This page contains information on policies and procedures for Edale UK Management Limited and Edale Enterprises Limited (hereafter Edale).
Compliance statements from Edale including modern slavery policy can be seen at https://edale.co/statements/.
Terms and conditions for promotions can be seen here.
Edale Key Information and Disclosure
This document is issued on behalf of Edale of 33 Kings Avenue, Redhill, RH1 6QH whom can be contacted at 0207 99 35 360. Our principal place of business is 15 Bell Street, Reigate, RH2 7AD. This document gives you key information about us, how we work and services we provide.
Edale is Authorised and Regulated by the Financial Conduct Authority reference number 812332. The Financial Conduct Authority (FCA) regulates the financial services industry in the UK and their address is 25 The North Colonnade, Canary Wharf, London, E14 5HS. You can check this on the FCA’s Register by visiting the FCA’s website http://www.fca.org.uk/ FCA or by contacting the FCA on 0800 111 6768.
Edale is satisfied that it has embedded the Treating Customers Fairly (TCF) values and principles into its business. A strong focus on client service and listening to our clients has always been part of our culture and our client-related processes and policies are continually reviewed and re-aligned where required.
Key indicators relating to our TCF policies are monitored regularly throughout the business. All outcomes are reviewed and considered by senior management to ensure that TCF stays firmly on our agenda and that it is part of our business as usual processes.
For the purposes of the FCA rules, we will treat you as a Retail Client unless otherwise specifically stated in writing. This classification allows you the maximum level of regulatory protection. On the basis of the information you provide on your Application Form we shall classify you as a retail client, a professional client or an eligible counterparty for the purposes of the FCA rules. We shall confirm this classification in writing to you when we confirm the opening of your account.
We will communicate with you in English both verbally and written for the sending and reception of orders. To avoid any doubt instructions should be issued in writing.
Scope of Service
We are an independent firm but provide restricted investment services and simplified advice. We provide access to Securities (Equities and Bonds) and Investment Funds (Unit Trusts and Open Ended Investment Companies) from a restricted list of recognised investment markets and product providers. We also promote specific tax-advantaged ‘wrappers’ in which these funds can be held e.g. Individual Savings Accounts (ISAs) and Self Invested Personal Pensions (SIPPs) and offshore investment-linked life policies.
Services to be provided
The services we provide you with will be in accordance with one of the following categories, which will be agreed with you when opening your account and confirmed by your signing of the relevant client agreement.
We offer two levels of service:
- Execution only
All the services are designed to provide you with choices for your ongoing advice and service. At the time that you instruct your us to implement any of the recommendations then you will be asked to select the level of ongoing service you require.
You will not receive advice or a recommendation from us. We operate an Execution Only service. If you are in any doubt regarding the suitability of an investment you should ask to be referred to an independent financial planner, who are authorised to provide investment advice. Transactions taken out on an execution only basis via Edale will be carried out without advice on their merit or suitability. When buying a contract under these terms, you will not benefit from some of the regulatory protection provided when authorised advice is given and you have no right to redress should the contract turn out to be unsuitable.
To help guide our clients we provide web-based tools and issue product information, independent investment research, market commentary and example portfolios. In providing these we are not giving you personalised advice.
It is important that you read the Product Provider’s Key Features Document carefully and we would particularly draw your attention to the section on Cancellation and Withdrawal Rights. Please note that as you are investing as an Execution Only client your cancellation and withdrawal rights may be affected.
With an advisory service, we accept responsibility for advising you as to the merits of any particular investment based on the information supplied by you in the application form pertaining to your individual circumstances, requirements and objectives. We may provide you with investment advice on your request. Information supplied by you, via the application form should be updated as necessary before we give you advice on a particular transaction. If you do not inform us of any investment or types of investments, which you do not wish us to recommend or purchase for you, we may recommend to you any investments provided that we have reasonable grounds for believing that each investment product we do recommend is suitable and appropriate for you, in accordance with FCA rules.
We will advise and make a recommendation for you however under this service we only offer products and services from our chosen product providers. Therefore this is defined as ‘restricted advice’ by the FCA.
Edale does not handle clients’ money. We never handle cash or accept a cheque made out to us, unless the cheque is in settlement of charges or disbursements for which we have sent you an invoice.
When we have arranged any investments or policies for which you have given us instructions we will not give you any further information unless specifically agreed.
Advice and Instructions
We prefer our clients to give us instructions in writing, to aid clarification and avoid future misunderstandings. We will, however, accept oral instructions provided they are confirmed in writing. We may, at our discretion, refuse to accept instructions although such discretion shall not be exercised unreasonably. We will record all transactions on our files which, along with copies of relevant documentation, will be retained by us for a period of not less than six years. You have a right to inspect copies of contract notes, vouchers and entries in our books or computerised records relating to your transactions. We reserve the right to withhold copies of these records if information to other parties would be disclosed.
