Terms of business.
Dentons Wealth outline our Terms of Business with regards to our independent financial planning services, fees, conflicts of interest, cancellation rights and more.
Our Independent services.
1. Dentons Wealth is an independent financial adviser and offers an independent advice service covering the ‘whole of market’ investment products and non-investment products from a range of insurers.
Dentons Wealth is a trading name of Dentons Investment Services Limited who provide independent financial advice for our clients.
Dentons Wealth is authorised and regulated by the Financial Conduct Authority (FCA). The registration details can be checked
on the FCA Register by visiting:
https://register.fca.org.uk/s/firm?id=001b000000MfIewAAF
or by contacting the FCA on 0800 111 6768 and quoting Firm Reference Number 194538.
Dentons Wealth is a trading name of Dentons Investment Services Limited who provide independent financial advice for our clients.
Dentons Wealth is authorised and regulated by the Financial Conduct Authority (FCA). The registration details can be checked
on the FCA Register by visiting:
https://register.fca.org.uk/s/firm?id=001b000000MfIewAAF
or by contacting the FCA on 0800 111 6768 and quoting Firm Reference Number 194538.
2. It is a requirement of the FCA that all our clients are categorised. Unless otherwise agreed, you have been categorised as a “retail client”. This gives you the highest level of regulatory protection. You are able to request a different categorisation and we would advise you of any limitations to your regulatory protection resulting from such a change.
3. We offer an initial meeting for no charge at which we will find out about your aims and objectives and describe our services along with explaining the payment options.
4. Investments can rise and fall and you may not get the full amount you invest returned. Our suitability letter will detail specific risks and provide further information.
3. We offer an initial meeting for no charge at which we will find out about your aims and objectives and describe our services along with explaining the payment options.
4. Investments can rise and fall and you may not get the full amount you invest returned. Our suitability letter will detail specific risks and provide further information.
Disclosure of charges/fees
5. Remuneration for ‘investment’ advice and services provided will be by way of an agreed predetermined fee, which can be timecosted, service-based or, if appropriate, related to the amount being invested. Current hourly rates are £365 for an Adviser; £300 for a Research Analyst and £285 for an Administrator - with an indication of the expected total fee being provided, where possible. Your agreement to incur additional charges will be sought should the time spent exceed the original estimate.
6. A detailed Fee Schedule for specific services and other advisory functions is attached and constitutes part of this document.
7. Where commission is received from a Product Provider - usually for insurance contracts - the amount of the commission received will be credited against the agreed fee. We require payment of fees within 14 days of your receipt of our invoice. We reserve the right to charge interest at 8% pa above the Bank of England Base rate to any balance which is not settled within that timescale. Where advice has been provided, and agreement given to the level of a fee, you will be invoiced even if the advice so provided has not resulted in a specific recommendation or you have decided not to accept a recommendation.
8. We are required to advise you of the possibility that other costs not detailed in the fee schedule, beyond the control of Dentons, which may include taxes, might be imposed with payment of these costs being your responsibility.
9. By signing this Client Agreement and Terms of Business, we will deem this an instruction for us to act on your behalf either for a new contract or for an amendment to an existing contract. For other matters, we will accept written or oral instructions but for the latter will require subsequent written confirmation. We will endeavour to action your instructions as soon as possible and within no more than five working days.
6. A detailed Fee Schedule for specific services and other advisory functions is attached and constitutes part of this document.
7. Where commission is received from a Product Provider - usually for insurance contracts - the amount of the commission received will be credited against the agreed fee. We require payment of fees within 14 days of your receipt of our invoice. We reserve the right to charge interest at 8% pa above the Bank of England Base rate to any balance which is not settled within that timescale. Where advice has been provided, and agreement given to the level of a fee, you will be invoiced even if the advice so provided has not resulted in a specific recommendation or you have decided not to accept a recommendation.
8. We are required to advise you of the possibility that other costs not detailed in the fee schedule, beyond the control of Dentons, which may include taxes, might be imposed with payment of these costs being your responsibility.
9. By signing this Client Agreement and Terms of Business, we will deem this an instruction for us to act on your behalf either for a new contract or for an amendment to an existing contract. For other matters, we will accept written or oral instructions but for the latter will require subsequent written confirmation. We will endeavour to action your instructions as soon as possible and within no more than five working days.
Conflict of interest
10. Occasions could arise where we, or one of our other clients, may have some form of interest in business, which we are transacting for you, or some other conflict of interest. Should this occur, you will be informed in writing and your consent obtained before proceeding.
Your cancellation rights
11. You, or we, may terminate this Client Agreement and Terms of Business at any time without penalty. If provided verbally, notice of termination must be confirmed in writing. Such termination will not affect the completion of any transaction already initiated on your behalf. You will remain responsible for any charges, fees or other disbursements incurred and payable up to, and including, the date of termination.
Documentation
12. We keep records of all our business transactions for a maximum of six years following the end of your business relationship. The information we hold about you can be held both electronically and in paper form. This information will only be disclosed to third parties for the purposes of processing investments, pensions, other contracts of insurance or for the purposes of compliance verification or upon request by any statutory regulatory authority. You (or your agent) may inspect copies of any papers or computer records which relate solely to your own affairs.
13. We may verify your identity electronically when we process new business, when you move house or if your circumstances change. Otherwise, there will be a periodic three year check, or more frequently if required to achieve a positive result, by matching information against information held by Credit Reference and Fraud Prevention agencies to comply with anti-money laundering regulations.
Details of credit histories are not made available to Dentons Wealth and, although the data provider will add a note to your reference file to show that an identity check has been made, it cannot be used for future credit assessment purposes and should not affect your credit rating. We will not share the results of any electronic verification checks with any third parties other than those associated with your investment/pension for purposes of investing your money. A copy of these results will be held on our systems to evidence that your identity has been verified.
