Important Information

We believe that our most important responsibility to all our clients is to ensure the safety and security of the assets entrusted to us - both shares and cash.

With this in mind, we have put in place a policy with a major insurance company, which provides substantial protection in addition to that offered by the Financial Services Compensation Scheme (FSCS).

In general terms, as a client you will enjoy the following types of protection of your assets:-

Regulatory Protection

Under the Financial Services Compensation Scheme (FSCS), in the unlikely event that any of the banks that we use is declared in default, each individual client is entitled to up to a total of £85,000 (or £150,000 for joint accounts) in compensation for losses across all their deposits per institution.

The FSCS also provides clients of Jarvis (and other organisations regulated by the FCA), compensation of up to £50,000 per investor per firm for investments. The amounts covered under this scheme are revised from time to time. Further information can be found on the FSCS website at www.fscs.org.uk.

Additional Protection

In addition to the regulatory protection, under the FSCS, our professional indemnity policy provides protection against loss arising in the event of negligence, fraud or misappropriation. The Financial Conduct Authority (FCA) dictates the terms and conditions of the policy and the level of protection to Jarvis.

This protection would only come into play if a financial loss was incurred.

In the unlikely event that Jarvis ceased trading for any reason, creditors would not have any claim on client assets, either cash or stocks.

Client Money

All client money is placed within client money bank accounts - this means that your money is segregated from our own funds, in line with the FCA's client money rules. The banks where client money is placed are subject to due diligence checking in order to ensure the security of your funds - this includes only placing funds with banks that are covered by the FSCS. We may place client funds within term deposits that require a notice of up to 95 days for withdrawal - this will not affect your ability to deal on funds deposited with us.

Client Assets

All assets are either held directly through our Nominee company (JIM Nominees Ltd) or with external custodians, in line with the FCA's custody rules. This means your investments are identifiable as client assets. Your investments may be pooled with the investments of other clients at external parties, however, we maintain detailed records of beneficial ownership.

Controls

Our internal system maintains detailed records of beneficial ownership of both client money and assets. As well as the built in functionality within our systems, we carry out a number of procedural controls in order to ensure accuracy of these records. We also have a Compliance Committee that meet on a regular basis in order to ensure compliance with the FCA's client money and custody rules. The Committee's actions are overseen by our Board, who receive reports from the Committee at each Board meeting.

Order Execution

Jarvis Investment Management Ltd ("Jarvis") is required to establish and implement an order execution policy and to provide appropriate information on this to its clients. This information about Jarvis's order execution policy is applicable to all retail clients of Jarvis.

  1. General Principles

    When executing or routing orders in relation to financial instruments on your behalf, we will take all reasonable steps to achieve what is called 'best execution'. This means that our policy and procedures are designed to obtain the best possible execution result, subject to and taking into account your characteristics, client classification (categorisation as a retail client) and the characteristics of the order, the financial instruments that are the subject of that order and the Execution Venues to which that order can be directed.

    Our commitment to provide our clients with best execution does not mean that we have any fiduciary responsibilities over and above the specific regulatory obligations placed upon us or as may be otherwise contracted to.

  2. Order Execution Policy

    Subject to any specific instructions from you, when executing orders on your behalf or transmitting them to another entity for execution, we shall take all reasonable steps to achieve the best possible execution result for your order taking into account the execution factors listed below.

  3. Execution Factors

    The execution factors that will be taken into account are:

    • price;
    • costs of the transaction;
    • speed of execution;
    • likelihood of execution and/or settlement;
    • size and complexity of the order; and
    • characteristics and nature of the order.

    Ordinarily price and overall costs for transacting the deal will merit a high importance in obtaining the best execution result for the order. However, in some circumstances we may determine that other factors listed above may be more important in determining the best execution result for the order. We will exercise our own discretion in determining these factors.

  4. Execution Venues

    Jarvis will execute deals through:

    • Regulated markets - a large proportion of the orders we execute is traded on the London Stock Exchange
    • Multilateral Trading Facilities
    • Systematic internalisers
    • Market makers for their own account
    • Other liquidity providers
    • Non-EU entities performing similar functions

    Jarvis places significant reliance on the following execution venues

    Product Execution venues
    UK Equities and
    exchange-traded products
    Winterflood Securities
    KBC Peel Hunt
    Shore Capital Stockebrokers Ltd
    Knight Equity Markets
    Cantor Fitzgerald Europe
    Non-UK instruments Winterflood Securities
    KBC Peel Hunt
    Stifel Nicolaus Europe Ltd

    Our order handling system will normally route orders to a network of Retail Service Providers (RSPs), who will have the opportunity to quote an execution price. Prices achieved through this process are generally better than best available price on the London Stock Exchange at the time of polling. Where more than one price is quoted, the price that gives the best outcome for the customer will be selected.