In transmitting investment applications on your behalf to third parties, we will take all reasonable steps to ensure that we obtain the best possible result for you. This is referred to as ‘best execution’. A copy of our best execution policy is available on www.edale.co/terms.
Paying for services
Not all firms charge for services in the same way. We will discuss your payment options with you and answer any questions you have. We will not charge you anything until you have agreed how we are to be paid.
We may charge an initial fee or an ad-hoc fee as permitted by the Product Provider or agreed directly with you. A Service Charge and or an Advisory Fee which is determined by the value of the funds on which the service is required. These fees are shown below:
Upto 1.00% per annum Service Charge calculated and paid quarterly using the value of the fund.
Examples of the Standard Service Charge:
Value of funds £20,000 the fee is £16.66 per month / £200 per annum
Upto 1.00% per annum Advisory Fee calculated and paid quarterly using the value of the fund.
Examples of the Standard Advisory Fee:
Value of funds £20,000 the fee is £16.66 per month / £200 per annum
In addition to the Fees above you could have charges to pay from the Funds and/or product provider. Details on the charges will be shared with you along with the Client Agreement.
Paying via the product & product provider: The client agrees that the Firm can receive the Service Charge or Investment Advice Fee from the Product Provider for the full amount determined above. The amount payable will reduce or increase in line with the value of the investments. The client may be required to complete a provider instruction should the client wish to pay fees in this way.
By agreeing to this method of paying the fee, you authorise the Product provider to sell units/shares from the fund and pay Edale to satisfy the Service Charge or Advisory Fee.
Edale may, from time to time, receive fees from product providers for advertisements in the company brochure, bulletins, website or other material. The existence of an advertisement should not be taken as an endorsement of any particular product by Edale.
At the point the firm receives written confirmation that the Client no longer requires the services of Edale, the Firm will ensure that the Service Charge ceases.
The purpose of the Service Charge is intermediation whereby the Firm acts on behalf of the Client with the provider. This may include but is not limited to: provide web-based tools and issue product information, independent investment research, market commentary and example portfolios.
Right to Cancel
We will inform you of your statutory right to cancel.
If you wish to register a complaint, please write to The Compliance Manager, Edale, 15 Bell Street, Reigate, RH2 7AD or telephone 0207 99 35 360. If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.
We are covered by the Financial Services Compensation Scheme (FSCS) if we cannot meet our obligations. This is dependent upon the type of business and the circumstances of the claim. Most types of investment business are covered up to a maximum limit of £50,000. For non-advised investment services an investor may not have access to FSCS, however, they would have access via the product provider, should the product provider default.
Conflict of interests
We will endeavour always to act in the best interests of you our client. However, circumstances can arise where we or one of our other clients may have some form of interest in business being transacted for you. If this happens or we become aware that our interests or those of one of our other clients conflict with your interests, we will write to you and obtain your consent before we carry out your instructions, and detail the steps we will take to ensure fair treatment.
The information you have provided is subject to the General Data Protection Regulation that replaces the Data Protection Act 1998 in the UK (the “Act”). By doing business with Edale you consent to us or any company associated with us for processing, both manually and by electronic means, your personal data for the purposes of providing administration and management.
“Processing” includes obtaining, recording or holding information or data, transferring it to other companies associated with us, product providers, the Financial Conduct Authority or any other statutory, governmental or regulatory body for legitimate purposes including, where relevant, to solicitors and/or other debt collection agencies for debt collection purposes and carrying out operations on the information or data.
We may also contact you or pass your details to other companies associated with us to contact you (including by telephone and email) with details of any other similar products, promotions, or for related marketing purposes in which we think you may be interested.
If at any time you wish us or any company associated with us to cease processing your personal data or sensitive personal data, or contacting you for marketing purposes, please contact The Data Protection Officer on 0207 99 35 360 or in writing at 15 Bell Street, Reigate, RH2 7AD.
You may be assured that we and any company associated with us will treat all personal data and sensitive personal data as confidential and will not process it other than for legitimate purposes. Steps will be taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary. Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to the data.
Subject to certain exceptions, you are entitled to have access to your personal and sensitive personal data held by us. You may be charged a fee (subject to the statutory maximum) for supplying you with such data.
What Are Cookies
For more general information on cookies see the Wikipedia article on HTTP Cookies.
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the this site. Therefore it is recommended that you do not disable cookies.
You can learn how to manage cookies on your web browser by following the Browser Cookies Guide.
