firm is authorised to advise on and arrange Life Assurance, Pensions, Collective Investments, New Individual Savings Accounts, Mortgages and General Insurance. We are bound by the rules of the FCA.
We are a Chartered firm of financial planners. This is the industry’s gold standard for our industry. We have satisfied rigorous criteria relating to professional qualifications and ethical good practice. You can therefore be confident that you are dealing with one of the UK’s leading firms that is wholly committed to providing you with the best possible advice, service and support.
We offer products from a range of insurers for non‐investment life insurance, critical illness, permanent health insurance, waiver of premium cover, private medical insurance, buildings insurance, contents insurance and mortgage payment protection insurance and accident, sickness and unemployment insurance. Ask us for a list of the insurers we offer insurance from.
When providing advice, we will often come across the need for one or more of the above. We are happy to provide general advice on these matters and can refer you to a number of specialist services. The referral will vary depending on exactly what it is that you require and we are constantly seeking new and improved providers of these services. We can refer you to a low‐cost service or a more comprehensive service as required. Discussions regarding these matters will normally form part of a meeting with your adviser, but please feel free to raise the matter if you would like more information. Your adviser will be able to provide more information on this service including an indication of the costs.
We offer mortgage products from the whole market. We will advise and make a recommendation for you on mortgages after we have assessed your needs. We offer a range of services dependant on the complexity of your personal circumstances. This service is not included in this document and we agree our terms with you separately.
We offer advice on an Independent advice basis. We will advise and make recommendations for you after we have assessed your needs. This means that we provide unbiased advice based on a comprehensive and fair analysis of the relevant market, giving due consideration to the full range of retail investment, pension products available in the marketplace which may be suitable for you.
All individuals employed by or contracted to Alexander House Financial Services Limited to provide investment advice are approved by the FCA.
Unless confirmed in writing to the contrary, we will assume that you do not wish to place any restrictions on the products recommended.
It is important that you know what to expect in terms of the services we provide, and that you understand our commitment to you in the provision of those services. We intend to be professional, clear, and fair in our dealings with you, and will always ensure that any service or advice provided is in your best interests.
Alexander House Financial Services is a multi‐channel national advisory practice committed to delivering quality advice services to both our individual and corporate clients. You can choose whether you would like to deal on an assisted guidance basis only, via the telephone, via video‐conferencing or at a face to face meeting. You can also choose between a Diploma qualified advisers or a Chartered Adviser Specialist, depending on your needs and we have a range of specialists who can all work with you throughout our relationship.
We offer advice services for all your needs, from savings and investment for the future, planning for your retirement needs, tax planning, protecting you and your family, mortgage and general insurance advice and our clients can choose a number of payment options that will suit their budget and their needs. Our aim is to build a relationship that will allow us to fully understand your life plans and ambitions and be able to deliver long‐term support to help you utilise your monies as wisely as possible and to protect you from any nasty surprises in the future.
We pride ourselves as financial planners who focus on your aspirations and objectives and will deliver a range of solutions and advice on products that meet your needs where that is appropriate. We provide advice services as opposed to selling products and our fees reflect this and ensure we are not conflicted in the advice we give.
We will meet with you face‐to‐face, via a web meeting or telephone conference to understand your current circumstances and your aspirations, priorities and objectives in terms of your financial future. The initial discussion is at our cost. We will get to know you, give you information on our company, services and costs and agree whether our advice services are appropriate for you and how they can be provided within your budget. There is no obligation to proceed at this stage, and no costs will have been incurred. Should you decide to proceed, further to the next stage, we will ask you to formalise your agreement to us becoming your Financial Adviser and permission for us to commence chargeable work for you by signing this Agreement.
Once we have agreed the terms on which we are to operate we will proceed to capture important information in more detail about your current circumstances, your financial history, and your aspirations, priorities and objectives in terms of your financial future. We will also discuss your attitude toward ‘investment risk’, analyse your ‘capacity for loss’ and your understanding of how such risks may affect you. The consultation will close with a summary of our findings, and our suggested next steps toward a tailored, yet realistic, solution to your needs.
