SHEPPARD DAVIES ASSET MANAGEMENT

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 programmes 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

In the unlikely event of your having a complaint about any aspect of investment products or services which we have supplied to you, please immediately contact the compliance officer at Sheppard Davies Asset Management Ltd. Your complaint can be in writing or by telephone or email and will be dealt with as a matter of urgency. You will receive a response within five working days and be informed of the progress of the complaint. A final response will be issued within eight weeks of receipt of the complaint. However, if this is not achieved, a statement of progress will be issued with a new date for the final response.

If we cannot deal with the complaint to your satisfaction, you have the right to take the complaint to the Financial Ombudsman Service (FOS) and we would send you a leaflet explaining how this should be done. We will also send you a copy of the firm's complaints procedure if you wish.