The Cookies We Set
- Email newsletters related cookiesThis site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
- Forms related cookiesWhen you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
- Site preferences cookiesIn order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.
Third Party Cookies
- This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.For more information on Google Analytics cookies, see the official Google Analytics page.
- The Google AdSense service we use to serve advertising uses a DoubleClick cookie to serve more relevant ads across the web and limit the number of times that a given ad is shown to you. For more information on Google AdSense see the official Google AdSense privacy FAQ.
Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. This Cookies Policy was created with the help of the Generator of GDPR Cookies Policy.
However if you are still looking for more information then you can contact us through one of our preferred contact methods:
- Email: email@example.com
- Phone: 02079935360
We treat older and vulnerable clients, their families and representatives with additional consideration by being sympathetic and sensitive to any issues they may have by ensuring our staff treat client’s with dignity, kindness and respect at all times.
To achieve this goal we have procedures to support these clients and summarise these below
- We take steps to understand any capacity or physical limitations such as mobility, hearing and visual impairments. These are taken into account when meeting and communicating with clients. The pace and duration of meetings are aligned to the needs of the client.
- We will take extra care to explain and ensure that the client and their representatives understand our recommendations.
- We recommend a trusted friend or members of a client’s family are present during meetings and conversations involving financial advice. A record of the persons present is confirmed in our recommendations. If there is no family or trusted friend the client can elect to have a solicitor, accountant or other professional to be present.
- We may need at some point to see the client alone and will do our utmost to make sure they the client feels at ease and understands why it is necessary to meet them alone.
- Where financial terminology has to be used we will take care to ensure our client understands and use plain English where possible. We will not proceed until we are satisfied that our client is comfortable.
- We will write any factors related to age or vulnerability in our notes and record them in our recommendations. We shall report the client’s situation and requirements in our recommendation to ensure we have understood the client. We encourage feedback, add any additional information and make corrections if necessary.
- We are sensitive to the possibility of discomfort where a client does not have a current passport or driving license. We will take extra care to not cause embarrassment while needing to complete our money laundering requirements. We can often confirm identity and address with electronic database checks, after getting the clients permission.
- Anyone acting in a capacity for the client shall be asked to produce ID to be verified and also show any Lasting Powers of Attorney (or Enduring Powers of Attorney) in order to verify their entitlement to act.
- Documentation can be produced in a larger print if requested.
- We can accommodate meetings at the client’s home or our offices that do have stairs but we can meet at a location near our office that has better access and suitable facilities for older and vulnerable clients. We can also meet at a third party premises if convenient.
We are advocates for financial literacy and making a financial plan and in an ideal world we would like to help everyone but we need to make a profit to survive and protect our long-term future so will support clients where we feel we can do so conscious of our costs and goals. Where additional costs will be incurred for a client we shall make them aware prior to commencement of any work.
Edale of 33 Kings Avenue, Redhill, RH1 6QH whom can be contacted at 0207 99 35 360 who has our principal place of business is 15 Bell Street, Reigate, RH2 7AD hereinafter referred to as ‘Edale’ or ‘we’ have created this privacy statement (‘Statement’) in order to demonstrate our firm commitment to the privacy of the details that you provide to us when using Site and the Edale Services. In this Statement, references to ‘you’ and ‘your’ are references to the Edale User who may or may not be a registered Edale Client. When you use the Site, you are consenting to the practices set forth in this Statement.
Your acceptance of the statement
This Statement governs your use of the Site and Edale Services, including any dispute concerning privacy. By using the Site and the Edale Services, you accept this Statement in full. You should read the Statement carefully and ensure that you understand its effect before proceeding to use the Site. We reserve the right to modify this Statement at any time due to a change in the law or otherwise without notice by posting the changes on this page. your continued use of any portion of the Site following the posting of the updated Statement will constitute your acceptance of the changes. If we make any material changes, we will notify you by email.
Collecting your data
As part of the process of using the Site and the Edale Services, we may collect certain data from you including but not limited to
- your contact details upon registration to become a client including your first and last names, email address and other account details including nationality and tax identification numbers e.g. National Insurance number;
- Information required to create your client file and login;
- ‘Customer Due Diligence information, such as identification documents or other verification documents, as well as information in relation to or documents to evidence your source funds or wealth;
- your visits to the Site, the resources and Edale Content that you download;
- Information that you provide to us by written communication by post or email;
- Information that you provide to Edale or Edale employee or affiliate;
- Information that you provide to us when we speak to you by telephone. we may keep a record of the information that you share with us;
- Information that you provide to us by completing surveys; and,
- Details of investments you carry out as a Edale client through the Site and Edale Services and the information we provide to your Representative with your approval.
