Treating Clients Fairly (TCF) Policy

Introduction  

Capiteus adheres to the principle of paying due regard to the interests of its clients and treating them fairly (TCF). Capiteus is fully committed to TCF and this Policy has been designed to demonstrate the application of TCF during the course of our day to day activities.

TCF is embedded in everything Capiteus does and has as its aims:

  • Consumers must be confident they are dealing with a firm (Capiteus) where TCF is central to the corporate culture

  • Products and services marketed and sold by Capiteus are designed to meet the needs of the client

  • Clients are provided with clear information and are kept appropriately informed before, during and after the point of sale

  • Where clients receive advice, that advice is suitable and takes account of the client’s circumstances.

  • Clients are provided with products that perform as we have led them to expect and the associated service we provide is both of an acceptable standard and as they have been led to expect

  • Clients do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

Our TCF Guiding Principle

We will act with integrity in everything that we do and will always treat our clients fairly.

 Our TCF Principles

  1. Clients will be provided with clear information and kept appropriately informed before, during and after the point of sale.

  2. If we give advice to our clients, the advice will be suitable and take account of their circumstances.

  3. Our level of service and product performance will meet the expectations of our clients as far as reasonably possible.

  4. We will ensure that there is no barrier for clients to express their requests, concerns or complaints, and will always be responsive to them.

  5. Products and services will be designed to meet the needs of clients

Assessing and implementing our TCF Principles

Marketing

All Capiteus’s financial promotions and marketing literature are reviewed to ensure that they are appropriate for the target audience and are presented in a clear, fair and not misleading manner.

Sales, Advice, Management

When providing advice, Capiteus’s brokers obtain a detailed understanding of the client’s investment objectives, their level of expertise and their attitude to risk so that their recommendations are suitable, except where the client conducts their own research and analyses and asks Capiteus to transact on their behalf on an Execution Only basis. We will take all reasonable steps to ensure that our clients understand the risks involved with any service or product offered and are aware of all applicable charges.

Post-Sale Information and Support

Capiteus strives to keep its clients informed at all times. Appropriate records are provided as required and on an ongoing basis. We have appropriate capacity and processing arrangements in place to ensure continuous support and no post-sale barriers.

Policies and Procedures

Capiteus has a number of policies and procedures that are relevant to the fair treatment of clients.  These include (this not an exhaustive list):

•    Conflicts of Interest Policy

•    Data Protection Policy

•    Complaint Handling Procedures

Management Information

Capiteus produces Management Information reports in order to assess its performance against its published TCF principles. We ensure that Management Information reports are accurate, timely, consistent and relevant in order to assist the business in making informed decisions in the best interests of our clients. These reports are reviewed regularly by senior managers, directors and board members in various committee meetings.

Awareness/Training

Capiteus ensures that all brokers and staff are familiar with the fundamental principles of TCF. In addition, where applicable, brokers and staff are trained in order to suitably advise on and efficiently explain and provide our products and services. We make sure that all of our brokers and staff achieve the necessary qualifications and training in order to carry out their job functions with the required competence level. We undertake regular monitoring and assessment of our brokers and staff so that we can be certain of their competence.

Compliance

Capiteus has a compliance team which is independent and regularly monitors all key areas of compliance including TCF.

Remuneration

Capiteus operates a remuneration model that mitigates sales bias and rewards all staff in a way that does not negatively impact the treatment of its clients.

Complaints

Capiteus aims to provide excellent client service and complaint handling is a major component of its TCF measures. We deal with client complaints fairly and  objectively and attempt to put things right as quickly as possible. All complaints are recorded and monitored by our compliance team and reported and analysed in company Management Information and committee meetings.

  

Conclusion

TCF is embedded in the Capiteus culture. Capiteus frequently reviews its policies, procedures and practices to ensure that TCF remains at the heart of our business.

We ask our clients to provide us feedback, sometimes formally through client surveys, so that we can improve our service. The information we collate from our clients can be reflected in company Management Information and reviewed by senior managers, directors and board members to help shape any strategic decisions.