Client Protection

S&T Asset Management LLP (“S&T”) is authorised and regulated by the Financial Conduct Authority which is located at 25 The North Colonnade, Canary Wharf, London, E14 5HS (“the FCA”) and as such is regulated by the FCA in the conduct of its designated investment business under the Financial Services and Markets Act 2000 (“the FSMA”). S&T is entered on the Financial Services Register under registration number 501695.

S&T outsource all its safe custody (nominee) settlement and cash management to Pershing Securities Limited (“Pershing”), affiliated to Pershing LLC, a subsidiary of Bank of New York Mellon corporation. Pershing is one of the world’s largest providers of back office services to the financial sector.

Conflicts of Interest

A conflict of interest may arise where your interests may conflict with our interest, the interest of a member(s) of our staff or the interests of another client. In accordance with the FCA rules we will take all appropriate steps to identify and to prevent or manage conflicts of interest that may arise in the course of us providing our services. We maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to prevent conflicts of interest adversely affecting the interests of our clients. We have in place a conflicts of interest policy to identify, prevent and manage our actual or potential conflicts of interest, which is regularly reviewed, as well as a supporting register of conflicts. A summary of our conflicts of interest policy is set out below and further details are available on request.

Where the arrangements that we have in place are not sufficient to ensure with reasonable confidence that a risk of damage to you will be prevented we will disclose to you the general nature or sources of the conflict of interest or both and the steps we have taken to reduce the risks before we undertake the business for you.

Third party payments and benefits

In the course of providing our services to you we will not accept or retain any fee or commission from a third party. We may accept and retain minor non-monetary benefits where this is permitted by the FCA rules, for example, the provision of product-specific information from a product provider, participation in training events on the benefits and features of investments and de minimis hospitality or training facilities. We will only accept and retain minor non-monetary benefits where such acceptance would not prevent us acting in your best interests. We will disclose to you generic details of the amount of the minor non-monetary benefits we receive at least annually. Entertainment, hospitality and other inducements which the account executives may receive are recorded in the firm’s minor non-monetary benefits register and each is considered by our compliance department to ensure that it satisfies the requirements to be a minor non-monetary benefit, as described above. As S&T routes all its trades through one venue, PSL (see the best execution policy), there is very little risk that the account executives would be swayed by hospitality. For the avoidance of doubt, any third-party investment research that we receive and retain (apart from any such research capable of constituting a minor non-monetary benefit) will be paid for by us directly from our own resources and we will not operate a research payment account.

Summary of our Conflicts of Interest Policy

Our account executives are required to disregard any interest they have when making personal recommendations or dealing for you under their discretion. Certain account executives are also members of S&T and may indirectly receive increased annual remuneration based on increased profits that we generate. No members of staff share dealing commission and there are is no link between dealing activity and the remuneration staff receive. We have a robust independent compliance function which analyses portfolios and clients annual total expense ratios. Exceptions to a standard set by S&T are analysed by our partners. Our staff members can make personal account transactions. We have a personal account dealing policy of which all staff are aware. All personal trades conducted by staff members are recorded by the compliance department and analysed. Under no circumstances is a member of staff allowed to trade ahead of a live client order. Any recommendations we make will be based on our opinions and we may be influenced by external research; however, we have no ties with research providers meaning a stock is only recommended or traded under a discretionary agreement that we believe at the time

Other examples are that when we recommend a transaction to you or enter into a transaction for you, we or one of our associated companies could be:

  • dealing as a principal for our or its own account by selling the investment concerned to you or buying it from you;
  • matching your transaction with that of another client by acting on that client’s behalf as well as yours;
  • buying or selling units in a collective investment scheme where we are, or an associated company is, a trustee, operator (or an adviser of the trustee or operator) of that scheme;
  • buying investments where we are, or an associated company is involved in a new issue, rights issue, take-over or similar transaction concerning the investment;
  • undertaking designated investment business for other clients;
  • in receipt of instructions from another client to buy or sell the same investments; or
  • acting as an adviser to the issuer of the relevant investments.

