Treating Customers Fairly

Our TCF Principles

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

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

• Our level of service and product performance meets the expectations of our customers as far as reasonably possible.

• We ensure that there is no barrier for customers to express their requests, concerns, or complaints, and always are responsive to them.

• Products and services are designed to meet the needs of clients.

Assessing and implementing our TCF Principles

Marketing

All 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, our brokers obtain a detailed understanding of the clients’ investment objectives, their level of expertise, and their attitude to risk so that their recommendations are suitable.

We ensure that our clients understand the risks involved with any service or product offered and are aware of all applicable charges.

We classify all our clients correctly to ensure they are offered the appropriate level of protection.

Investment and asset allocation decisions are regularly reviewed by the relevant committee.

Fenchurch Faris Ltd. always strives to keep clients informed.

Policies and Procedures

Fenchurch Faris Ltd. has a number of policies and procedures that are relevant to the fair

treatment of clients:

• Conflicts of Interest Policy

• Data Protection Policy

• Personal Account Dealing Policy

• Complaint Handling Procedures

• Financial Promotions Procedures

• Investment Procedures

• Compliance Manual

Management Information

Fenchurch Faris Ltd. produces MI in order to assess its performance against TCF principles. We ensure that MI is accurate, timely, consistent and relevant in order to assist the business in making informed decisions in the best interests of our clients. Fenchurch Faris Ltd. produces MI reports which are reviewed regularly by senior managers, directors, and board members in various Executive committee meetings.

Awareness/Training

Fenchurch Faris Ltd. ensures that all advisers and staff are familiar with the fundamental principles of TCF. In addition, where applicable, advisers and staff are trained in order to suitably advice on and efficiently explain and provide our products and services. We make sure that all of our advisers 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 advisers and staff so that we can be certain of their competence.

Compliance

Fenchurch Faris Ltd. has a compliance team who is independent and regularly monitors all key areas of regulatory compliance.

Remuneration

Fenchurch Faris Ltd. operates a remuneration model that mitigates sales bias and rewards non-sales staff in a way that would not negatively impact the treatment of its clients.

Complaints

Fenchurch Faris Ltd. aims to provide excellent customer service and complaint handling is a major component of its measures. We deal with customer complaints fairly and objectively and attempt to put things right as quickly as possible.

Customer feedback

We are happy to receive Customers’ feedback to identify that we are treating customers fairly. Satisfied customers and feedback responses help us to improve and identify areas where our firm and its advisers are or are not treating customers fairly and therefore areas where improvements are needed.

Conclusion

Fenchurch Faris Ltd.’s culture is and has been throughout the years in line with all regulations.

However, we frequently review our policies, procedures, and practices to ensure that TCF remains a crucial part of our business.

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