Principle 5 (Transparent management of Conflicts of Interest) of the Pension Transfer Gold Standard requires us to create and maintain a Conflicts of Interest statement which identifies all the conflicts of interest to which the firm and its advisers may be exposed specifically in respect of advising on Safeguarded Benefit transfers, and sets out how these conflicts are mitigated and/ or remedied.
This document is our statement for this purpose.
We will take all appropriate steps to identify all conflicts of interest which our firm / advisers may be exposed to when advising on Safeguarded Benefit transfers and set out how these conflicts are to be mitigated and/or remedied.
When identifying the types of conflicts that arise, or may arise, we assess whether our firm, anyone connected with our firm or (if relevant) another client has an interest in the outcome of a service provided and has the potential to influence the outcome to the detriment of a client.
Following our latest assessment, we have identified the following as actual or potential conflicts of interest in relation to giving advice on the transfer of safeguarded benefits:
|1||Contingent Charges may create an incentive to transfer|
|2||Being part of the deVere Group may unduly influence transfer advice|
|3||Remuneration of advisers may create an incentive to give unsuitable advice to generate income|
We have the following systems & controls in place to mitigate the conflicts of interests we have identified.
|1||At present Contingent charging is permitted by the FCA where it is suitable for clients. All clients receive a detailed Suitability Report which has been checked by a Pension Transfer Specialist to ensure it is a suitable recommendation. The cost of the advice itself is the same whether the client transfers or not. We believe we should only charge for the additional work involved in arranging a transfer and managing the investments if that is actually required.|
|2||deVere Group have no involvement in our transfer advice process and each case is considered on its own merits for suitability. We do not use deVere funds or platforms and do not receive any incentives for doing so. The DBAR transfer information service ceased in 2016.|
|3||We have a remuneration policy to manage adviser bonus etc. This includes compliance and other measures to ensure business is written to a high standard and is suitable. All transfer recommendations are signed off by a Pension Transfer Specialist. There are no special arrangements for DB transfer cases|
To ensure that this statement remains correct, we will review this on at least an annual basis. Any necessary changes will be made within seven working days of any review.