Other de-personalised data which does not record Personal Data as such, rather information such as the date of the visit to the Site, the path taken, the browser used, the IP address etc is used primarily to aid the technical administration of the Site, to better understand how the Site is functioning for visitors and clients and to draw conclusions upon demographic information.
How is your data used?
You acknowledge that your Data may be used by Edale to contact client by post, phone or by electronic mail when necessary in connection with Edale Services, the Edale advice process and the investment process in general.
From time to time, Edale may contact you by electronic mail by way of sending you periodic marketing emails with the latest ideas, updates, investment news and advice or any other newsletter or information or offers regarding upcoming products, promotions, services, specific events, case studies or customer surveys. we will not e-mail you for marketing purposes unless you have given us your consent to do so or if we have a legitimate interest in doing so (for example, if we already have a relationship with you as a customer and we are letting you know about a similar product to one previously purchased).
If Data has been passed to third parties with your consent, you may need to contact them separately if you change your mind in relation to their use of your Data.
In order to provide the Edale Services we may need to:
- communicate with a Company’s owners, officers and employees (“Company’s Contacts”) in relation to the services;
- process identification details of clients and counterparties in order to confirm their identities;
- check such Personal Data against databases of individuals who are subject to sanctions, classified as “politically exposed persons” or have committed crimes and to follow up any suspicions to ensure that Edale complies with its anti-money laundering and terrorism obligations and to avoid fraud itself;
- record or monitor communications as set;
- use such Personal Data to meet the Investment Adviser’s compliance and regulatory duties; and /or
- transfer such Personal Data outside the European Economic Area and the UK and disclose it to antifraud organisations and law enforcement or regulatory agencies anywhere in the world, and Edale will be acting as a data controller in respect of such processing.
Who has access to your data?
To minimise the risk of unauthorised access to your Data, we use some of your Data to authenticate you when using the Site. For our daily operations, we use the services of third parties to provide some of our business and operational functions. Some of these services are provided by our affiliates or partners. For the avoidance of doubt, your Data is used solely by Edale (and its group companies and the partners) for the sole purpose and to the extent necessary to enable Edale to effectively provide you with all the functionality required by the Edale Platform throughout the life of the investment process) and is not shared with any person or company without your express consent. Any Data that is held with Edale shall be retained in accordance with the General Data Protection Regulation that replaces the Data Protection Act 1998 in the UK and related legislation and/ or our retention and destruction policy culminating in its permanent deletion.
Disclosure of your data in compliance with laws
You should be aware that we may release your Data when we believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which you transacted with Edale or an Edale Partner, or to protect the rights, property or safety of Edale, Edale Clients or third parties. This includes any requirements of the Financial Conduct Authority (“FCA”).
Transfer of your data outside of the EEA
From time to time, we may transfer your Data to a related company, agent or contractor in order to improve our services or to assist our security, credit risk or fraud protection activities. Such companies may be located outside of the EEA and you consent to the transfer of your Data to such companies for the purposes set out here in accordance with this Statement and as permitted by the Data Protection Legislation from time to time.
Transfer of data in the event of the Edale
In the event that Edale is sold or transfers some of its assets to another party, your Data could be one of the transferred assets. If your Data is transferred, its use will remain subject to this Statement. your Data will be passed on to a successor in interest in the event of a liquidation or administration of Edale.
Other sites and their Privacy Policies and Cookie Policies
The Site may contain links to other websites. Edale is not responsible for the privacy practices or the content of such websites or for the privacy policies, cookie policies and practices of other third parties, so you should be careful to read and understand those website policies independently.
Security of your data
We endeavour to take all reasonable steps to protect your Data, including the use of encryption technology. When you enter sensitive information such as bank account information, we encrypt the transmission of that information using secure socket layer technology (SSL). However, we cannot guarantee the security of any Data you disclose online. In using the Site, you accept the inherent security implications of engaging in transactions over the Internet, and you agree that you will not hold Edale responsible for any breach of security unless we have been grossly negligent or in wilful default. If you have any questions about security on our Site, you can contact us at firstname.lastname@example.org. you acknowledge that email messages sent over the internet are not encrypted and are not secure. Despite efforts to protect your Data, we cannot ensure or warrant the security of any Data you transmit to us, via, to, or from our Site. you accept that Edale cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. you transmit all such Data at your own risk.
Communications between you and Edale
We may intercept, record and/or monitor any communication(s) (including telephone calls or other electronic communications) between you and us. we may do so in order to resolve queries in the future and for the purposes of ensuring security, staff training and complying with our regulatory and legal responsibilities.
