Regulatory Disclosures

FNZ (UK) Ltd Governance

FNZ is committed to firm-wide governance and a risk management framework that is appropriate to the nature, scale, and complexity of the business. Under the ‘Three Lines of Defence’ model, the Board has ultimate responsibility for managing and controlling risk within FNZ’s stated risk appetite.

To assist FNZ in fulfilling its responsibilities an organisational structure is in place which manages risks across the business. Responsibilities for managing risks are allocated to:

First Line – Business functions retain primary responsibility for managing risks and operating an effective suite of internal controls;

Second Line – Includes specialist functions such as Risk & Compliance, Legal, and Information Security. These functions operate independent of the First Line and are tasked with the ongoing development and delivery of the risk management framework. Second line functions provide guidance and challenge as appropriate;

Third Line – This is Internal Audit. FNZ’s Internal Audit function is responsible for providing the Board with independent assurance around the management of risk and internal control assurance.

The framework above is governed and structured through a variety of tools that assist employees in understanding their responsibilities. In addition to the general training and development courses provided, FNZ ensures, amongst other things, the following:

  • That risk is a core consideration when setting strategy, formulating business plans and managing performance.
  • That the risk and control self-assessment process facilitates the identification and assessment of risks across all business units and provides a systematic means of identifying risk and control gaps.
  • The establishment of an effective risk management governance structure distinguishing between management, oversight activity, and accountability.
  • That the firm’s risk appetite is clearly articulated in order to safeguard stakeholder assets whilst achieving FNZ’s objectives.
  • The development and implementation of risk policies and procedures.

The governance process in place ensures that appropriate risks and/or events are identified and escalated in a timely fashion. Where a risk is deemed to pose a significant threat to FNZ’s clients or strategic objectives, it will be escalated to the FNZ Board. The Board then delegates certain activities to the Board Risk & Compliance Committee (“BRCC”), which reports back in respect of these activities.

FNZ makes a number of regulatory disclosures including Pillar 3 and remuneration. The remuneration disclosure document is available on request and includes further information on the processes that govern how FNZ identifies, manages, and mitigates risk.

Gender Pay Gap - FNZ UK (Ltd)

A copy of the latest FNZ Gender Pay Gap report can be accessed here

Supplier Code of Conduct 2018/19

A copy of the Supplier Code of Conduct 2020 can be accessed here

FNZ’s Annual Slavery and Human Trafficking Statement

Introduction to the Act

The Modern Slavery Act 2015 (“Act”) is UK legislation which came into force on 29 October 2015*. This brings the serious criminal offences of slavery, servitude, forced or compulsory labour and human trafficking together, under one piece of legislation. The intention of the Act is to protect victims, bring perpetrators to justice and to provide more effective tools for law enforcement.

The Act also places disclosure obligations on large companies (being those with annual turnover of over £36million) supplying goods or services in the UK. These companies must publish an annual statement setting out the processes and due diligence they have undertaken to ensure modern slavery does not exist in their business and supply chains.

About FNZ

FNZ is a market leading provider of end-to-end technology and highly scaled industrial strength back-office investment services to the financial services and wealth management sectors. Our services support a wide range of asset types and work across a range of currencies and markets to drive our customers’ businesses around the globe. Our service platform combines cutting edge software, industrial scale, secure infrastructure and efficient asset servicing to offer cost-effective, bespoke wealth management solutions.

FNZ engages with, and contract with, business critical suppliers in delivering its services to its customers. FNZ is committed complying with the Act and ensuring that there is transparency in its supply chain, which is primarily made up of suppliers of software, hardware and market data.

Our Approach

Acting honestly, fairly and complying with applicable laws and regulations is core to FNZ’s ethical standards.

FNZ has already taken steps to combat slavery in the supply chain, updating the Procurement Policy and our supplier due diligence processes respectively, to set the scene for this zero tolerance approach. We ensure that, while setting up commercial arrangements with our global suppliers, we discuss compliance with international standards, and always ask our suppliers to adhere to all applicable laws and regulations.