Best execution policy

Introduction

When we execute an order on your behalf we are under an obligation under the FCA rules to take all sufficient steps to obtain the best possible result for you taking into account relevant execution factors. In order to comply with our obligations in relation to best execution we have in place a best execution policy. We have provided below a summary of this policy which describes the policy that we have adopted to obtain best execution for you and for acting in your best interests in relation to orders that we place with other parties on your behalf. Full details are available on request. You should read our best execution policy and if there is anything in it which you do not understand you should ask us to explain it to you. By entering into the agreement with us you consent to our best execution policy.

Specific client instructions

If you provide us with a specific dealing instruction it may prevent us from following our best execution policy as we would usually do but, under FCA rules we will be deemed to have satisfied our obligations under our best execution policy to take all sufficient steps to obtain the best possible result for you in relation to that part of the order to which your instructions relate.

Public limit orders

You instruct us, and any third party to whom we pass an instruction on your behalf, not to make public “client limit orders” in shares admitted to trading on a regulated market, multilateral trading facility or organised trading facility which are not immediately executed under prevailing market conditions, except where in our, or the third parties’ discretion, it is in your interest to make public all or part of a client limit order.

Summary of our best execution policy

When dealing on your behalf we will exercise our discretion in assessing the criteria that we need to consider to obtain the best possible result for you.

In our dealings for you as a retail client, the most influential factor in determining our final execution decision will be that of ‘total consideration’; this represents the price of the financial instrument and the costs related to the execution.

Depending on the characteristics of the financial instrument concerned we will also consider the following criteria:

  • Certainty of execution
  • Order size
  • Speed of execution
  • Settlement
  • Any other relevant criteria to the execution of the order.

We transmit all orders to one venue, Pershing Securities (“PSL”) who have demonstrated that they enable us to provide the best possible results for the execution of our clients’ orders on a consistent basis. PSL has access to the widest range possible of venues and markets to provide us with best execution. Additionally, PSL reports to us its results including detailed analysis of each trade placed on our behalf which demonstrate how PSL achieved the best possible result.

The choice of venue we have chosen will be reviewed not less than on an annual basis.

All orders received and decisions to trade will be transmitted to PSL in an orderly, prompt and timely manner. Orders received by post, fax or email will be executed as soon as reasonably possible after receipt of the order.

Instructions received or decisions to trade at a time when the stock market on which the instrument is traded on is closed will be executed as soon as that market re-opens. Dealing instructions can only be considered and dealt with during our normal business hours.

We will aim to place any Unit Trust/OEIC orders received before 10.45am on the same day pricing point. Orders received after 10.45am will (in most cases) be placed at a pricing point of the following business day. Some Unit Trust/OEIC’s may price earlier than midday or on certain days, weeks or months; these orders will be placed for the next available pricing point.

This policy came into force on 3rd January 2018, by instructing us to trade or allowing us to trade with discretion for you on or after this date indicates to us that you agree to this policy. It replaces all previous policies and will be monitored for effectiveness on a regular basis. You will be notified by a durable medium should the policy change in the future.

Monitoring

We will monitor both our compliance with our Best Execution Policy, and the quality of execution of third parties to whom we have passed orders at least annually. We will advise you of any material changes to our Best Execution Policy as necessary.

The FCA rules require that we must obtain your consent to our execution policy. Unless you have provided a written objection to us adopting this policy, we will deem you to have provided such consent for us to continue to trade on your behalf. Should you require any further information or assistance in relation to the Execution Policy please contact your S & T executive.

Complaints

All formal complaints should in the first instance be made in writing to us at 43- 45 Market Street, Marple, Stockport, SK6 7AA. This firm adheres to an internal complaints procedure, a copy of which is available upon request. Complaints will be dealt with in accordance with the FCA rules. You may also have a right to complain directly to the Financial Ombudsman Service. Further information is available on request from us and from www.financialombudsman.org.uk or contact the Financial Ombudsman Service on 0800 023 4567 or 0300 123 9123 or by email at:

complaint.info@financialombudsman.org.uk.