Conflicts of Interest Policy
Who are we?
When we use “we”, “our” or “us” in this notice, we mean one or more of the Succession Group companies listed below:
Succession Jersey Ltd (SJL)
Succession Group Ltd (SGL)
Succession Wealth Management Ltd (SWM). FCA Firm Reference Number 588378
Succession Financial Management Ltd (SFM). FCA Firm Reference Number 225831
Succession Employee Benefit Solutions Ltd. (SEBs) FCA Firm Reference Number 767956
Succession Advisory Services Ltd (SAS). FCA Firm Reference Number 510054
What is a conflict of interest?
Conflicts may arise in a number of ways in the course of our normal business activities. Conflicts arise where the interests of one party could be favoured over the interests of another, for example:
Between different groups of clients,
Between different firms within our Group,
Between the interests of our clients and those of third parties,
Where individuals are providing advice services but have another relationship with the client, i.e., personal relationship, trustee.
We recognise the importance of identifying and understanding such conflicts and ensuring that we appropriately consider fairness between groups before making any business decision. In doing this we will always ensure that in our dealings with our clients and business partners we are:
Clear, transparent and straight forward;
Honest, carrying out our business with fairness and integrity;
Fair and objective in the criteria we apply when awarding contracts and selecting business partners;
Fair and transparent in our treatment of our clients and business partners;
Ethical in the giving and receiving of corporate hospitality and gifts;
Principled in the receipt of confidential information.
We take all reasonable steps to avoid conflicts of interest and, when they cannot be avoided, manage, monitor and (where applicable) disclose those conflicts of interest in order to prevent them from adversely affecting the interests of our clients and fairness of outcomes.
How do we manage and monitor Conflicts of Interest?
As a minimum, we will consider the following factors to identify whether, in providing the service or undertaking an activity, we:
Are likely make a financial gain, or avoid a financial loss, at the expense of a client;
Have an interest in the outcome of a service or transaction provided to a client which is distinct from a client’s interest in that outcome;
Have a financial, or other incentive, to favour the interest of another client, or group of clients, over the interests of a client;
Carry on the same business as a client; or
Receive, or will receive, from a person other than a client, an inducement relating to a service provided to a client, in the form of monies, goods, services, other than the standard commission or fee for that service.
The Compliance Director and where relevant the Board will assess all new identified conflicts and make a decision on whether:
Existing control mechanisms are sufficient to mitigate it;
New/additional controls are required; and
We should disclose the conflict to relevant clients so that they are able to take an informed decision as regards the related service.
Succession has a number of control mechanisms in place to manage potential conflicts of interests. These include:
A suite of policies that all employees must read and adhere to, including a Conflicts of Interest Policy, an Anti-Bribery Policy and a Gifts, Hospitality and Inducements Policy;
Conduct standards requiring all employees to act with the highest standards of integrity to avoid any allegations of conflicts of interest;
Remuneration arrangements designed to ensure that our approach to remuneration does not give rise to conflicts;
A Personal Dealing policy that sets out the conditions under which our staff may engage in investment activity for their own account;
Appropriate restrictions on outside interests, such as directorships of other companies; and
Assurance arrangements to test adherence to company procedures.
We keep and maintain a record of the types of services and activities carried out by group companies, or on our behalf, where a conflict has been identified that may result in a material risk of damage to the interests of our clients. This includes potential and actual conflicts which might arise when providing an ongoing service to our clients.
Disclosure of Conflicts
These arrangements demonstrate that we have taken all appropriate steps to prevent a conflict from adversely affecting the interests of our clients. However, in the unlikely event that a conflict of interest cannot be avoided or managed under these arrangements, we will disclose this to our client(s) before carrying out any business on their behalf.
Succession keeps, and regularly updates a Conflicts of Interest register. Periodic reviews are undertaken to identify any further potential conflicts. On at least an annual basis, and whenever else required, the Conflicts of Interest Policy is reviewed and updated.
Monitoring of adherence to this policy and the procedures in place around conflicts is conducted by Compliance and reported in line with our corporate governance arrangements.
Conflicts associated with the Succession Investment Platform
Succession Advisory Services Ltd (SAS), a wholly owned subsidiary of Succession Jersey Ltd, provides the Succession Investment Platform (SIP). The SIP is made available to clients of Succession Wealth along with a number of other platforms which are subject to due diligence and oversight by Succession Wealth. Whilst SAS shares a number of common directors with other companies within the Succession Group including SWM and SFM, none of our Wealth Planners have any direct financial interest in SAS or the Succession Investment Platform.
The Succession Wealth advice processes and associated quality controls ensure that your Wealth Planner will only recommend that you place assets on the Succession Investment Platform where it is in your best interest to do so and it is suitable for your agreed objectives and needs.
Where appropriate your Wealth Planner may also recommend the 'Succession Powered by 7IM' and/ or the 'Succession Powered by LGT Vestra' range of model portfolio solutions, for which an investment management charge is applied. As with the Succession Investment Platform, these portfolios are provided by SAS. These model portfolios form part of the Succession Wealth investment matrix which is overseen by the Succession Wealth Investment Committee.