In addition, we have introduced a supplier code of conduct which will strictly prohibit both forced labour and child labour as a requirement for securing or maintaining a commercial relationship with FNZ. This code of conduct will include a summary of the appropriate and relevant actions to be taken where we do identify or have reasonable suspicion that this code of conduct is being breached.

Our Commitment

FNZ recognises that there are challenges in the highly dynamic and fluid problem of modern slavery. We acknowledge that there may be some areas where more visibility of FNZ’s supply chain is required. Therefore, we commit to map out, review and address the potential risks in all countries where we source products and services.

The Role of Procurement

Modern slavery affects many industries, and while it is illegal in every country in the world, FNZ recognises that it still occurs across the globe. FNZ Procurement has a critical role to play, through sourcing in a manner that enables and rewards suppliers for good employment practices, rather than purchasing in a manner which drives the use of modern day slavery practices.

We will make all reasonable attempts to identify and address risks such as those related to forced labour and human trafficking, evaluating the supply chain over no less than a 24-month period to identify risks at global, regional, and local levels.

Closing Statement

Our approach includes ongoing collaboration with other businesses to understand how they are approaching the Act, keeping abreast of changes in policy, growing our understanding of the issues, and listening to the UK Government.

We recognise this is an ongoing process and welcome input from external stakeholders about our approach. Please contact us at procurement@fnz.co.uk if you wish to share information with us or discuss our approach further.

Adrian Durham, CEO

September 2020

*See also Section 39 of the Human Trafficking & Exploitation (Scotland) Act 2015.

Summary of FNZ (UK) Ltd Complaints process

FNZ strives to provide the best customer experience, placing our customers first with the aim of providing a first class service. In line with this, FNZ takes and will continue to take all complaints from its customers very seriously.

FNZ defines as a complaint any expression of dissatisfaction by its customer which alleges actual or potential financial loss or material distress or inconvenience on the part of the FNZ customer.

Any customer wishing to raise an issue as a formal complaint should send details of the complaint, in writing, to: Matthew Ferman, UK CEO, Level 5, 67 Lombard St, Langbourn, London, EC3V 9AJ or by emailing matthew.ferman@fnz-group.com.

Please note that only complaints received from FNZ’s customers will be subject to this process. Any complaints received from underlying individual customers will be forwarded to our customers’ complaints departments to deal with through their own complaints management policies.

FNZ will aim to acknowledge any complaint from its customer promptly, notifying the customer of the name of the individual who will be responsible for investigating the complaint and providing the customer with this summary of its complaint handling process.

FNZ will record details of the complaint for future reference, regulatory and learning and development purposes.

FNZ will ensure that any complaint is investigated by a member of staff who was not directly involved in the matter that is the subject of the complaint. Such an FNZ employee has the authority to settle the complaint or alternatively will have ready access to someone who has.

FNZ will aim to resolve the complaint in a timely manner. If this is not possible, the complaint will be escalated internally to a more senior level.

When a complaint has been resolved, FNZ will confirm the details of the resolution to the customer, in writing.

Please note that FNZ customers are categorized by FNZ as eligible counterparties and are not eligible complainants. Customers therefore do not generally have the right to refer a complaint to the UK Financial Ombudsman Service.

However, if for any reason a customer is unhappy with the outcome of a complaint that customer may be able to refer the matter to mediation or other form of Alternative Dispute Resolution and /or to take legal action subject to the provisions of the customer’s contract with FNZ.

South African Policies

The below documents are available on request from our compliance team at compliance@silica.net:

Complaints Policy Australia

To lodge a complaint with FNZ please fill out the form in the “Contact Us” by filling out all the relevant fields and providing us with as much detail as you can.

FNZ’s guiding principles for complaints handling encompasses a customer focused system that is visible, fair and accessible. We are committed to resolving your complaint as soon as possible. For most standard complaints, we will endeavour to provide a written response within 30 calendar days after receiving your complaint. If your complaint is resolved with 5 business days, we may not provide a written response. Complex complaints may have different timeframes for responding as per regulation and we will notify you if that is the case for you.