At this stage, we will begin to undertake the process of thoroughly analysing your current position based on our extensive knowledge of financial markets, and diligently researching potential solutions for your needs. Should we need to consult with any professional advisers or financial services providers with whom you have an agreement, we will ask for your express consent to do so. The process will identify and quantify any gaps in your short and longer term financial objectives.
When we have all the information we require we will arrange to meet with you to discuss our findings and initial discussion around the potential solutions available. This will allow you to understand what you need to do, a better understanding of the options available, a chance to provide additional information or tailor your objectives further and finally decide whether you want to proceed further. At this stage, you will only have incurred our minimum charges and we will be proceeding to give you specific recommendations and the full fee stage begins.
This is where our experience of the market takes place. Our ability to compare and analyse different products, funds and providers for charges, specific features, past performance, volatility and asset allocation will be used to find the best solution that matches your needs and objectives. We will use all the information we have collected about you, apply everything we know about you and everything we know about the market place to determine the best solution for you. This is a very individual solution so it is always bespoke in its design. Where your investments are of a size to require proper diversification, we will utilise an investment committee to build portfolios
When we have agreed our initial analysis and solution strategy and you want us to move forward towards full recommendations and implementation, we will prepare the comprehensive report which outlines your objectives and the solutions we are recommending, along with the products, providers and funds that we believe will give you the best chance of achieving your objectives. To do this we consider your tax position, the current tax rules that you are affected by and the best solutions to minimise this. We also use a comprehensive range of research tools and due diligence to ensure we are providing you with the best solutions. We will also make it clear where you still may have shortfalls in your plans that will need to be considered in future review meetings. We will arrange to meet with you to discuss our product recommendations in full, and take you through our Report step‐by‐step. You are free to take the report away and give it due consideration before agreeing to move forward to the next stage.
Once you feel that you are in a position to make a fully informed decision to proceed, and you have given us your consent to do so, we will begin the process of acting between yourself, your professional advisers and the product provider with a view to arrange the purchase of any investment products recommended and implement our recommendations. We will assist you in completing all the relevant forms and ensuring your applications are processed by the relevant investment houses and providers in a timely manner.
Depending on the size and complexity of your portfolio once in place, you may or may not require on‐going management services. It is important to be aware that, in the absence of a specific agreement to provide you with on‐ going services, your portfolio and goals will not be monitored unless you contact us to ask for a specific service. Should you wish us to monitor your on‐going position and ensure the advice given remains suitable, we will agree an appropriate service offering outlined in the Services Offering and Costs section in this agreement. The benefits of agreeing to an ongoing service arrangement will include access to your adviser throughout the term of your agreement, regular newsletters and commentaries and access to our Smart Alex Personal Finance Portal if required.
How We Charge
You will always know our fees before you make a decision to appoint us. We don’t hide our costs and have a transparent charging structure, so you can be sure we are working efficiently for your benefit. Our fees are based wholly upon the provision of our qualified and professional expertise; the time taken to analyse your circumstances and devise an appropriate strategy going forward; the design of an appropriate summary report to communicate this strategy to you; and takes into account our firms exposure to regulatory, commercial and financial risk.
Our standard minimum fee is £1,295 for standard advice. More complex advice such as Defined Benefit Pension Transfer Advice, Inheritance Tax Planning and Complex Investment Advice will be charged at a minimum fee of £2,995 plus an additional £495 per additional scheme. Less complex Pension Switches with multiple ceding schemes will be charged at £1,295 plus an additional £495 per additional scheme. Should we undertake initial research towards your goals and discuss our initial findings (Stages 1‐4), but you subsequently decide not to continue with our advice services and do not proceed with our report stage (Stage 5) we will raise an invoice for the agreed minimum fee to recoup our costs to this stage. The full fee remains the same whether we recommend alternative products or utilise your existing schemes to achieve your objectives, our aim will be to fulfil your needs as effectively and efficiently as possible.
Where the implementation of our recommendations includes protection products, general insurance products and home finance arrangements the costs are paid by commission from the chosen product provider and are subject to the charging structure shown below and in our separate mortgage agreement.
Should you decide to continue with our advice services after our initial evaluation, and we go ahead with us preparing your report (Stage 5) we will charge your total fee based on the size of your assets we are advising on for you and will be between 1% and 3.25% depending on the size and complexity of any capital invested but where this exceeds the recommendation fee only the higher of the fees will be charged.