If you do not wish to be contacted by Edale in respect of future marketing communications (excluding any mandatory communications which are a necessary part of being an Edale client which cannot be opted out of), we will give you the opportunity to unsubscribe to the receipt of such communications in every electronic mail communication that we send you.
In the event that either you or we fail to exercise any right or remedy contained in this Statement, that does not mean that you or we (as applicable) have waived that right or remedy and so shall not be construed as a waiver.
If you wish to register a complaint, please write to The Compliance Manager, Edale, 15 Bell Street, Reigate, RH2 7AD or telephone 0207 99 35 360. If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.
Choice of Law
This Statement shall be governed by and construed in accordance with the laws of England and Wales.
You agree to submit to the exclusive jurisdiction of the courts of England and Wales. This means that if you want to bring a legal action against us, or we want to bring a legal action against you, it must be done in one of these courts.
The adoption by the UK of the Markets in Financial Instruments Directive (MiFID), a European directive which aims to harmonise the operation of financial markets across Europe, requires that we provide clients with information concerning our execution policies in respect of transactions we undertake on your behalf.
The overriding requirement is that we must take all reasonable steps to
obtain the best possible result, taking into account the following:
• Likelihood of execution
• Settlement, size
• Any other consideration relevant to the execution of the order
For retail clients price will normally be the most important aspect in obtaining the best possible result. EDALE will therefore assume that the best available price is the most important outcome for your transaction unless you specify at the time of dealing that another factor is of greater importance.
In some circumstances, for some clients, orders, financial instruments or markets, we may determine that other Execution Factors are more important than price in obtaining the best possible execution result.
We will determine the relative importance of the Execution Factors by using our commercial judgement, experience in the context of market conditions and information available to us, and taking into account the Execution Criteria.
EDALE will take all reasonable steps based on those resources available to us to satisfy ourselves that we have processes in place that can reasonably be expected to lead to the delivery of best execution of your orders, we cannot guarantee that we will always be able to provide best execution of every order executed on your behalf.
In executing your order we:
• May use a third party broker to execute your order;
• Will not trade as Principal
• May trade as agent.
The execution venues we may use will be Regulated Markets including the London Stock Exchange and Plus markets plc, Multilateral Trading Facilities (MTF) and Retail Service Providers (RSP). However we reserve the right to use other venues if the nature of the order requires us to do so.
Generally orders will be executed where possible via the RSP network and our systems will poll for the venue that is providing the best price at that time. If the order falls outside certain size criteria set by the RSPs then the order may need to be dealt over the telephone and will be executed on the venue that provides the best overall result.
All the above orders will be deemed as executed ‘on exchange’ and will be reported as required to a regulated exchange.
To the best of our ability we will not execute transactions in shares that are capable of being executed on a regulated market or MTF, away from these venues. However you hereby accept that in certain circumstances it may be necessary for us to do so. These transactions are known as Over The Counter (OTC) trades.
Where available we may cross a client’s order with that of another opposing client.
Dealing in Collective Investment Schemes
When we deal in collective investment schemes (Unit Trusts and OEICs) we will deal directly with the fund manager. Unit trust and OEIC providers generally calculate their prices once a day (in accordance with FCA regulations).
Use of Third Parties
Our terms and conditions with our counterparties provide that they will make all reasonable efforts to provide best execution when we instruct transactions through them.
If a client provides us with a specific instruction to deal for them it may prevent us from following our Order Execution Policy which is designed to get the best overall result for the execution of orders on a consistent basis.
Clients will be able to place limit orders in the market only. These orders will either be left with the market to execute and will be ‘good for the day’ or will be placed on an electronic trading facility of the Regulated Market.
Monitoring & Review
Edale regularly reviews its Order Execution Policy and may add to or remove the venues where we execute our trades without reference to you. Full Details of the execution venues currently employed by us will be made available upon request.
Edale is required by the Markets in Financial Instruments Directive (MiFID) which has been adopted into UK legislation, to provide you with a summary of our arrangements to manage our Conflicts of Interest, should they arise.
We are therefore required to:
Take all reasonable steps to identify conflicts of interest between (i) EDALE or a linked entity and its clients or (ii) one client and another.
Maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps designed to prevent conflicts of interest from constituting or giving rise to a material risk of damage to the interests of our clients.
Where Edale produces “externally facing” investment research, put in place appropriate information controls.
Disclose the general nature and/or the sources of the conflicts of interest for the client, where the arrangements to manage a conflict of interest are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interests of a client will be prevented.
Identification of Conflicts
When identifying potential conflicts of interest, EDALE will take into account whether the firm or an employee:
- Is likely to make a financial gain, or avoid a loss, at the expense of the client.
