We are delighted to take this opportunity to give you some information on our corporate governance policy. The firm considers corporate governance to be a top priority and as such reviews its policies on a regular basis to ensure they are in line with the firm’s ethos and mission statement. The corporate governance system is a set of rules, practices, and process by which a firm is directed and controlled. At the core of our governance culture is an ethos to ensure we provide a top-class service to our clients whilst respecting our colleagues and ourselves. The firm has robust corporate governance arrangements which include a clear organisational structure with well defined, transparent, and consistent lines of responsibility. In addition effective processes to identify, manage, monitor and report the risks to which it is or might be exposed, adequate internal control mechanisms, including sound administrative and accounting procedures, IT systems and controls and remuneration policies and practices that are consistent with and promote sound and effective risk management are in place.
Culture
We believe that a strong governance and compliance culture is central to the day to day running of our business and to the overall long-term success of our business model. We believe our clients are best served in an environment where their interests are considered to be of paramount importance.
We foster a top down approach where our board and management team lead by example. Starting from the top, our board of Directors, are fully committed to maintaining appropriate standards of governance and compliance with independent oversight and accountability. Fostering such a culture has positive “knock-on” effects on our staff. We believe that this top down approach is the most effective and appropriate way to ensure compliance from all employees and to foster a culture of openness and growth within the regulatory field.
We strive to ensure that we are fully compliant with the relevant regulations. We also strive not only to comply with the regulations but to encompass industry best practice in the services that we provide to customers and potential customers alike. We endeavour to act in the customers’ best interest, and we believe that having a strong and efficient compliance team support strengthens our customer relationship.
As compliance is a dynamic and ever changing area we have a team focus on looking forward to ensure that we are keeping on top of all incoming regulation and to ensure that the compliance function works efficiently, dynamically and independently.
Mission Statement
Provide a transparent and bespoke service to our clients.
Reliability is at the heart of everything we do.
Our attitude towards others determines their attitude towards us.
Value for money through a combination of cost, quality, and sustainability to meet our clients needs.
Enable our clients to make informed decisions through a combination of detailed analysis and suitable recommendations.
Striving to achieve the best outcomes for our clients in a fair and equitable manner whilst respecting the integrity of our employees and our service partners.
Trust in our commitment to behave ethically with our clients, employees, and service providers, ensuring where possible, our business endeavours make a positive impact on society.
Governance
The firm has robust corporate governance arrangements which include a clear organisational structure with well defined, transparent and consistent lines of responsibility, effective processes to identify, manage, monitor and report the risks to which it is or might be exposed. Adequate internal control mechanisms, including sound administrative and accounting procedures, IT systems, controls and practices are consistent with and promote sound and effective risk management.
The governance arrangements are subject to regular internal review. The corporate governance structure and policies for the firm are articulated clearly and communicated to all appropriate staff.
The effectiveness of the Board in carrying out its governance role and oversight is a critical component in the overall regulatory framework. When fulfilling its oversight role of the compliance function the board take focuses on the following areas:
· Compliance Monitoring Obligations
· Compliance Reporting Obligations
· Compliance Advisory Role
· Effectiveness of Compliance Function
Accountability - The Board
The board is ultimately responsible for ensuring that the firm has a functioning permanent compliance function with the relevant experience, expertise, impartiality, and resources to enable it to fully carry out its duties. The Head of Compliance provides a report to the board on a quarterly basis. This is an important step in the oversight role of the board and is a forum where any issues can be assessed and addressed.
Accountability - Head of Compliance (HOC)
The Head of Compliance is charged with overseeing all aspects of the Compliance Function which are detailed in the job description. The HOC is aware of their duties in relation to reporting to the board on a regular basis.
Accountability - The Compliance Team
The compliance team are responsible for supporting the HOC in their role. The compliance team are aware that any breaches must be reported to the HOC, who in turn will report them to regulators.
Accountability - The Operations Team
The operations team is aware of their duty to report any breaches or any issues arising to the HOC without delay. As detailed in the reporting lines diagram all staff members are aware of their specific responsibilities in relation to reporting and escalating any issues to the correct person.
Risk Management
The firm considers risk management to be an integral part of its internal controls. The firm aims to ensure that all its potential risks are identified and addressed to mitigate those risks.
The Firm shall monitor and manage risks on an ongoing basis, to ensure they are addressed appropriately.