SHEPPARD DAVIES
ASSET MANAGEMENT

Sheppard Davies Asset Management

SHEPPARD DAVIES TREATING CUSTOMERS FAIRLY

Policy

Sheppard Davies' policy on Treating Customers Fairly is balancing the customer's needs with the firm's needs, being absolutely clear about what the firm and its services offer, and being transparent about fees and levels of service.

Specifically this requires that:

  • Our customers should clearly understand the nature of the services we provide, including our terms, conditions and charges.
  • Customers must clearly understand the risks inherent in the markets and securities in which they invest through us.
  • We must communicate in an open, transparent and easily understandable manner and have a clear understanding of Customers investment objectives, investment experience, attitude to risk, financial standing and resources.
  • We must be clear about the suitability of our recommendations to our customers.
  • We will not promise to provide services we are not able or equipped to deliver.
  • Training and Competence programs must embed the concept of "Treating Customers Fairly" within our corporate culture.
  • Our complaint procedures must be clear, unambiguous and impartial.
  • We must be able to measure the effectiveness of our policies of treating customers fairly.

Complaints

You expect first class service from us and that is what we aim to provide. However, sometimes you may not be happy with a financial product or service. This may be our fault or may simply be because of the nature of the product or service. If there is a problem or if you are not happy about the service you have received please tell us and we will try to put things right. If you don't understand something or you think that there is a problem, ask us for an explanation. We need to know and understand what the problem is. If we do we can often resolve matters quickly and easily. But if you are not happy with the answers we give you, you may need to make a formal complaint.

What is a Complaint?

We deem a complaint to be any expression of dissatisfaction from or on behalf of a customer, whether oral or written and whether justified or not. Please note that we may handle disputes about regulated business in a different way to non regulated disputes.

What do we do if we receive a complaint?

All complaints will be referred to the Compliance Manager, Sheppard Davies Asset Management Ltd, Agincourt House, Agincourt Square, Monmouth NP25 3BT even if the problem has already been sorted out. A dispute may be about a regulated product or service or a non-regulated activity. In either case we undertake to resolve the matter in a timely manner and will keep you informed of progress.

Regulated complaint

A complaint about a regulated investment activity is defined as:

  • the issue is raised by or on behalf of an eligible complainant (i.e. a private customer)
  • the dispute relates to regulated activity
  • the dispute involves an allegation that you have suffered, or may suffer, financial loss, material distress or material inconvenience
  • the dispute has not been resolved by close of business on the day following receipt.

If a dispute does not fall within the above definition then it will be treated as a dispute about a non-regulated activity.

Acknowledging the dispute

We will acknowledge your complaint in writing within 5 days. Our letter will set out our understanding of the dispute and invite you to let us know if our understanding of the nature of your complaint is incorrect. The acknowledgement letter will outline the result of the investigation if it has been completed by then. If it has not been completed, we will:-

  • investigate the issue and respond within 4 weeks;
  • highlight that if the investigation is not completed within 4 weeks following the initial receipt of the complaint, you will be informed of the reasons for the delay and will be given an indication of the expected timescale to provide a final response ; and
  • point out that on completion of the investigation you will be informed of the outcome and the options available to you.

If the complaint is against another authorised firm we will forward the complaint on to that firm promptly and advise you of the fact giving you details of how to contact the firm. We will write to you giving you our final decision and advising you that if you are dissatisfied with the outcome that you may refer the matter to the Financial Ombudsman Service within six months of the letter. The letter will include the name, address and telephone number of the Ombudsman and a leaflet about the Ombudsman's arrangements.

If the complaint is against another firm and us we will investigate the part against us and will forward details of your complaint to the other firm. We will send you the contact details of the other firm. If the complaint is against a firm that was but is no longer authorised we will refer the matter to the Financial Services Compensation Scheme and provide you with the contact details.

Conclusion

On completion of the investigation we will write to you advising you of the outcome of the investigation, the nature and terms of any settlement, and that if you are dissatisfied with the outcome that you may refer the matter to the Financial Ombudsman Service within six months of the letter. The letter will include the name, address and telephone number of the Financial Ombudsman Service and a leaflet about the Ombudsman's arrangements.

If our investigation is not concluded within 4 weeks, we will write to you informing you that the investigation is continuing, the reasons for the delay and when we expect to be able to contact you again.

If our investigation is not concluded within 8 weeks, we will write to you informing you of the reasons for further delay and that if you are not satisfied with progress you may refer the complaint to the Financial Ombudsman Service. The letter will include the name, address and telephone number of the Ombudsman and a leaflet about the Ombudsman's arrangements.

© 2007-8 Sheppard Davies Asset Management
Sheppard Davies Asset Management Ltd is regulated by the Financial Services Authority