Treating Customers Fairly (TCF) Policy

Introduction

The FCA’s Treating Customers Fairly (“TCF”) initiative builds upon the regulator’s core Principles for Business, specifically PRIN 6 – “A firm must pay due regard to the interests of its customers and treat them fairly.”

TCF is embedded throughout the FCA’s handbook. TCF outcomes are envisaged:

  • Customers can be confident they are dealing with firms where TCF is central to the corporate culture.
  • Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and targeted accordingly.
  • Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
  • Where consumers receive advice, the advice is suitable and takes account of their circumstances.
  • Consumers are provided with products that perform as firms have led them to expect and the associated service is both of an acceptable standard and as they have been led to expect.
  • Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

The purpose of this policy is to ensure that, at all times, CAM and its employees comply with our FCA obligations to Treat Clients Fairly. TCF must inform every internal decision and interaction with our customers.

Our Mission Statement

To preserve and enhance our clients wealth with creative and responsible management of their portfolios through a comprehensive understanding of their total financial circumstances and objectives.

Embedding TCF principles throughout City Asset Management

  • Adviser and Staff Training and Competence – We ensure that all adviser and staff are appropriately versed in all of the fundamental principles of TCF. In addition, where applicable, advisers and staff are comprehensively trained in order to suitably advise on and efficiently provide our services. We ensure that all TCF training is kept up to date in order to take account of market and regulatory changes.
    We operate a robust Training and Competence Scheme. This is to ensure that all our advisers and staff achieve the necessary qualifications and training in order to carry out their job functions with the required competence level. Within our Training and Competence Scheme, we implement stringent monitoring and assessment of our advisers so we can be certain they remain competent for their respective duties.
  • Communication – All communications with customers will be made in an open and transparent manner.
  • Customer Service – We have service standards for our customers so they can be sure of the level of service that they may expect from us.
  • Suitability – AAll clients will be correctly classified to ensure they are offered the appropriate level of protection. All recommendations made to our customers will be tailored to their requirements and suitable for their investment objectives.
  • Management Information (MI) – We use MI to ensure that our TCF commitment is being met. Good MI enables the management and directors of CAM to make informed business decisions in the best interest of our customers. Good MI should be accurate, timely, relevant and consistent. In this vein, CAM’s compliance department produces a monthly MI report which is reviewed at the monthly Board meeting. This MI report is made available to all directors and senior managers each month and discussed in detail at the monthly board meeting. Other MI reporting, including compliance reporting, is produced throughout CAM.
  • Risk Management – Our risk management policy helps ensure we are aware of and appropriately control our risks in order that we can provide the best service to clients. Risks are reviewed weekly and discussed with directors and senior management in the Risk and Compliance Committee (the “RACC”).
  • Systems and Controls – Our risk management is further supported by a series of system processes and controls to help monitor our risks and compliance to procedures.
  • Policies and Procedures – CAM has in operation a significant number of policies and procedures that are designed to manage any conflict and risks that may arise in our fair treatment of customers. These policies and procedures can be found within our Corporate Governance Handbook, our company compliance manual and departmental procedural manuals.
  • Complaints – CAM strives to provide the very best level of customer service. We deal with customer complaints in a fair and objective way including awarding compensation when necessary. All complaints are recorded by our Compliance Department and reported and analysed in RACC meetings, MI reporting and Company Board meetings. We have implemented a separate complaints policy.
  • Complaints Procedure - Should you be dissatisfied with any aspects of the services provided to you, you may make a complaint to the Compliance Officer. We ask that complaints be confirmed in writing. You should send your complaint to CAM's registered office address:
    Compliance Officer
    7 Bishopsgate
    London
    EC2N 3AR.

    Upon receiving the complaint, CAM shall acknowledge the complaint and provide details of CAM's internal complaint handling procedures.

    If you are dissatisfied with the outcome of CAM's investigation of your complaint, you may complain directly to the Financial Ombudsman Service. You need make any such complaint to the Financial Ombudsman Service within six months of CAM sending you its final response to the complaint.

    The Financial Ombudsman Service's contact details are:

    The Financial Ombudsman Service
    South Quay Plaza
    183 Marsh Wall
    London, E14 9SR
    Tel: 0800 023 4567
    Email: complaint.info@financial-ombudsman.org.uk
    Web: http://www.financial-ombudsman.org.uk/

Summary

The majority of the above TCF policy has been longstanding practice throughout City Asset Management. However, we acknowledge that TCF is an ever developing and continuous process so we are constantly reviewing our policies and procedures to ensure that TCF remains of paramount importance.

We welcome any ad hoc feedback from clients as to how we can improve our service.


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Important Information and Risk Warnings

The company is authorised and regulated by the Financial Conduct Authority (FCA) ensuring that its conduct and practices are governed by the rules and principles of the FCA. By accessing these pages you shall be deemed to accept and agree to be bound by the terms of this notice.

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For the purposes of the Retail Distribution Review (RDR), City Asset Management offers Restricted Advice. This means that we will advise and make a recommendation for you after we have assessed your needs , but we may only offer advice on limited types of products, or products from one company or a limited number of companies. For example, we may only recommend our own in-house investment products and services.

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