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.
This page contains the regulatory disclosure for the following regions and their regulated entities:
- United Kingdom
- South Africa
- New Zealand
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.
Within the UK, the FNZ Group has the following entities which are regulated by the Financial Conduct Authority ("FCA"):
- FNZ (UK) Ltd - FRN 438687
- FNZ Securities Limited (previously known as Rexigon Securities Limited) - FRN 733400
- FNZ TA Services Limited - FRN 932253
FNZ (UK) Ltd Disclosures and Complaints process
- The Pillar 3 disclosures document can be accessed here
- The remuneration disclosure document is available on request
- The Gender Pay Gap Report - FNZ (UK) Ltd and FNZ Group Technology Ltd, can be accessed here
- A copy of the Supplier Code of Conduct 2022 can be accessed here
- The Tax Strategy for all FNZ UK entities can be accessed here
Summary of FNZ (UK) Ltd Complaints process
FNZ (UK) Ltd (FNZ UK) strives to provide the best client experience, placing our clients first with the aim of providing a first-class service. In line with this, FNZ UK takes and will continue to take all complaints from its clients very seriously.
FNZ UK defines as a complaint any expression of dissatisfaction by its client which alleges actual or potential financial loss or material distress or inconvenience on the part of the FNZ UK client.
Any client wishing to raise an issue as a formal complaint should send details of the complaint, in writing, to: Alastair Conway UK CEO, Level 10, 135 Bishopsgate, London EC2M 3TP or by emailing firstname.lastname@example.org.
Please note that only complaints received from FNZ UK’s clients will be subject to this process. Any complaints received from underlying individual customers will be forwarded to our clients’ complaints departments to deal with through their own complaints management policies.
FNZ UK will aim to acknowledge any complaint from its client promptly, notifying the client of the name of the individual who will be responsible for investigating the complaint and providing the client with this summary of its complaint handling process.
FNZ UK will record details of the complaint for future reference, regulatory and learning and development purposes.
FNZ UK 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
FNZ UK 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 UK will confirm the details of the resolution to the client, in writing.
Please note that FNZ UK clients are categorised by FNZ UK as eligible counterparties and are not eligible complainants. Clients therefore do not generally have the right to refer a complaint to the UK Financial Ombudsman Service.
However, if for any reason a client is unhappy with the outcome of a complaint that client 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 client’s contract with FNZ UK.
FNZ Securities LTD Policies (UK)
- FNZ Securities Ltd MIFIDPRU 8 Disclosures for the year ending 31 December 2022 is available here
- A copy of the Supplier Code of Conduct 2022 can be accessed here
- The Best Execution Policy can be accessed here
- Conflict of Interest Policy Summary can be accessed here
FNZ Securities LTD Complaints Procedure (UK)
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 at
- Email: email@example.com
- FNZ Securities Compliance Level 5, 67 Lombard St, London, EC3V 9AJ
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
FNZ Ireland – Irish Progressive Services International Limited (IPSI) Policies
- The Gender Pay Gap Report - FNZ (Ireland) Irish Progressive Services International Limited (IPSI), 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.
FNZ is a market leading provider of end-to-end technology and highly scaled industrial strength backoffice 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 contracts 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.
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.
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.
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 firstname.lastname@example.org if you wish to share information with us or discuss our approach further.
Adrian Durham, CEO
*See also Section 39 of the Human Trafficking & Exploitation (Scotland) Act 2015.
FNZ (Europe) DAC Regulatory Disclosure
FNZ (Europe) DAC (FNZ EU) is regulated by the Central Bank of Ireland (CBI).
We are an investment business firm authorised by the CBI under Regulation 8 (3) and deemed authorised under Regulation 5 (2) of the Statutory Instrument No. 375/2017 European Union (Markets in Financial Instruments) Regulations 2017.
Details for FNZ EU are noted below.
Name: FNZ (Europe) DAC
Reference number: C432287
Authorised since: 22 Dec 2020
Registered Office: Block C Irish Life Centre, Lower Abbey Street, Dublin, D01 V9F5
FNZ EU has CBI permission to perform the following regulated activities.
Investment Services and Activities
Reception and transmission of orders in relation to one or more financial instruments.
1. transferable securities;
2. money-market instruments;
3. units in collective investment undertakings;
4. options, futures, swaps, forward rate agreements and any other derivative contracts relating to securities, currencies, interest rates or yields, emission allowances or other derivatives instruments, financial indices or financial measures which may be settled physically or in cash;
5. options, futures, swaps, forwards and any other derivative contracts relating to commodities that must be settled in cash or may be settled in cash at the option of one of the parties other than by reason of default or other termination event;
6. options, futures, swaps, and any other derivative contract relating to commodities that can be physically settled provided that they are traded on a regulated market, a MTF, or an OTF, except for wholesale energy products traded on an OTF that must be physically settled;
11. emission allowances consisting of any units recognised for compliance with the requirements of Directive 2003/87/EC
Investment Business Services
The administration of collective investment schemes, including the performance of valuation services or fund accounting services or acting as transfer agents or registration agents for such funds.
FNZ EU can offer regulated activities in other EEA countries. See the table below for further details.
Basis of Establishment
Finland, France, Germany, Italy, Luxembourg, Spain, Sweden
Freedom of Service
- The Firm is not permitted to hold client assets.
- The Firm is not permitted to hold client money.
South African Policies
The below documents are available on request from our compliance team at email@example.com:
- FNZ SA Conflict of Interest Policy
- FNZ SA FAIS complaints Policy
- Promotion of Access to Information Act (PAIA) Manual
The disclosures for FNZ Custodians (Australia) LTD Ltd ACN 624 689 694 can be accessed on this page: AUS Disclosures
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”) – A Financial Ombudsman Service. FSCL is an external dispute resolution scheme.
FSCL provides a free of charge service and can be contacted at:
Postal address: FSCL, PO Box 5967, Wellington 6140
Phone: 0800 347 257
Alternatively, you can also make a complaint to the Financial Markets Authority (FMA).
Hatch Feedback and Complaints
If you are a Hatch customer, our Hatch customer feedback and complaints process applies. Please click here for the Hatch feedback and complaints process.
New Zealand Holidays Act 2003
The Holidays Act 2003 (the Act) is the fundamental piece of legislation outlining leave entitlements for employees. This Act aims to legislate a balance between work and other aspects of the lives of employees.
Over the last few years, a large number of employers, have discovered that they have been incorrectly calculating holiday pay for some people. A taskforce of businesses, workers and the Government has been set up to review and recommend changes to the Holidays Act going forward.
What is FNZ doing?
FNZ has been through a thorough review process of its historic and future payroll processes to ensure full compliance with the Holidays Act.
As a result of our investigation, we have identified underpayments and under-entitlements for some current and former FNZ employees, primarily those who received incentive/bonus payments and or on-call or other related allowances.
Where underpayments or under entitlements have been identified, FNZ is committed to rectifying these. Once former employees contact FNZ and provide the required details, we will
authenticate and reimburse them appropriately.
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