- Has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome.
- Has a financial or other incentive to favour the interests of another client or group of clients over the interests of the client.
- Carries on the same business as the client.
- Receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monies, goods or services, other than the standard commission or fee for that service.
Management of Conflicts
Edale maintains a number of policies and procedures, which includes a documented policy of independence, which applies whenever its employees provide advice to any of our customers or recommend a transaction. This requires employees to disregard any interest in the transaction that they or EDALE may have, in order to ensure that our clients are given suitable advice.
We also maintain physical separation between various group companies.
Where it is not practical to effectively manage such conflicts we ensure that they are properly disclosed to customers, and we will decline to act for customers should it be necessary.
These are the arrangements we have in place to restrict access to information held in one part of the business from employees in other departments. Our Chinese Wall Procedures sets out in detail the restrictions that are in place to restrict, control and manage the flow of information between group connected companies.
This includes a physical restriction on the staff allowed access to certain parts of the organisation and includes restrictions on access to the data held within various group companies, divisions or departments. The procedures dictate that those staff who are required to be involved in any transaction will be privy to information or ‘brought over the Chinese Wall’. All staff are prohibited from disclosing information except as detailed in the procedures.
Personal Account Dealing
Personal Account Dealing by EDALE personnel must be in strict compliance with our policies and procedures to ensure adherence with all relevant regulation and legislation, both for the benefit of clients and the protection of employees. The procedures are to ensure that employees’ interests do
not conflict with those of our clients and adherence with these is strictly monitored.
EDALE remuneration policies are designed to reflect employees experience and performance, balanced with the requirement to ensure that their remuneration does not conflict with their obligations to our clients. Where employees’ remuneration reflects an element of commission received for transactions undertaken for clients, procedures are in place to monitor the suitability of their recommendations.
The giving or receiving of gifts or other inducements may compromise or conflict with the recipient’s obligations to his clients. Therefore employees are required to comply with our strict policy regarding the reporting and approval of all gifts and hospitality.
Employees are required to notify the company of any outside interest. Any disclosed outside interests will be reviewed by the Head of Compliance and if necessary reported to the CEO who will consider the potential for conflicts of interest before permitting the continuance of any such outside interest.
All policies and procedures for identification and management of conflicts of interest are, as a minimum, subject to annual review and any significant issues will be reported to the Management Executive Committee and to the Board as necessary.
The risks listed below are the main risks to your investment, fund or mandate (the “Portfolio”).
Investors should be aware that other risks may also be relevant to their Portfolio from time to time.
This section explains some of the risks that apply to the Portfolio. It does not purport to be a complete explanation and other risks may also be relevant from time to time. In particular, the Portfolio’s performance may be affected by changes in market and/or economic and political conditions, and in legal, regulatory and tax requirements. No guarantee or representation is made that the investment program will be successful and there can be no assurance that the Guidelines will be attained. Also, past performance is no guide to future performance, and the value of investments may go down as well as up. Changes in rates of exchange between currencies may cause the value of a Portfolio’s investments to diminish or increase.
Edale or Portfolio’s may be exposed to operational risks, being the risk that operational processes, including those related to the safekeeping of assets, valuation and transaction processing may fail, resulting in losses. Potential causes of failure may arise from human errors, physical and electronic system failures and other business execution risks as well as external events.
Foreign markets will involve different risks from the European markets. In some cases the risks will be greater. The potential for profit or loss from transactions on foreign
markets or in foreign denominated contracts will be affected by fluctuations in foreign exchange rates.
Under certain trading conditions it may be difficult or impossible to liquidate a position. This may occur, for example, at times of rapid price movement if the price rises or falls in one trading session to such an extent that under the rules of the relevant exchange trading is suspended or restricted. Use of stop loss order or Limit Order will not necessarily limit
your losses to the intended amounts, because market conditions may make it impossible to execute such an order at the stipulated price.
Shares, known as equities, represent a portion of a company’s share capital. The extent of your ownership in a company depends on the number of shares you own in relation to the total number of shares in issue. Some shares are bought and sold on stock exchanges and their values can go down as well as up in line with market conditions. These shares are termed “quoted”.
In respect of unlisted shares or shares in small companies, there is an extra risk of losing money when such shares are bought or sold. There can be a big difference between the buying and
selling price of these shares. If they have to be sold immediately, you may get back much less than you paid for them. Shares in companies incorporated in emerging markets may be harder to buy and sell than those shares in companies in more developed markets and such companies may also not be regulated as strictly.
