Treating Customers Fairly Policy

Purpose

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

Policy

“Treating Customers Fairly” was an initiative started by the FCA.  It picked up speed in 2004 through to 2006 and is now a key element of the firm’s obligation to puts its customers first.  It is primarily aimed at retail clients.

CAM strives to provide the very best level of customer service and integrity.  We have a longstanding practice through CAM to treat customers fairly and this policy 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 client as to how we can improve our service.

Our mission is to preserve and enhance our client’s wealth with creative and responsible management of their portfolios through a comprehensive understanding of their total financial circumstances and objectives.  CAM is committed to treating customers fairly and adheres to the six customer outcomes as defined by the FCA:

•Consumers can be confident they are dealing with firms where the fair treatment of customers 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 are 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 into account their circumstances.

•Consumers are provided with products that perform as firms have led them to expect and the associated series is both of an acceptable standard and also 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.

We have embedded TCF principles through CAM and all staff are required to undertake TCF training during the induction processes and throughout their employment.

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 communication with customers will be made in an open and transparent manner.

Customer Service

We have in place set service standards for our customers so they can be sure of the service level expected from us.

Suitability

All clients will be correctly classified to ensure they are offered the correct level of protection.  All recommendations made to our customers will be suitable to their requirements and 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 decision in the best interest of its 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 on a monthly basis and discussed further at the monthly board meeting.  Other MI reporting, including compliance reporting is produced throughout the firm.

Risk Management

Our risk management policy helps ensure we are aware and 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 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 this 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 reports and analysed in Committee meetings, MI reporting and Company Board meetings.  We have implemented a separate complaints policy.

Version Winter 2016 KQ2480