A minimum fee of £495 is charged for the report stage (Stage 6) of any Life Assurance, Permanent Health Insurance, Critical Illness Cover, Waiver of Premium Cover, Private Medical Insurance, Accident, Sickness & Unemployment Cover. Depending on the amount of work carried out this fee may be typically offset against commission received from the product provider.
In many occasions, we can arrange for your total fees to be deducted from the investment amount at outset or by instalments from the premium you pay each month, via the product provider. Alternatively, you may prefer to make your payment to us by an agreed payment method. Your choice can be made in the Client Declaration section of this document.
If you choose to have your adviser charge deducted from the product you will pay nothing to us up front, this does not mean that our service is free. You still pay us indirectly through the deductions from the amount you pay into your product. These deductions will pay towards settling the adviser charge. These deductions could reduce the amount left for investment. For example, if you were to invest £100,000, our initial charge would be 3.25%, which would have the effect of reducing your investment to £96,750.
Any invoices are issued within 10 days of either an advice service being finalised and/or presented and before the transaction is completed or, where your payment is coming from an investment or product,
Whether you have a number of financial goals we are working towards, a sizable and complex portfolio of products or investments, or one or two modest investments or savings plans, it is important to consider how these should be managed going forward. We can provide an on‐going service designed to expertly maintain and monitor your goals. The benefit of this is to ensure that your objectives and attitude to risk are correctly aligned with your products and investments over an extended period of time, changes in budgets and legislation are reviewed, tax implications continue to be managed, and any newer better products on the market can be evaluated on your behalf.
Other advantages to agreeing to an on‐going advice and review service include access to your adviser for support and questions throughout the term of the agreement, regular newsletters and access to our Smart Alex Personal Finance Portal (if required). Here you will be able to see up to date valuations of your portfolio, create a budget plan for a special occasion or important event plus be able to share documents and message your Adviser safely and securely online.
In addition, on‐going advice services ensure that developing and future financial objectives are considered. Furthermore, aspects of your financial arrangements can change over time, including your goals and risk profile as well as the underlying asset’s risk characteristics. On‐going service can help adapt and position your arrangements to manage such changes and influencing factors.
The availability of some services is dependent upon the type of financial plan we implement for you.
Service Offerings and Charges
We offer our Wealth Management clients one of 4 Service Offerings, Bronze, Silver, Gold and Platinum solutions, based on the size of the investments and product types within their portfolio. If you insist on doing so we will focus on a specific area of your finances but where we do you should be aware that this could affect any future advice and my advice could be different than if we had done this in light of your full situation. This service offering will be agreed at outset. Ongoing fees are due monthly and can be paid by direct payment, by deduction from your portfolio or a combination of both.
Alchemy – Self Invest solution ‐ BRONZE
Alchemy is Alexander House Financial Service’s new online system that allows you to access a managed portfolio of passive funds at a much lower cost to more traditional advice routes. We use a cutting‐edge platform from Parmenion to invest your money in funds chosen by our experienced investment committee and managed by CAERUS Portfolio Management
Alexander House Wealth Management Solutions
This solution will suit clients who want to receive ad‐hoc advice on a specific subject and wants to pay an hourly rate or a fixed charge. There is no ongoing service provided in this solution.
This service is our most popular and will provide initial advice on all your financial objectives and then provide ongoing advice on each of these objectives as part of our retained charges. Additional initial charges will only then be incurred if additional funds are added to the portfolio or Specialist circumstances such as estate planning, long‐term care or equity release.
This solution will suit more complex or sophisticated clients who require enhanced solutions and a more bespoke plan for reviews and specialist services. These solutions are always costed on a bespoke basis but will use the Gold Solution costs as the baseline.
It is possible to restrict us to providing advice on a single Platinum area of need which would restrict the work we did for you and the advice you received both initially and on an ongoing basis ‐ this would be a ‘Platinum Managed’ service.
Payable at £250ph for Chartered Advisers and £200ph for Diploma‐qualified advisers.
Available as timed hourly rate of agreed fixed cost based on estimated timescales.