Investing in shares that are concentrated in a specialist sector is considered to be a higher risk strategy, due to the concentrated exposure to the market sector in question. Whilst such
investments may offer greater returns over the long term, this can be coupled with the risk of higher volatility.
Collective investment products
Collective investment products include investment trusts, unit trusts, open ended investment companies (OEICs), real estate investment trusts (REITs) and exchange traded funds (ETFs)
which are deemed to be ‘qualifying’ under the Undertakings for Collective Investment in Transferable Securities directives (UCITS).These are all investment vehicles that invest their assets
in the securities of other issuers, or in cash, in accordance with their own internal rules. Whereas investment trusts and REITs are listed companies with their shares traded on the stock exchanges, unit trusts and OEICs are not traded on a stock exchange, but are traded through the manager of the product. Investment trusts and REITs may trade at a discount or premium to the cumulative value of their underlying investments, depending on the demand for their shares. Unit trusts and OEICs are usually priced daily using a set formula based on their net assets minus charges. Some collective investment products may specialise in certain countries or sectors and you should read the terms of any key features document carefully before deciding on an investment.
As with individual equities, the value of your investment can go down as well as up and you might not get back the original amount you invested. Any income you receive from your investment in a collective investment scheme may vary with the dividends or interest paid by the underlying investments and so could fall as well as rise. Collective investment products that focus on a country, sector or market index may display greater volatility than the wider market and so should be considered as higher risk than more widely invested collective investment products. All investment in collective investment products carries a degree of risk. You will be provided with a key investor information document and/or a simplified prospectus for all UCITS qualifying collective investment products that you want to trade with us. The documentation will be available on our website as part of the trading process. You should read these documents carefully prior to purchasing a collective investment as they include full details of the particular risks relating to the product. It is your responsibility to ensure that you fully understand the contents of the documentation provided and if you are in any doubt you should seek professional advice.
Edale is committed to eliminating all forms of bribery, fraud and corruption by having adequate prevention measures in place. All suspicions of bribery, fraud or corrupt practise will be investigated and there will be no distinction made in investigation and action between those that generate financial benefits and those that do not. Any investigation will not compromise the firm’s commitment to Equal Opportunities or the requirements of the Human Rights Act. The firm advocates strict adherence to its anti-fraud framework. The firm will not tolerate bribery,
fraud or corruption by its employees, employees, suppliers, contractors or partners.
This summary Policy is intended to provide a clear statement of intent and responsibilities for:
(a) Preventing bribery, fraud and corruption and
(b) The investigation, reporting and handling of alleged irregularities
This Policy outlines the firm’s commitment to eliminating fraud and corruption, whilst creating an anti-fraud culture and maintaining high ethical standards so as to protect public money.
The Policy is based on a series of comprehensive and inter-related procedures, designed to prevent, detect and deter fraud and to take effective action against any attempted or actual fraudulent act affecting the firm. These procedures will keep pace with any future developments in both preventative and detection techniques regarding fraudulent or corrupt activity that may affect the firm’s operations.
CORPORATE FRAMEWORK AND CULTURE
The prevention and detection of fraud and the protection of money are responsibilities of everyone, both internal and external to the organisation. The firm expects that Members and officers at all levels will lead by example in ensuring adherence to legal requirements, contracts procedure rules, financial procedure rules, codes of conduct and best practice. They are positively encouraged to raise any concerns regarding fraud, immaterial of seniority or status in the knowledge that any such concerns wherever possible, will be treated in confidence.
The firm believes that maintaining a culture of honesty and openness is a key element in tackling fraud. The overall culture supports intolerance stance towards fraud, bribery and corruption. Failure to uphold these Codes will be considered as detrimental to the aims of the firm and will lead to the appropriate action being taken against those concerned.
PREVENTION AND RESPONSIBILITIES
The firm recognises that incidences of fraud and corruption are costly, both in terms of reputational risk and financial losses. The prevention of fraud is therefore a key objective of the authority and respective roles and responsibilities are outlined below.
A key preventative measure in dealing with fraud is to take effective steps at the recruitment stage. These will be to establish, as far as possible, the previous record of potential staff, in terms of their honesty and integrity. In this regard, temporary, casual and agency staff should be treated in the same manner as permanent officers.
Staff recruitment will be undertaken in accordance with the firm’s policies for Recruitment and Selection. Whenever possible, written references should be obtained regarding the known honesty and integrity of potential members of staff, before formal employment offers are made.
For all appointments to posts where the employee will:-
– have access to corporate computer systems or be required to order goods or authorise invoices or
– be required to handle cash or cheques or negotiate contracts for the supply of goods or services or for any other post which the responsible Director considers appropriate. Disclosure and Barring Service (DBS) checks are undertaken for employees deemed to be working in appropriate roles.
