Company Policies

Treating Customers Fairly (TCF)

We are committed to ensuring that our customers are treated fairly and that the fair treatment of our clients is at the heart of the firm.

We believe that customers are the most important aspect to our business and we endeavour to provide a service that is consistent to what our customer expects.

Our TCF policy is embedded within our firm and covers all aspects of our business from senior management to our client facing staff.

We will always try to ensure that our products and services marketed and sold are designed to meet the specific needs of our individual clients and are in keeping with their investment objectives. Communication with clients will be clear, fair and not misleading and clients will be kept appropriately informed before, during and after the point of sale.

Wherever possible, clients will have access to their portfolios online via a secure internet login so that they have complete transparency of their portfolios.

Our staff will remain at all times trained and competent to do their jobs and deal with customers in a friendly, helpful and efficient manner.

Policies and Procedures

To ensure that the highest standards are maintained we have in place the following policies and procedures:

  • An investment committee and policy which ensures that our defined investment process is followed on the investments that we recommend.
  • An account opening process which ensures that we know our clients and that advice given is suitable for each individual.
  • An inducement policy which ensures that our staff do not receive or give inducements if they are likely to conflict with a duty owed to our clients.
  • A Conflicts of Interest policy which sets out any issues which may have an impact on the independence of advice and any actions taken by the company’s staff and ensures that advice given is clear, fair and not misleading.
  • Chinese Walls exist within the firm to restrict the flow of information between departments.
  • A Personal Account dealing policy which ensures that personal trading does not conflict with customers interests.
  • A Data Protection policy that ensures that the personal and sensitive information held on behalf of our customers is maintained in a secure and confidential environment.
  • Risk warnings that are clear and easy to understand.

Compliance

Cornhill has a dedicated compliance team that monitors communications with clients to ensure that their requirements are being met at all times and that conflicts of interest are appropriately managed.

Independence

Cornhill Capital is completely independent when advising clients meaning that we are not tied to any financial institution, thereby enabling us to source the most appropriate products for our clients from the most reputable third parties.

Confidentiality

Cornhill Capital Limited regards information as proprietary if sharing that information with the public would undermine its competitive position. Proprietary information may include information on products or systems which, if shared with competitors, would render the firms investment therein less valuable. Further, Cornhill Capital Limited regard information as confidential if there are obligations to customers or other counterparty relationships binding the firm to confidentiality. In the event that any such information is omitted, we shall disclose such and explain the grounds why it has not been disclosed.

For the Conflict of Interest Policy click here

For the Execution Policy Notice click here