Example: Pension Switch may take 12 hours which would equal £3,000 from a Chartered Adviser.
This is not available for drawdown cases without an agreed ongoing service as this ongoing support is vital to ensure your savings versus your income levels are appropriately controlled.
Based on assets advised on:
Up to £99,999 = 3.25%
£100,000 ‐ £249,999 = 2.75% (min £3,250)
£250,000 ‐ £499,999 = 2.25% (min £6,875)
Above £500,000 = 1.5% (min £11,250)
This solution has the same charging structure as the Gold Solution with additional services included.
Each service will incur an additional charge which can either be on a % or fixed basis.
Initial Services Included
Access to (minimum) Diploma Qualified Adviser, who has been trained and tested to ensure they are competent to provide advice in the areas of advice or, if required, access to our Specialist Advisers. (All Advisers undertake a minimum of 35 hours of study every year to maintain the high standards we require. Each adviser is required to work within an ethical protocol, understand all the regulations determined by the Financial Conduct Authority (FCA))
A comprehensive review of either a Platinum or a holistic view of your financial plans. For the Gold Service this will be a comprehensive review of your full financial situation and lifetime requirements, including taxation issues and estate planning. For the Platinum service this will be limited to the specific need area only. We would always recommend our holistic Gold Solution, but will accept your instructions to limit our service.
Full assessment of your shortfalls and objectives, identifying any gaps. For retirement planning this will also include investigating your eligible state benefits.
Full assessment of your attitude to risk and capacity for loss, using comprehensive questionnaire designed to illicit your position on risk versus reward, along with a review of your income and outgoings to evidence and support your objectives.
Full analysis of the tax wrappers (products) that could be utilised to deliver solutions to meet your objectives in line with the latest products available and the latest tax rules and legislation.
Full research on current products held and a comprehensive comparison to see if they are meeting your current objectives and a review of alternative solutions. This work uses complex research tools and evaluations of the market, which require significant experience and analytical ability to deliver the best solutions to you.
Evaluation of portfolio performance using industry leading comparison and modelling tools, if required, so you can track and understand the impact of your risk outlook versus market performance.
If you proceed to Stage 6, you will receive a comprehensive report outlining our recommendations, our reasons for that recommendation and details of any disadvantages or implications.
We then undertake to deliver a quality review of the advice given, based on risk‐based selection criteria, and provide you access (if required) to your own portal so you can see your communications and valuations in one place and with a secure login.
Finally, we undertake the role of completing the appropriate administration forms, deal with the Product provider to ensure your plans are set up in a timely way, and that all your records are in order for future review and evaluation.
Ongoing Services Included – GOLD
Access to an Adviser within 48 hours via our market leading virtual services and website chat
We will provide regular updates on relevant financial services topics including general economics and legislation changes to keep you informed.
Regular review meeting (s), depending on your contract to ensure your plans are on track. The Gold Solution will also consider the implications from the annual Budget, your tax position and a review of tax mitigation options, a full shortfall analysis and an estimate of your current Inheritance Tax position. The Platinum and Gold solutions include a standard annual review and monthly telephone access if required (Skype only for Platinum Solution)
Annual evaluation of the market to ensure your plans are still suitable for your circumstances and objectives and ongoing advice in relation to the plans implemented (Platinum Solution) or your full holistic position (Gold Solution)
For clients who have taken advantage of the Managed Portfolio Solution we have chosen, you will also receive discretionary rebalancing of portfolios and assessment of funds held and fund manager performance.
Access to both Alexander House and ‘Smart Alex’ social media sites which provide regular updates on what is happening in the country in relation to financial services and educational material to keep you knowledgeable and informed.
Quarterly newsletter and annual Budget summary.
Where you have restricted the advice you want to receive we will focus on reviewing this area only and this will be completed for a reduced minimum charge of £480 per annum or 0.75% of the funds under advisement whichever is the highest. Example: £100,000 under advisement is £750 per annum.
Our ongoing service fee is not dependent on any new recommendations being made or implemented but is based on our full advice support.
As we act on your behalf as an intermediary with a view to the arrangement of a transaction our fees are presently exempt from VAT which means we do not usually have to make an additional charge of 20%. If we do have to charge you for a service which is subject to VAT, we will inform you in advance.
