We are committed to acting at all times in our customers best interests.
With a policy of openness and transparency, any conflicts of interest that do arise are managed without prejudice to the interests of our customers, and we have well-defined internal policies and procedures that are embedded and supported at all levels across the company.
Policy Statements
Hoodless Brennan (HB) has a documented policy of “Treating Customers Fairly” that amongst other things, specifically requires that:
Customers should clearly understand the nature of the services we provide, including our terms, conditions and charges.
Customers must clearly understand the risks inherent in the markets and securities in which they invest through us.
We must communicate in an open, transparent and easily understandable manner and have a clear understanding of Customers investment objectives, investment experience, attitude to risk, financial standing and resources.
We must be clear about the suitability of our recommendations to our customers.
We will not promise to provide services we are not able or equipped to deliver.
Training and Competence programs must embed the concept of “Treating Customers Fairly” within our corporate culture.
Our complaint procedures must be clear, unambiguous and impartial.
We must be able to measure the effectiveness of our policies of treating customers fairly.
Supporting Policies and Procedures
To ensure that the information and investment needs of our customers are properly supported, Hoodless Brennan has, in addition, adopted the following Policies and Procedures:
Conflicts of interest are managed by our prompt and detailed disclosures of risk, and the manner in which we manage potential conflicts of interest. For example:
“Chinese Walls” procedures restrict the flow of sensitive information between departments.
A “Conflicts Management Policy” sets out the controls on how investment research is produced and issued.
A “Policy of Independence” requires staff to act independently of HB’s own interests.
A “Gifts and Entertainment” policy requires staff to observe HB’s restrictions on offering, giving, soliciting or accepting any inducement if it is likely to conflict with any duty owed by HB to its customers;
A “Stock Sourcing Policy” and procedures, ensure that stock acquired by HB offers customers a suitable balance between risk and reward having regard to customers stated risk preferences.
A Personal Account dealing Policy and commission and salary structures that minimize risk of conflict of interest with employees.
A “Compliance Policy” and procedures that detail how we monitor and enforce our policies and procedures.
Communication of information to customers is managed through detailed disclosure:
In Client Information forms.
Terms of Business agreements.
At time of dealing.
In Research notes, contract notes, statements and valuations.
In marketing material and other financial promotions.
In Customer Information Forms.
On HB’s website.
Suitability of recommendations. HB’s internal procedures emphasize the importance of, and specifically require all staff to observe the FSA’s Conduct of Business rules, notably in relation to suitability and advice. This is documented in detailed:
Customer take-on procedures.
Credit Control Policies and procedures.
In-house selling practices and procedures.
Risk disclosures at time of dealing
Monthly reviews of Retail Customer Profiles (RCP’s) and Customer Investment Objectives (CIO), to update customer investment objectives and preferred risk profiles.
Dealing Practices. HB will not accept any selling practices, whether direct or indirect, that unfairly influence customers, or in any way breach HB’s internal policies. The following Principal Dealing policies and procedures in particular document how HB ensures its customers are treated fairly:
On EVERY occasion, Brokers are required to give customers a series of detailed disclosures on the risks of the stock, and any interest that HB may have in the stock.
All principal deals are executed “between the spread”.
“Market size” is tested before any principal dealing commences and no customer will be recommended a position in a size greater than current market size.
Research notes are provided to the Broker to give customers the “house” view of the stock, and then posted on HB’s website.
All calls are taped for monitoring purposes and protection of customers.
These and other terms used in transacting business are contained in our publication titled “A plain English guide to dealings with Hoodless Brennan” which is available on request, and which is also avalaible for download below.
Complaints
HB sets high standards for customer service and satisfaction and has a policy of responding promptly and positively to all customer queries and complaints.
Wherever possible, queries are dealt with to the customer’s satisfaction within one business day.
Where a complaint is received, HB’ policy is to give a detailed response within four weeks wherever possible.
HB aims to compensate customers where grievances are justified, and to communicate clearly our understanding of events where we do not consider compensation is justified.
Where we are aware that a mistake has been made on a customer’s account, HB’s policy is to take prompt action to put the matter right and provide adequate compensation rather than wait for customers to complain.
Details of any complaints received are forwarded to HB’s Board of Directors for prompt consideration and remedial action where necessary.
Compliance Arrangements
HB’s experienced Compliance team carries out detailed daily, weekly and monthly monitoring tests that are reported to the Board on a monthly basis. Examples of the monitoring reports include:
Principal dealing; looking at suitability of trading in terms of investment objectives, risk profile, size and marketability of transaction.
Principal dealing disclosures to customers.
PCP / CIO update reports.
Personal Account dealing by employees.
Insider dealing / watch list reports.
Where the Compliance team has concerns about the suitability of any transaction, it is a requirement that the customer is contacted again by their broker to go through additional risk warnings, and where appropriate, offered the opportunity to cancel the deal.
Any internal training issues identified are acted upon and if the Compliance team continues to have significant concerns, disciplinary action may be initiated, resulting in written warnings and ultimately dismissal if appropriate. Senior Management Oversight. HB’s commitment to its customers is reinforced by the Board, which has full oversight and responsibility for ensuring effective management systems, controls and compliance arrangements.
Full details of the above policies and procedures can be obtained on request by contacting us on 020 7510 1166
The following are examples of the Private Client Profile (PCP) that brokers use to discuss client investment objectives, when an account with us is opened and at regular intervals thereafter, and examples of our dealing tickets, disclosures and the questions a broker works through with a client on every principal trade to ensure the client understands the deal entered into:
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