Our Code of Ethics
Waterhouse Financial Planning Ltd is committed to providing and upholding the highest standards of care and professionalism to our clients. The CII Code of Ethics is therefore of upmost importance to us and underpins how we run our business and interact with our clients, staff and suppliers. This includes but is not limited to the five key areas set out below.
We expect our staff to:
- Comply with our company’s Code of Ethics and all relevant laws and regulations.
- Act with the highest ethical standards and with integrity.
- Always act in the best interests of every client.
- Provide the highest possible standard of service.
- Treat people fairly regardless of their race or racial group; sex or sexual orientation; religion or belief; age; and disability.
1. COMPLY WITH OUR COMPANY’S CODE OF ETHICS AND ALL RELEVANT LAWS AND REGULATIONS.
This first core duty is paramount to the way we operate. We expect our staff to operate in the following manner and that they should:
- Deal with regulators and the CII in an open, clear and co-operative manner.
- Ensure that all correspondence and queries from regulators and the CII as well as others acting on their behalf are dealt with promptly and courteously.
- Work not only within the law, but also within the spirit of the law.
- Make sure our organisation is suitably regulated and has effective compliance arrangements.
- Ensure, where required, that we are individually authorised or regulated.
- Report any breaches of the Code to the CII. Where this core duty conflicts with another core duty this duty will have priority over the others.
2. ACT WITH THE HIGHEST ETHICAL STANDARDS AND WITH INTEGRITY.
This second core duty is all about building trust and being ethical in the way we conduct ourselves. We expect our staff to operate in the following manner and that they should:
- Be honest, trustworthy and open.
- Be reliable, dependable and respectful.
- Not take unfair advantage of a client, a colleague or a third party.
- Not bring the financial services industry or the CII into disrepute whether through their actions in work or outside work.
- Not offering or accepting gifts, hospitality or services which could, or might appear to, imply an improper obligation.
- Promote professional standards within the industry.
- Encourage and support our company to produce an ethical code.
- Make sure our CII membership or chartered status is described correctly.
- Inform the CII of any change in our work or circumstances which affect our membership or chartered status.
- Operate both professionally and in a financially responsible manner to avoid becoming insolvent.
3. ALWAYS ACT IN THE BEST INTERESTS OF EVERY CLIENT.
This key duty is about information and the way we handle it. We must make sure we know about the right products and services for our clients’ needs and convey that information in the best way possible. We expect our staff to operate in the following manner and that they should:
- Encourage our company to put fair treatment of clients at the centre of its culture.
- Base our decisions on a clear understanding of client needs, priorities, concerns and circumstances.
- Give our client all the information, of which we are aware, which is needed for them to make an informed decision, provided that information is not confidential to another client.
- Make sure the promises we make to clients about a product's performance and the after sale service are true.
- Respect confidential information of clients, former clients and potential clients.
- Ensure we do not use information from work improperly and/or to our personal or business advantage.
- Turn down work where a conflict of interest exists between the client and us.
- Refuse to act where a conflict of interest exists, except where acting in these circumstances is expressly permitted by a regulator.
(Please Note: A conflict of interest is a situation in which someone has competing professional or personal interests. Depending on the circumstances, there may be a perceived rather than an actual conflict of interest. Both perceived and actual conflicts must be dealt with appropriately.
Conflicts of interest can arise where: We owe, or our firm owes, separate duties to two or more clients in relation to the same or related matters and those duties conflict or there is a significant risk they may conflict; or our duty to act in the best interests of any client conflicts, or there is a significant risk it may conflict, with our own interests.)
4. PROVIDE THE HIGHEST POSSIBLE STANDARD OF SERVICE.
This key duty is about putting our clients first, being accurate and straightforward, keeping up to date with best practice and ensuring we seek feedback to ensure we are able to do better. We expect our staff to operate in the following manner and that they should:
- Communicate with each client in a way that is accurate and straightforward and expressed in a way that clients can understand.
- Be transparent about our fees and other costs.
- Make sure reasonable steps are taken to ensure all advice is accurate and suitable for the client.
- Obtain and provide clear information before, during and after the point of sale.
- Ensure adequate and correct records are kept.
- Act with skill, care and diligence.
- Act only within our ability and authorisation and seek help where necessary.
- Ensure our knowledge and expertise is kept up-to-date and relevant for our work including meeting any Continuing Professional Development (CPD) requirements.
- Ensure those who work for us have appropriate training and supervision and that we contribute to their learning and development.
- Make sure our company has a clear written complaints procedure, which is followed.
5. TREAT PEOPLE FAIRLY REGARDLESS OF THEIR RACE OR RACIAL GROUP; SEX OR SEXUAL ORIENTATION; RELIGION OR BELIEF; AGE; AND DISABILITY.
Our final key duty is about equality and diversity. We expect our staff to operate in the following manner and that they should:
- Obey the equality and diversity laws in our country.
- Treat each person with respect and as an individual.
- Challenge and report unlawful or otherwise unfair discriminatory behaviour and practice.
- Act openly and fairly and treat employers, employees, colleagues, clients, potential clients and suppliers with equal respect and opportunity at all times.
- Make reasonable adjustments to assist people with disabilities or particular needs we may deal with at work.
- Encourage our company to produce and promote an equality and diversity policy setting out how the business plans to promote equality, diversity and inclusion, prevent discrimination and deal with any instances of discrimination, which might happen.
- Make sure processes and procedures do not discriminate.
We expect every individual that works for Waterhouse Financial Planning to follow our values and code of ethics. This can be summarised into the following key points:
- Understand why a code of ethics is important – understanding is key to correct behaviour.
- Set the best example – you are responsible for your behaviour.
- Think beyond yourself – ethics involves more than one person.
- Reflect upon what you are doing – keep asking yourself the right questions.
- Make this an integral part of your working practice - make sure you give it regular attention.