Conflict of interest
- how we avoid this
Authorisation
2plan wealth management Ltd (2plan) is a firm of national Independent Financial Advisers (IFAs). It is also a “network” and authorises Appointed Representative firms. 2plan is authorised and regulated by the Financial Conduct Authority (FCA) under registration number 461598.
The FCA requires 2plan to take all reasonable steps to manage its confiicts of interests appropriately. Principle 8, of the FCA’s Principles for Business state that a firm must manage confiicts of interest fairly, both between itself and its customers and between a customer and another client.
Conflicts of Interest definition
A confiict of interest arises where a person or organisation is involved in multiple interests, one of which could mean the client’s best interests are not put first, or are different from the interests of the person or organisation.
One Financial Solutions is committed to ensuring its decisions and decision making processes are, and are seen to be, free from any bias and do not unfairly favour any individuals and clients.
At all times, One Financial Solutions conducts its business in accordance with FCA rules and principles, and is committed to effectively managing confiicts of interest fairly between itself and its clients.
At One Financial Solutions, The Board and Senior Management Team are responsible for ensuring that systems, controls and procedures are adequate to manage any confiicts of interest.
Conflicts of Interest policy
All staff, advisers, and management of One Financial Solutions will strive to avoid any confiict of interest between the interests of One Financial Solutions on the one hand, and personal, professional, and business interests on the other. This includes avoiding actual confiicts of interest as well as the perception of confiicts of interest. The purpose of this policy is to protect the integrity of One Financial Solutions’s decision-making process, to enable our stakeholders to have confidence in our integrity, and to protect the integrity and reputation of staff, advisers and management.
In the course of meetings or activities, advisers will disclose any interests in a transaction or decision where there may be a confiict between One Financial Solutions’s best interests and the client’s best interests or a confiict between the best interests of any organisations that the adviser is involved with. This policy is meant to supplement good judgment, and staff, advisers and management should respect this.
Disclosure to clients
Clients are provided with the One Financial Solutions disclosure document before commencing any business relationship. This document is known as the Personal Client Agreement (PCA) and provides notification to clients as to what the process is should any confiict(s) of interest arise.
Remuneration
One Financial Solutions clients are given a choice of how they wish to pay for services from a given menu of options. Both the level of service and the cost is agreed at outset prior to any work commencing.
For investment and pension business payment can only be made by way of a fee, be this fixed, a percentage of the investment amount or an hourly rate. This ensures that there is no bias towards a particular provider or platform.
Alternatively, for an insurance product payment can be made by either commission from the insurance provider, a fee or a combination. Similarly with mortgage cases, a procuration fee would be paid by the lender. These commissions and procuration fees will be disclosed to clients before they proceed.
Compliance procedures
The One Financial Solutions compliance procedures manual confirms that advisers must provide notice of any other business activities they have or wish to become involved with, whether these are a confiict of interest or not.
Advisers and principals (of Appointed Representative forms) must seek approval from 2plan in writing before commencing engagement or with any other business activity or intend to sign any agency agreements, introducer agreements, or set up any other businesses whether financial services related or not.
This ensures that 2plan are aware of any activities that could cause potential confiicts of interests. If potential confiicts of interest may arise then these other business activities will not be authorized by 2plan.
Examples of conflicts of interest
Examples noted below of what could be considered confiicts of interest
- A product provider may offer gifts or entertainment that may infiuence the placement of a product with that particular product provider
- An employee is to make financial gain, or avoid financial loss, at the expense of a client
- An adviser receives a payment from a third party in relation to services provided to the client that is outside the normal commissions or fees for the agreed service
- Advising a client on investments that are not regulated • An adviser who is also on the board of another organisation that is competing for a client
- An adviser who has shares in a business that may profit from unregulated advice
- An adviser passing large amounts of business to a particular insurer because they previously worked at the insurer and still have friends there
- A mortgage adviser passes large amounts of business to a lender because they have a relative working at that lender
- A product provider may offer a loan and cash gift in the expectation of getting more business in return
- An adviser has a financial or other incentive to benefit the interests of one customer over another
- An adviser dealing with both divorced clients
Register
One Financial Solutions maintains an internal confiicts of interest register within which any confiicts are noted.
Identifying conflicts of interest
One Financial Solutions has developed a number of processes to identify potential confiicts of interest. These include at least an annual analysis of the products and providers recommended and the types and amount of remuneration received, in addition to reviewing internal procedures and processes to ensure these remain suitable to ensure any potential risks can be identified.
A central record is also held to log details of where a third party, product provider or fund management group provides training and seminars to advisers.
One Financial Solutions is here to help you.
We advise on a wide range of financial services including protection for both you and your business, general and business insurance, savings and investments, commercial finance, pensions and auto enrolment, employee benefits, profit extraction and mortgages: our aim being to provide you with ‘one solution’ for all your financial needs.
We provide truly independent financial advice, sourced from the whole of the financial marketplace, for individuals and commercial businesses throughout the United Kingdom.
Please call us on 020 3714 9565 for a confidential conversation about how we can help you, or visit our website at
www.onefinancialsolutions.co.uk for more information.
One Financial Solutions is an Appointed Representative of 2plan wealth management Ltd, which is authorized and regulated by the Financial Conduct Authority. One Financial Solutions is entered on the FCA register (www.fca.org. uk) under reference number 607130. Registered office: Chapter House, 33 London Road, Reigate, Surrey RH2 9HZ. Registered in England and Wales, company registration number: 08141263