Fees are payable subsequent to our Professional Advice Services being provided, and therefore refunds are not available in normal circumstances. Fees paid in respect of regular or annual services are not refundable. However, any on‐going service may be cancelled upon request.
Where you have paid our fee by commission from the product provider or have received a commission rebate on a product and you cease to pay the premiums due on this product, it is our policy to claim a refund from you. You understand the maximum amount of this refund will be the amount of commission reclaimed by the Provider which shall never exceed the amount of commission which will have previously been disclosed to you in writing. The maximum time under which we may enforce this paragraph is 4 years from the commencement of the product.
You may decide to opt‐out of any ongoing advice and review service. You are free to do so.
However, please take note of the following:
- If your financial circumstances, objectives and attitude to risk change over time, the structure of your investment portfolio may no longer be in your best interests.
- As financial markets fluctuate, the way your assets are allocated in your portfolio may become unbalanced and ultimately expose you to more investment risk than you wish to accept.
- You will not be kept abreast of changes in taxation, new legislation, or new products that could be suitable for you.
- On Pension Drawdown Plans in particular, without advice on making withdrawals, you may incur unexpectedly high levels of income tax, emergency tax, Lifetime Allowance tax and inadvertently restrict your ability to make future pension contributions.
You may opt back in to ongoing services at any time.
This document represents our standard client agreement upon which we intend to rely. For your own benefit and protection, you should read these terms carefully before signing below. If you do not understand any point please ask for further information.
Our typical charges are based on the Scale of Fees outlined above. This Agreement is designed to confirm and formalise our discussion regarding the services we provide.
Where our charges are based upon a percentage of portfolio value, due to the ease of calculation, we will not confirm the fee in specific monetary terms. Where our charges are defined by an hourly rate, we will provide an estimate of the overall cost to you before proceeding.
An invoice in respect of Professional Advice Fees will be raised upon completion of the initial service, or upon completion of any associated transaction/s or product/s, to meet the cost of our services to you.
Please select one of the following options:
Tick this box if you agree to pay our fees as part of our Silver, Gold or Platinum service proposition:
COMMUNICATING WITH YOU
We will enter into communication with you through whatever means is convenient to you and us, including face‐to‐ face, telephone, email and other acceptable electronic communication methods.
We like to keep clients informed of products and services we offer which may be of interest to them. If you would prefer to be excluded from these services, please contact us.
We act as your agent in arranging investment transactions. We never own the investments you buy or transact through us. All investments will be registered in the name(s) of the client(s) unless otherwise agreed in writing. We will forward to you all documents showing ownership of your investments as soon as it is practical after we receive them. Where a number of documents relating to a series of transactions are involved, we may retain each document until the series is completed and then forward them to you. In some cases, the documentation will be sent to you direct from the provider. We may not lend to a third party the documents of title held by us or borrow any money on your behalf against the security of those documents.
Where we provide advice on a non‐packaged product, such as an Enterprise Investment Scheme (EIS) or Venture Capital Trust (VCT), you will not have post sale cancellation rights.
We cannot accept responsibility for taxation advice. Clients must be responsible for their own taxation position and we strongly recommend that clients take advice on taxation matters from a qualified accountant.
English law will be the basis of this contract and the language in which this contract will be interpreted. All communications will be conducted in English.
The Contracts (Rights of Third Parties) Act 1999 shall not apply to this client agreement.
CLIENT CLASSIFICATION – RETAIL CLIENT
In providing investment services to you, we categorise you as a “retail client” unless you have instructed us to treat you otherwise and such instruction has been agreed by CAERUS Financial Limited. The type of client category will determine the level of protections afforded to you under the regulatory system. As a “retail client” the regulatory protections available to you are determined by this category and will be the “highest available”.
Where we have categorised you other than as a “retail client”, you may request re‐categorisation under a client category which benefits from a higher degree of protection. However, we reserve the right to agree to such a re‐ categorisation on a case‐by‐case basis, and where we agree to do so does not necessarily mean that you will have a right of access to the Financial Ombudsman Service.