All staff must abide by the firm’s Code of Conduct for Officers, which sets out requirements on personal conduct. All professional staff are expected to follow the codes of conduct laid down by their respective professional institute or trades body.
The firm recognises that staff are often the first line of defence in preventing fraud. The Financial Procedure Rules place responsibility for fraud prevention on all employees and all employees of the firm have a duty to assist with an investigation. They are expected to conduct themselves in ways which are beyond reproach, above suspicion and fully accountable.
Employees are expected to be aware of the possibility that fraud, corruption and theft may exist in the workplace and be able to share their concerns with appropriate officers.
The firm has in place disciplinary procedures for all employees and these will be used to facilitate a thorough investigation of any allegations of improper behaviour by employees. Those found to have committed any acts of misconduct will face disciplinary action. Where criminal activity is suspected or found, the matter will be referred to the police for investigation and possible prosecution, in accordance with the Criminal Acts Procedure. In addition, the firm will pursue recovery for any financial loss.
Internal Control Systems
The firm has Financial and Contract Procedure Rules, Accounting Procedures and various rules and codes of conduct in place. Staff are required to comply with this best practice when dealing with the firm’s affairs.
The firm’s aim is to have sound financial systems and procedures, which incorporate efficient and effective internal controls. Effective role separation will guarantee decisions made are seen to be based upon impartial advice and ensure that no single individual has complete authority over one transaction. Directors and Assistant Directors are responsible for maintaining effective internal controls including the prevention and detection of fraud and other illegal acts. The firm’s internal auditors will monitor and report upon these controls.
REPORTING, DETECTION AND INVESTIGATION
It is the responsibility of Directors and Assistant Directors to maintain good control systems and ensure that all staff complies with these systems.
Reporting suspected irregularities is essential to the Anti-Fraud and Corruption Policy and ensures:
– consistent treatment of information regarding fraud and corruption
– proper investigation by an experienced team
– the optimum protection of the firm’s interests
Although this document specifically refers to bribery, fraud and corruption, it equally applies to any forms of malpractice that can reduce public confidence in the firm and its services and may also include acts committed outside of official duties but which impact upon the firm’s trust in the individual concerned. As part of the culture, the firm will provide clear routes by which concerns can be raised by both Members and officers and those outside who are providing, using or paying for services. Staff will report any irregularities to a Director. The Director will determine if an investigation is necessary. The Director will decide whether to involve the Police in cases where an offence is suspected. Every concern raised will be centrally and formally recorded.
There are a number of ways in which we seek to deter a bribe or potential fraudsters from committing or attempting fraudulent or corrupt acts, whether they are inside or outside of the firm, and these include:
– publicising the fact the firm is firmly set against fraud and corruption and states this at every appropriate opportunity, e.g. statements in contracts, on claim forms, on the firm’s website and in publicity literature both internal and external.
– acting robustly and decisively when fraud and corruption is suspected and proven, to deter others from committing offences against the Authority, e.g. the termination of contracts, the dismissal and/or prosecution of offenders
– taking action to effect the maximum recoveries for the firm, e.g. through agreement, court action, penalties, insurance, superannuation etc
– having sound internal control systems, that still allow for innovation and calculated risk, but at the same time minimising the opportunity for fraud and corruption.
This summary policy will be reviewed at appropriate times in response to procedural and legal changes.
No Initial Advice Cost
The Voucher cost will be refunded to the Qualifying client’s card that purchased the voucher within 1 month after the Investment Period (“qualifying refund”) where the client opens a new account(s) and invests in GBP investment products.
Clients may only use our Offer in good faith for simple financial purposes. You may not:
– use the voucher for more complex advice. Complex advice consists of pension carry forward, pension consolidation, ISA transfers, etc.
Purchasing the voucher means Edale shall waive its initial fees for UK clients that use the voucher to open an invstment account. Initial fees are fees that are agreed with the client and usually charged to setup, advise and recommend investment products. For qualifying investors Edale waives its initial fees during accounts opened during the invstment period. Ongoing and ad hoc fees agreed with the client remain payable. Product and fund charges from third parties and out of Edale control are also payable.
Edale reserves the right to:
amend, alter or change the Offer at any time, without notice; and
terminate the Offer at any time, without notice.
In the event the Offer is terminated, Edale will not be obliged to complete any transactions that would have otherwise qualified for the Offer.
We will determine, in our sole and absolute discretion, whether there has been a breach of this Agreement. When a breach of this Agreement has occurred, Edale may take such action as we deem appropriate, including (but not limited to) termination of this Agreement, closing your account(s), closing third party account(s) and suspending the Offer.