No costs will be incurred to the complainant for lodging a complaint.

Alternatively, if you are unsatisfied with our response to you, or the complaints handling process itself, or you did not receive a response within the required time frame, you may be eligible to take your complaint to an external complaints body.

FNZ holds membership number 67394 to the Australian Financial Complaints Authority (AFCA) which is a free and independent dispute resolution scheme.

Australian Financial Complaints Authority (AFCA)
Mail - GPO Box 3, Melbourne VIC 3001
Call - 1800 931 678
Online – www.afca.org.au

New Zealand Feedback and complaints

In general, you should contact your service provider if you have a complaint to make. However, in the event that you wish to provide feedback about our service or make a complaint, you may contact us by telephone or email as provided above.

We have an internal complaints process and undertake to investigate your concerns promptly and fairly.

If you have complained to us and you are not happy with the outcome, or if we have taken more than 40 working days to resolve your complaint, you may contact:

Financial Services Complaints Limited (“FSCL”), an external dispute resolution scheme.

FSCL provides a free of charge service and can be contacted at:

Postal address: FSCL, PO Box 5967, Wellington
Phone: 0800 347 257
Email: complaints@fscl.org.nz

Alternatively, you can also make a complaint to the Financial Markets Authority (FMA).

Hatch customers

If you are a Hatch customer, our Hatch customer feedback and complaints process applies. Please click here for the Hatch feedback and complaints process.

FNZ Securities Complaints Procedure

Conflict of Interest Policy Summary

We take care to maintain high standards of service. If we are aware of client concerns
or unease, we give priority to resolving the matter as quickly as possible. To assist with this process we have prepared procedures to ensure that complaints are handled fairly and within reasonable timescales. The below is a summary of our complaint handling procedure. A copy of our full procedure is available on request.

How to make a complaint.

If you have a complaint about us and/or our services, you should direct this in the first instance to your investment manager. If you are uncomfortable doing so, your complaint can be directed to the Chief Executive Officer. You can complain in writing, by telephone, or via e-mail. Details can be found on the Contact Us page.

What happens after I have complained?

Upon receipt of a complaint, a senior person who, where possible is independent of the case, will investigate the complaint. You will be given the name and contact details of the person dealing with your complaint. We will aim to resolve the complaint as quickly as possible. The person investigating your complaint will;

  • Initiate a record and file of your complaint; and
  • Acknowledge your complaint as soon as is reasonably practicable after the receipt of your complaint. This will generally be within 5 working days of receipt.

The acknowledgement may, especially in the case of an oral complaint, set out the nature of the complaint and may request further clarification if necessary. Your complaint will be investigated using our files together with reports from other parties if relevant. We may also write to you if further information is required.

We will keep you informed of the progress of the complaint investigation. After eight weeks, if a final response letter has not already been sent to you, you will receive a final response letter detailing our conclusions and resolution to the complaint. If we are not in a position to make a final response, we will give the reasons for the delay and will indicate when we expect to be able to provide a full response.

What if I am still not satisfied?

Within our final response letter to you, we will include details of the Financial Ombudsman Service (the “FOS”) whom, provided you are an eligible complainant, you have the right to right to refer a complaint if you are not satisfied with our response. Any referral to the FOS must be made within 6 months of receiving our final response. Further information about the FOS and whether you are an eligible complainant can be found at http://www.financial-ombudsman.org.uk

FNZS Policies

Email: securitiescomplianceuk@fnz.com

FNZ Securities Pillar III - Disclosures as at 31.03.2021

FNZ Securities Limited (FNZS)is subject to the capital adequacy requirements set by the UK Capital Requirements Regulation (UK CRR) and The Financial Conduct Authority (FCA) Prudential Sourcebook for Investment Firms (IFPRU). These regulations establish the framework for prudential management and include components that require firms, including FNZS, to assess their financial resources. Pillar 3 requires firms to disclose information regarding their risk management and policies, own funds and capital requirements. This Pillar 3 disclosure has been prepared in accordance with UK CRR and IFPRU.

Please click this link for FNZS’ Pillar 3 disclosures.