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The aim of this statement is to detail the Firm’s policy with regard to Financial Services Authority (FSA) Principle 6: "pay due regard to the interests of its customers and treat them fairly" and the processes of putting customers’ interests at the heart of the business.
We are fully committed to the principle of treating our clients fairly, and the following confirms our commitment to you:
Correspondence with you
It is the policy of the firm to attempt to make all correspondence and promotions with you as clear, concise, simple, fair and not misleading. We attempt to make suitability letters as easy to understand as possible, whilst still meeting all associated FSA rules.
Advice and sales process
We will at all times endeavour to provide advice that is appropriate and that accounts of your specific profile, needs, knowledge and attitude to investment risk. When assessing your attitude to investment risk we will do our best to ensure that you understand what this means. We will always obtain sufficient information from you to understand your circumstances, needs and requirements.
By carrying out full and/or regularly updated fact finds, where possible, we will structure a programme over time to protect you in terms of your exposure to risks and capitalise on opportunities via good financial planning. We will then give you the option to act upon these needs or reject them if you wish without pressure to proceed.
We will always ensure that we disclose information in a way that is understandable to our clients whilst complying with FSA rules and requirements. This particularly applies to the potential risks clients take when investing. We will always ensure fair treatment.
Flow of information between Whitehead Group Ltd and its customers
It is important that you understand the nature of the services being offered by us and how you pay for them.
We are a fee and commission practice and we will always agree any fee charged before commencement of the work. If additional charges are to be incurred, then we will agree and explain these to you before carrying out the actual work. If you wish to pay our fee by allowing us to retain any commission payments, we will offset such an amount against our fee but always refund any difference to you. We will maintain adequate records to account for client monies and invoices raised.
We will always be open with you and will, if relevant, communicate with you on any matters that might affect you.
Accurate and timely record keeping
It is important that we keep accurate and adequate records of your needs and instructions at each stage of the sales process. It is also important that the administration of your transaction is carried out efficiently. Accurate records are kept to record all advice and information given and received.
If you require information, we will be open and responsive to your request, replying in a timely manner. We will be mindful of the need to review customer information to ensure its accuracy and to comply with the Data Protection Act. This will enable us to respond fairly to you in the unfortunate event of a dispute.
At all times we will ensure that your data remains confidential.
Disputes and complaint handling
We already have in place a written complaints procedure that every member of staff has read and understood. It is important that disputes are handled sympathetically and that the firm is open and honest about its mistakes. We recognise that a well-handled complaint can prevent a potentially difficult situation escalating and can ultimately retain customer loyalty.
We will be open in our complaint handling procedures and inform you of areas outside of your complaint, if applicable, where we may have discovered errors of which they may not be aware. A complaint does not automatically lead to compensation, putting the matter right and offering an apology may often be more than enough. Customers readily accept that errors occur and in many cases are gratified that a firm will accept that they are fallible and keen to rectify the situation.
Staff training
We acknowledge that the dealings of all staff affect whether customers are treated fairly. Having members of staff who are adequately trained and mature enough to acknowledge whether a task is outside their expertise is important in this regard. Continuous professional development is important for all members of staff to maintain skills and competence. We also encourage our staff to obtain professional examinations.
Information from insurers/providers
It is important that our staff understand and consider documentation supplied by insurers, to ensure that they fully understand the features and risks associated with the product being recommended. Our staff should also be in a position to make an informed judgement on the content and opinions expressed in any insurer’s/provider’s literature.
Keeping up to date
Our senior management will continue to monitor further FSA guidance, to ensure that TCF is consistently built into the overall culture of the business, at all times.