    Where an order cannot be filled in this way, owing to its size or other factors, it will be routed to our dealing desk, where our order handlers will determine how to achieve the the best outcome. This may be via the RSPs, or it may be negotiated directly with market makers. Orders that cannot be traded in this way may be "worked" over a period.

    Our list of RSPs is reviewed at least annually, to ensure that we are able to get quotes from the key participants in the relevant markets. In the case of Funds that are not held in our preferred platforms, orders are placed directly with the fund management groups.

    For certain transactions, such as those where the security is traded by a limited number of entities, Jarvis may use alternatives where we consider it is in your best interests to do so.

    We will not normally execute your order outside a Regulated Market or Multilateral Trading Facility when that order could be executed through one of these.

  5. Delivering Best Execution

    Having given consideration to the Execution Factors and General Principles referred to above, we will select the most appropriate venue(s) from those available and execute your order accordingly.

    If you give a specific instruction with regard to order execution, you should be aware that this may mean that you will not achieve the best outcome on that trade. Jarvis will carry out the order in accordance with your specific instruction and will be deemed to have complied with the best execution requirement to the extent of that instruction.

  6. Review and Monitoring

    Jarvis will monitor execution quality and compliance with our Execution Policy on an on-going basis and will at least once a year make a formal assessment of its dealing policies. You will be notified of any material changes to the Execution Policy.

    Prices achieved are compared with official market prices and significant discrepancies are followed up.

  7. Limit Orders

    In the case of client limit orders in respect of shares admitted to trading on a regulated market which are not immediately executed under prevailing market conditions, unless you expressly instruct otherwise, we are required to take measures to facilitate the earliest possible execution of that order by making public immediately your limit order in a manner which is easily accessible to other market participants. Such publication may not always be in your interest so unless you give explicit instructions to publish at the time that you place the order with us, we shall deem that you have instructed us not to publish.

    The circumstances when we can publish your Limit Order(s) are:

    • The Limit Order must be placed by telephone during normal market hours;
    • The order size must be within the normal market size dictated by the market upon which the stock is listed, i.e. London Stock Exchange (LSE);
    • The stock must be an "order driven stock", i.e. a stock that can be published on the LSE order book;
    • You may only choose a settlement period of T+2; and
    • The limit order is 'Good for the Day' i.e. your order will be published until the market closes on the same day.
  8. Top 5 Venue Reports

    Jarvis assigns a high level of importance to price and overall costs in obtaining the best execution result for an order. However, in some circumstances we may determine that other factors, such as speed of execution, likelihood of execution and/or settlement, the size and complexity, or other characteristics of the order may be more important in achieving the best possible result.

    Jarvis does not have any close links with the external brokers used to execute client orders, and there are no special arrangements in place with such brokers.

    Jarvis applies the same level of rigour to orders for professional clients as it does for retail clients.

    Jarvis uses monitoring tools to compare execution results with official market prices.

    The RTS 28 analysis for 2017 can be found under the following link: RTS 28 analysis

General risk warning

The past performance of any investment is not necessarily a guide to future performance. The value of investments or income from them may go down as well as up. As stocks and shares are valued from second to second, their bid and offer value fluctuates sometimes widely. The value of shares may rise as well as fall due to, and not just including, the volatility of world markets, interest rates, economic conditions/data and/or changes in the rate of exchange in the currency in which the investments are denominated. You may not necessarily get back the amount you invested.

As an execution only client, any decisions on investments are purely your own choice and Jarvis Investment Management will not provide any advice on these investments. We will execute the transactions for you only. You will therefore be responsible for loss with the investments chosen. Please ensure you fully read and understand the risks involved in any decision you make. If you have any doubt whether any investment is suitable for you, you should obtain expert advice

Conflicts of interest policy

At Jarvis, we expect our business activities to be conducted honestly and with integrity. We believe that it is good business practice to try to identify and manage conflicts of interest which could harm our client's interests.

Our commitment

We are committed to identifying and managing the risk of a conflict of interest to make sure that we treat our customers fairly and comply with the law and regulations.

As part of this, we consider conflicts involving Jarvis Investment Management and the firm's individuals. For example:

  • Any of our directors, managers or employees;
  • Other people or companies we use to provide investment and related services (for example: appointed representatives or consultants).

What is a conflict of interest?

We provide a wide range of services to many different clients. Sometimes circumstances may arise where our duties to customers differ from what is best for us or for another client. This is a conflict of interest. We take our responsibility to identify and manage conflicts of interest fairly between us and our client's, or between two different clients, very seriously.

Principal 8 of the FCA's Principles for Business states that "a firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client".

When could a conflict of interest affect me as a customer?