DISCRETIONARY PORTFOLIO MANAGEMENT
We may make a recommendation to you to invest in a Portfolio or a Discretionary Management Services where the management of the Portfolio or provision of the Discretionary Management Service, is provided by CAERUS Portfolio Management Limited (FCA Number 175524). It is important that you aware that CAERUS Capital Group Limited, is the parent company of CAERUS Portfolio Management Limited and CAERUS Financial Limited. CAERUS Capital Group is in turn owned by Intrinsic Financial Services, therefore, Intrinsic Financial Services owns and receives payments from CAERUS Portfolio Management Limited. Whilst Alexander House Financial Services Limited do not receive any direct financial benefit from recommending this Portfolio rather than other funds, or Discretionary Management Service rather than other Discretionary Management Services, we would like to make you aware of the potential conflict of interest that exists for us in these circumstances.
CONFLICTS OF INTEREST
Alexander House Financial Services Ltd is an appointed representative of CAERUS Financial Ltd which is authorised and regulated by the Financial Conduct Authority. At all times, we will act in your best interests and provide a quality service and excellent financial advice to you.
In rare circumstances a conflict of interest may arise. This would be in a situation where someone in our company has competing professional and / or personal interests, which make it difficult to fulfil their duties to you fairly. If this arises we will inform you in writing of the conflict of interest and ask for your written permission to proceed. In the event that we cannot manage the conflict of interest we may have to decline conducting business with you.
After we have made you aware of the conflict of interest, you may at any time inform us that you no longer wish to receive services or advice from our company. For more information and details, please speak to your financial adviser or Nicholas Kelly in our firm.
In accepting this client service agreement, you agree that we may change the future content without receiving your prior consent to do so, but we will not conduct any investment business for you following any change unless we have given you at least 10 business days’ notice, unless it is impractical to do so.
The benefit of this Agreement, together with any rights and obligations arising hereunder, may be assigned, transferred, disposed of or charged by Alexander House Financial Services Ltd.
CLIENT’S BEST INTERESTS
We require our clients to give us instructions in writing (secure email or letter). We will accept oral instructions at our discretion, which must be confirmed in writing. We can refuse your instructions at our discretion.
Our network maintains professional indemnity insurance to enable us to meet any liability that may arise in respect of our obligations to you for services performed on your behalf.
TREATING CUSTOMERS FAIRLY (TCF)
Both Alexander House Financial Services Ltd and CAERUS Financial Limited recognise the importance of treating clients, staff, advisers and professional partners fairly and with respect at all times. Strategies and approaches adopted help to ensure that TCF principles are implemented and fully incorporated into its business and are committed to ensuring that all developments and initiatives are taken forward in an environment that supports the mission statement, vision and core values.
WE DO NOT HANDLE CLIENT MONIES.
Cheques for premiums or investments can only be made payable to the product provider. 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. No premiums or investment monies of any kind should be paid or be made payable to anyone else.
We will account to you for transactions effected on your behalf either by means of a contract note, or by providing documents of title or certificates evidencing title. We will supply, on request, to you or your appointed agent, contract notes, vouchers and copies of entries in our books or computerised records relating to your transactions. Where a copy is requested, we reserve the right to charge a nominal fee for the production of this copy. We undertake to maintain such records for at least six years from the date of each transaction. We treat all client records as confidential. We will register all investments in your name unless otherwise agreed in writing.
DATA PROTECTION AND DIRECT MARKETING INFORMATION
As part of our arrangement with you, Alexander House Financial Services Ltd has certain obligations under privacy laws, including the Data Protection Act (the “Act”) to notify individuals how it will process any personal information it collects about them. Full details of this can be found in Appendix 1 below.
IDENTITY & ADDRESS VERIFICATION
We are required to verify your identity in accordance with the Anti‐Money Laundering and Proceeds of Crime Regulation. No application will be made until such verification has been obtained. In the absence of such evidence, we may be unable to act for you. This process involves obtaining verification of your identity using documents such as your Passport or Driving Licence and your address (e.g. utility bill, bank statement). In addition, where applicable, we reserve the right to make further enquiries into the source of your funds or wealth to ensure we meet our regulatory obligations.