Data protection
14. This section explains the terms under which personal information is obtained from you and stored by Dentons Wealth under the new General Data Protection Regulation (GDPR) from the European Parliament that came into effect on 25 May 2018.
15. All the personal data we use is controlled by Dentons Wealth in the United Kingdom. No third parties have access to your personal data unless the law allows them to do so. We have a data protection regime in place to oversee the effective and secure processing of your personal data.
15. All the personal data we use is controlled by Dentons Wealth in the United Kingdom. No third parties have access to your personal data unless the law allows them to do so. We have a data protection regime in place to oversee the effective and secure processing of your personal data.
16. All information at Dentons Wealth is stored on secure servers. All our data transfers to and from authorised third party recipients have built in security features, including encryption, to best protect your personal data. Email communications cannot be secured in such a robust manner, although we do endeavour to supply confidential information in password protected files wherever possible.
17. Your basic personal data will be kept for a maximum of six years following the end of your business relationship.
18. Dentons Wealth will collect sufficient personal information from you in order to satisfy the ‘Know Your Client’ guidelines of the FCA. This includes basic facts such as your name, address, dependents and contact details as well as more subjective information such as your attitude to risk. It will also include health information that is categorised under GDPR as sensitive personal data, for which we will require you to provide your explicit consent. Your personal information will then be used to provide suitable advice recommendations. The lawful basis of the data processing is that you (known as the ‘data subject’) are giving your explicit consent that collection of the data is necessary for the performance of a contract with Dentons Wealth in respect of the products and services provided in accordance with our terms of business.
19. We may share information, including by electronic transfer e.g. email, with other product providers we use and we also have a legal obligation to provide information to government departments and our regulatory bodies, the Financial Conduct Authority (FCA), the Prudential Regulatory Authority (PRA), The Pensions Regulator (TPR), HM Revenue & Customs (HMRC), appropriate Ombudsmen and the Information Commissioner’s Office (ICO). We may also use third party companies to administer and communicate information in respect of our legal and regulatory obligations. Dentons Wealth is a controller and processor of the personal data you provide to us. Our registered office is Sutton House, Weyside Park, Catteshall Lane, Godalming, Surrey, GU7 1XE.
20. Product providers and Investment Managers may administer your investment(s) and provide services from centres in countries outside of Europe that do not always have the same standard of data protection laws as in the UK. However, they are required to put a contract in place to ensure that your information is adequately protected and they will remain bound by their obligations under the Data Protection Act, even when your data is processed outside Europe.
21. In order to advise you, we must obtain certain information from you regarding your financial objectives and your personal circumstances to assess your suitability for particular products and services. We will only advise and make recommendations after we have assessed your needs. If you do not disclose relevant information, this might affect the appropriateness of advice given to you. If at any point you believe information that we retain about you is incorrect, you can request to see this information and have it corrected and possibly deleted. You may also request that your data be transferred to another data controller in a machine-readable format. Providing you with your data information is free of charge, but charges may apply for excessive requests.
Client money
22. Dentons Wealth does not handle clients’ money and will never accept cash, a cheque, or payment by electronic means from you unless it is in settlement of our charges or disbursement for which you have been invoiced.
Consumer Duty
23. Manufacturer or Distributor - under Consumer Duty regulations, as from 31.07.2023, Dentons Wealth is calssified as a manufacturer of its sales process, a co-manufacturer of its central investment proposition with Square Mile, and a distributor of other providers prodcuts and services. In our capacity of manufacturer and co-manufacturer, we have produced our 'Fair Value Assessment' document.
Complaints
24. If you wish to raise a complaint , please write to the Compliance Officer at Dentons Investment Services Limited, Sutton House,Weyside Park, Catteshall Lane, Godalming, Surrey, GU7 1XE or contact us on 01483 521 528. A copy of a summary of our ‘Complaints Procedure’ is available on request at any time, should you ever have a concern or a reason to complain about the advice we have given or the service we have provided.
In the event that we are unable to agree a resolution to a complaint made against us, you may be entitled to refer the matter to the Financial Ombudsman Service (www.financial-ombudsman.org.uk) for their independent review. If you wish to raise a complaint on how we have handled your personal data, you can contact the Director of Dentons Wealth, Sue Stevens, at the above address, who will investigate the matter. If you are not satisfied with our response or believe we are not processing your data in accordance with the law you can complain to the Information Commissioner’s Office (https://ico.org.uk/).
In the event that we are unable to agree a resolution to a complaint made against us, you may be entitled to refer the matter to the Financial Ombudsman Service (www.financial-ombudsman.org.uk) for their independent review. If you wish to raise a complaint on how we have handled your personal data, you can contact the Director of Dentons Wealth, Sue Stevens, at the above address, who will investigate the matter. If you are not satisfied with our response or believe we are not processing your data in accordance with the law you can complain to the Information Commissioner’s Office (https://ico.org.uk/).
Additional protection
25. As a client of an authorised firm, you might be able to receive compensation from the Financial Services Compensation Scheme (FSCS) in the event that we are unable to meet our obligations towards you. Bank and Building Society deposits and most types of investments and mortgage business are covered to a maximum of £85,000. Claims in respect of long-term insurance benefits are protected 100% with no upper limit.
Disclosure
26. The provisions of this Client Agreement and Terms of Business are in force with immediate effect and we reserve the right to make amendments to these Terms of Business for reasons such as, but not limited to, a change in regulation, legislation and increase of fees.
27. We intend to rely on this Client Agreement and Terms of Business and by signing you are confirming that you have read and agreed to the terms, conditions and fees in full. Where you do not understand or require clarification on any point, please ask before signing.
July 2023
July 2023