A conflict of interest could result in Jarvis having an unfair advantage over you that you are not aware of. For example where we:

  • are likely to make a financial gain or avoid a loss at your expense.
  • have an interest in the outcome of a service we give you, or a transaction we make for you, which is different from your interest in the outcome.
  • have an incentive to favour the interest of one client, or group of customers, over another.
  • could receive an inducement (such as money, goods or services) for a service we provide other than the standard commission or fee for that service.

How do we deal with conflicts of interest?

The first step in dealing with conflicts of interest is to make sure that we can identify any real, or potential conflicts. To do this, we have procedures in place to prevent, identify and report conflicts of interest between us and our clients, and conflicts between one customer and another. These include:

  • A review of new business activity we may want to start to find out whether it results in any new conflicts of interest.
  • Designing the aims of the Jarvis and the personal objectives of employees to deliver fair treatment of customers as well as driving our commercial success

While we do everything we can to avoid a conflict, where this is not possible we make sure we manage any conflicts of interest to avoid any material risk, disadvantage or loss to clients. In every case, a senior member of staff will own and manage any conflict of interest we have identified. We also keep a written record of conflicts and potential conflicts of interest that involve a risk of damage to the interests of one or more clients.

If we believe we may not be able to effectively manage a potential or actual conflict of interest that affects clients, we will tell them about this. We will also tell them what steps we will take to reduce the risk of damage to their interests. We will give clients enough information to allow them to decide whether to do business with us regardless of the conflict.

How do you manage conflict of interests that might affect clients?

To help you understand the way we work to manage potential conflicts of interest we've included a few examples of our activities:

  • We operate appropriate systems and controls to manage confidentiality and security of information so that we do not disclose client confidential information inappropriately.
  • The nature of our business is non-advisory.
  • We design reward structures for our employees that are not target-based.
  • We do not impose unfair conditions when pricing products.
  • We operate appropriate restrictions and controls where our employees have outside interests that could cause a conflict of interest.
  • We operate personal account dealing policies for our employees and monitor their accounts.
  • We take all reasonable steps to carry out client orders to buy or sell their investments in a fair way that does not benefit us.
  • We do not seek to gain from delays in paying out client money.
  • We aim to pay the right amount for genuine claims, and to pay these quickly.
  • We have processes in place to deal with complaints fairly and objectively.

Pillar 3 disclosure

The European Union Capital Requirements Directive introduced a revised regulatory capital framework governing the amount and nature of capital that must be maintained by credit institutions and investment firms. In the UK the directive has been incorporated by the FCA into its regulations through the General Prudential Sourcebook ('GENPRU') and the Prudential Sourcebook ('BIPRU') for banks, building societies and investments firms. See our Pillar 3 disclosure.

Complaints Policy

In the event of a complaint regarding our service, please write to:

The Compliance Officer
Jarvis Investment Management Ltd
78 Mount Ephraim
Tunbridge Wells
Kent, TN4 8BS

Or email invest@jarvisim.co.uk

When we receive your complaint we will log it in our register and try to resolve the matter straight away. If we are unable to do this, we will normally provide a written acknowledgement of your complaint within 3 business days of its receipt.

Once our investigations are complete, we will write to you with our final response. Unless we have been able to resolve the matter straight away, our final response will notify you of your right to refer your complaint to the Financial Ombudsman Service (FOS) if you remain dissatisfied - a copy if the FOS leaflet will also be included.

You may contact the Financial Ombudsman Service at:

The Financial Ombudsman Service
Exchange Tower
London
E14 9SR

You can also contact them online via their website at: http://www.financial-ombudsman.org.uk/consumer/complaints.htm

Key Information Documents (KIDs)

From 1st January 2018 the Packaged Retail and Insurance-based Investment Products Regulation ("PRIIPs Regulation") will come into force which aims to increase the transparency and comparability of certain investment products through a Key Information Document (KID). Examples of investments covered by the PRIIPs regulation include:

  • Non-UCITs* Retail Schemes
  • Exchange Traded Derivatives
  • Structured Products

*Undertakings for Collective Investment in Transferable Securities (UCITS)

A KID will provide you with essential information about costs, potential risks and performance to enable you to better understand the product and make an informed investment decision.

The regulation applies to PRIIPs and purchased by an EEA Resident Retail Investor, regardless of their nationality and is applicable worldwide, no matter where a PRIIP is purchased as long as it is purchased by an EEA Resident Retail Investor.

If you already hold a PRIIP in your portfolio you will be able to sell it without referring to us.

However, if you are purchasing a PRIIP online, you will receive the following warning:

You have not confirmed that you have read the Key Investor Information Document for this fund. For further assistance, please contact the Dealing Desk quoting reference 475

In this instance you will need to call the Dealing Desk on 01892 510515.

Terms and conditions

Please download our terms and conditions document.