We may check the details you supply against those held on a number of specific databases. Online verification credit reference agencies have access to, for example information from the Electoral Register and fraud prevention agencies. Scoring methods can be used in the verification process as this gives a more thorough check of the available data. A record of this process will be kept and may be used to help other companies to verify your identity. We may also pass information to organisations involved in fraud prevention to protect ourselves and our customers from theft and fraud. If you supply false or inaccurate information and we suspect fraud, we may make the appropriate search using a reputable online credit reference agency and will keep a record of this search in line with the anti‐money laundering rules and the Data Protection Act 1998.
In fulfilling our obligations under the Proceeds of Crime Act 2002 and other anti‐money laundering legislation, where knowledge or suspicion of money laundering arises, we may pass certain information known to, or suspected by us to the appropriate authorities. This may result in a delay to a transaction and/or a decision that we will cease acting for you.
By signing the Declaration at the end of this Agreement, you consent to us carrying out the appropriate verification checks. Depending on the level of verification generated, we may need to contact you for additional information or documentation. Therefore, we cannot accept responsibility in instances where investments are delayed due to these regulations.
Claims payments will ordinarily be made to you, unless we make payment to a third party with an interest in your policy. If you require a payment to be made to a third party, we may ask for evidence of the third party’s identity and ask you to provide a brief explanation for your request.
If you should have any complaint about the advice you receive or product which you have bought, please write to: CAERUS Financial Limited, Trident 3, Trident Business Park, Styal Road, Manchester Airport, M22 5XB. Tel: 0161 488 3530, Email: firstname.lastname@example.org.
They will acknowledge your complaint and send you a copy of the internal complaints procedure. The matter will be investigated in line with procedures and findings reported to you. If you are still not happy with the outcome, you then have the right to forward any eligible complaint to the Financial Ombudsman Service. The details on how to do so will be provided to you.
If you make a valid claim against us in respect of any of the listed investments we arrange for you and we are unable to meet our liabilities in full, you may be entitled to redress from the Financial Services Compensation Scheme. Details of the cover are given in a leaflet, which we will send to you at your request. Further information is available from the Financial Conduct Authority at 25 The North Colonnade, Canary Wharf, London, E14 5HS. In addition, we are also insured for negligence by way of our Professional Indemnity Insurance.
We are covered by the Financial Services Compensation scheme (FSCS) if we cannot meet our obligations. This is dependent upon the type of business and the circumstances of the claim. Most types of investment business are covered by 100% of the first £50,000 per person per investment institution, with deposit accounts benefiting from protection of £85,000 per banking licence per person and insurance covered up to 100% of the claim with no upper limit. Further information about the compensation scheme arrangement is available from the FSCS.
TERMINATION OF THIS AGREEMENT
This Client Agreement may only be cancelled and our authority to act on your behalf may only be terminated in writing, at any time, without penalty, by either party and with immediate effect without prejudice to the completion of transactions initiated prior to receipt of such notice. Other than as stated in this paragraph, there are no cancellation rights that apply to this Client Agreement.
DATA PROTECTION AND DIRECT MARKETING INFORMATION
The purpose of this notice
As part of our arrangement with you, Alexander House Financial Services Ltd has certain obligations under privacy laws, including the Data Protection Act (the “Act”) to notify individuals how it will process any personal information it collects about them. Our associated group companies (“CAERUS Capital Group”) may also be provided with personal information about you. This Notice will inform you of what personal information we collect, how that information is used, where it is transferred and how you may wish to view such information. You may be assured that we will treat all personal information as confidential and will not process it other than for a legitimate purpose. Steps will be taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary. Measures will be taken to safeguard against unauthorised or unlawful processing and accidental loss, destruction or damage to the information.
What type of information will be processed?
We collect and process various personal data about you for the purposes of providing advice, administration and management services, which are explained in more detail below. ‘Processing’ is defined in the Act but could include obtaining, recording or holding information or data. ‘Personal Data’ is information which can identify you as a living individual, including where used in conjunction with other information. Common examples of personal data which may be collected and used by us in our day to day business activities include:
- Date of birth
- Marital status
- Telephone number and other contact details (including e-mail address)
- Job title
- Bank details and other financial details
Depending upon the types of products and services you require, the information collected and processed may also contain ‘sensitive data’ for purposes of the Act, which includes information held by us as to:
- Your physical or mental health or condition
- The commission or alleged commission of any offence by you
- Any proceedings for an offence committed or alleged to have been committed by you, including the outcome or sentence in such proceedings
- Sexual life
- In limited circumstances, your membership of a Trade Union, your political opinions, religious or similar beliefs
Any information which we receive fairly and lawfully relating to one of the above categories constitutes sensitive personal data. Examples of likely items which may contain sensitive personal data (although this is not an exhaustive list) are life insurance questionnaires, medical reports and SSP self‐certification forms.
Please note that, as with personal data, you have freedom of choice when it comes to your decision as to whether you provide us with sensitive personal data. In addition to your right to request that we stop processing your personal data and sensitive personal data at any time, you have an opportunity at the end of this Notice to choose not to provide sensitive personal data to us at all. You should however, note that if you exercise this right or subsequently request that we stop processing all or part of your personal data and/or sensitive personal data, this could impact upon our ability to provide you with certain types of product and services and may ultimately result in us being unable to provide them to you at all.
How will your personal data be collected and used?
We collect personal data from you to extent necessary to provide advice, administrative and management services and, subject to provisions below, related marketing activities.
We, or our associated group companies (“CAERUS Capital Group”) may process your personal data and sensitive personal data for the following reasons:
- the administration, management and provision of advice in relation to financial services products;
- our legitimate business process and activities including internal audit, accounting, business planning and proposed and actual transactions (including joint ventures and disposals of business); and
- compliance with legal (including dealing with claims), regulatory and other good governance obligations.
This list is not exhaustive and may be updated from time to time as business needs and legal requirements dictate. Some of the personal data that we maintain will be kept in paper files, while other personal data will be included in computerised files and electronic databases.
Who might your personal data be shared with?
Your personal data will be made available for the purposes mentioned above and only to responsible management, human resources, accounting, audit, compliance, information technology and other corporate staff including within CAERUS Financial Limited. It may also be made available to third parties providing relevant services to us, including regulatory support.
Certain personal data will also be reported to government authorities where required by law and for tax or other purposes. Personal data may also be released to external parties as required by legislation, or by legal process, as well as to companies you authorise us to release your personal data to. We will not sell your personal data to any third party.
We and our Group Companies may wish to provide you with information about new products, services promotions and other information in which we think you may be interested. We may send you such information by postal mail, fax and telephone, unless you have registered with the appropriate Preference Service (we would be grateful if you could let us know if this is the case). If you purchase a product from us we may retain your address for future mailings. If you do not want your information used for direct marketing purposes at any time, please contact our customer services department by e‐mail at email@example.com or by telephone on 0800 316 1811 to let us know and we will not send you any direct marketing.
We would also like to provide you with the above information by e‐mail. However, we appreciate that e‐mail ‘spam’ had become a problem in recent years. If you are a customer or you have previously asked us for information on our products:
- we may contact you regarding your purchase or other matters regarding transactions between us or your customer relationship with us or send you information on our products by e‐mail, unless you have asked us not to do so; and
- we may also use your e‐mail address to send you information about our products and services that we think may be of interest to you by way of informational e‐mails, unless you have asked us not to do so.
A consent tick box is provided on the Confirmation of Receipt form where you should indicate your preference to receive e‐mail marketing. If you decide at any time that you no longer wish to receive marketing e‐mails from us, please e‐mail us at firstname.lastname@example.org
Your right to review and amend personal data
You have the right to review your personal data and sensitive personal data held by us and have any inaccurate information about you corrected. If you wish to do so, or to notify a change in your details, please contact The Data Protection Officer, Nicholas Kelly, on 0800 316 1811 or in writing at 3 More London Riverside, LONDON, SE1 2RE. You may be charged a fee (subject to the statutory maximum) for supplying you with such data.
How to request that we cease processing of personal data
If at any time, you wish us to cease processing your personal data or sensitive personal data, or contacting you for marketing purposes, please contact The Data Protection Officer, Nicholas Kelly, 0800 316 1811 or in writing at 3 More London Riverside, LONDON, SE1 2RE.