Distributor Annual Data Collection

DISTRIBUTOR ANNUAL DATA COLLECTION QUESTIONNAIRE ('DADCQ')

ROBUST GOVERNANCE

We aim to ensure robust governance underpins all that we do. To our minds, good governance is more than just a regulatory requirement: instead, we believe that it is a core value and client-centric best practice ... and we think many professional advisers share this view and want to be confident of robust governance in the firms that they deal with.

As part of our distribution governance processes, as a condition of our Terms of Business ('ToB') with Professional Adviser firms, and to meet the FCA's Product Governance Sourcebook ('PROD') requirement to "take reasonable steps to ensure that the financial instrument [i.e. our plans] is distributed to the identified target market" (PROD 3.2.1(3)), we therefore ask Professional Adviser firms to complete a Distribution Due Diligence Questionnaire ('DDDQ'), when they start using our plans.

In addition, and also under PROD, we are required to "regularly review our products" (PROD 3.2.19), and in doing so we should "collect ... information to detect patterns in distribution" (PROD 3.2.20).

Therefore, as part of our distribution governance procedures, we also ask Professional Adviser firms to complete a Distributor Annual Data Collection Questionnaire ('DADCQ'), which operates in conjunction with our DDDQ, to facilitate us reporting to Professional Adviser firms, and Professional Adviser firms reporting to us, regarding ongoing product monitoring and target market / distributor governance, fulfilling our mutual obligations under PROD and our ToB.

As per our ToB with Professional Adviser firms, "You agree, on request from the Company, to use all reasonable endeavours to send the Company (except where to do so would result in the breach of any applicable law or regulation) information which the Company may require". Please only provide answers to the questions that do not result in the breach of any applicable law or regulation.

Please click here if you would like to understand more about why we ask the questions in our DADCQ

Under PROD 3.2.19, "we must regularly review" our products, taking into account any event that could materially affect the potential risk to our identified target market, to assess whether:

(a) they remain consistent with the needs, characteristics and objectives of the identified target market;
(b) our distribution strategy remains appropriate;
(c) they are being distributed to the target market; and
(d) they are reaching clients for whose needs, characteristics and objectives they are not compatible.

PROD 3.2.20 requires that we "should collect and analyse appropriate management information to detect patterns in distribution as compared with the planned target market in order to assess the performance of the distribution channels through which a financial instrument is being distributed".

Under PROD 3.2.30, you are therefore required to provide us with relevant information and, under our ToB with you, you have agreed to use reasonable endeavours to provide us with this information.

DISTRIBUTOR ANNUAL DATA COLLECTION QUESTIONNAIRE: SECTION 1

PLEASE PROVIDE THE FOLLOWING DETAILS ABOUT YOURSELF AND YOUR FIRM.

1.1 Please provide your name, job title and contact details:

Name:*

Job title:*

Telephone:*

Email:*

1.2 Please provide the name of your firm:*

1.3 Please provide your firm's FCA FRN (Firm Reference Number):*

1.4 Is your firm an Appointed Representative?*

Yes
No

If 'yes', please provide the name of the Principal Firm:

DISTRIBUTOR ANNUAL DATA COLLECTION QUESTIONNAIRE: SECTION 2

TO HELP BOTH OF US MEET OUR OBLIGATIONS UNDER PROD, WE WOULD LIKE TO ASK YOU TO CONFIRM THE FOLLOWING:

2.1 Were any of the investments into our plans made by or on behalf of clients of your firm outside our identified target market? We detail our target markets for our plans within the investor-facing plan documents for each plan and explain these further within the supporting materials which we produce for each of our plans for Professional Advisers, including our product proposal packs (PPPs) and professional adviser information packs (PAIPs).*

Yes
No

If 'yes', please provide an explanation

2.2 Did all of the clients of your firm who made investments, or on whose behalf investments were made, into our plans receive a suitability assessment and personal recommendation from your firm and / or were all of the investments made as part of a managed portfolio?*

Yes
No

If 'no', please provide an explanation

2.3 Has your firm received any complaints in connection with any investment into any of our plans?*

Yes
No

If 'yes', please provide an explanation

2.4 If you have conducted your own regular review of our plans in your capacity as a Distributor, is there any information which you think we, as the Manufacturer, should be made aware of?*

Yes
No (nothing to make Tempo aware of or no review undertaken)

If 'yes', please provide an explanation

DISTRIBUTOR ANNUAL DATA COLLECTION QUESTIONNAIRE: SECTION 3

UNDER OUR TERMS OF BUSINESS, WE WOULD LIKE TO CONFIRM THE FOLLOWING TO YOU:

We undertake regular reviews of our products. Our ToB with you require us to inform you immediately if certain events occur. We can confirm:

(a) No such events have occurred;

(b) Our reviews for the year to 31st July 2019 conclude that there are no material changes to the risk / return expectations of any plan and that each plan continues to remain consistent with the needs, characteristics and objectives of our identified target market; and

(c) We are not aware of any breach by us of our ToB with you.

DISTRIBUTOR ANNUAL DATA COLLECTION QUESTIONNAIRE: SECTION 4

UNDER OUR TERMS OF BUSINESS, WE WOULD LIKE TO ASK YOU TO CONFIRM THE FOLLOWING TO US:

4.1 Has your firm ceased to be the appointed Professional Adviser for any of the clients who invested in any of our plans:*

Yes
No

If 'yes', please provide an explanation

4.2 Have any of the clients of your firm who have invested in our plans become a US Person, or a United States Person, or is any plan now held for the account of, or for the benefit of, a US Person or United States Person:*

Yes
No

If 'yes', please provide an explanation

4.3 Have the details for your firm, or details of clients of your firm, changed from those previously provided*

Yes
No

If 'yes', please provide an explanation

4.4 Have any authorisations, registrations or permissions that your firm needs under your firm’s ToB with us been restricted, suspended or revoked in any way:*

Yes
No

If 'yes', please provide an explanation

4.5 Has your firm breached any applicable law or regulatory requirement to which it may be subject in relation to the distribution of any of our plans:*

Yes
No

If 'yes', please provide an explanation

4.6 Has your firm, or any of the principals of your firm, become the subject of a regulatory investigation, sanction or fine, or has your firm or any of the principals of your firm received a warning that your firm or any principal of your firm may become subject to such a regulatory investigation, sanction or fine in the future:*

Yes
No

If 'yes', please provide an explanation

4.7 Have there been any changes to your business model since your firm previously completed our Distributor Due Diligence Questionnaire (‘DDDQ’), which would materially affect the answers your firm gave, or that would otherwise materially affect our business relationship or your distribution of our plans:*

Yes
No

If 'yes', please provide an explanation

THANK YOU FOR COMPLETING THIS QUESTIONNAIRE ...

A member of our business development team will be in touch if we require any further information based on the responses you have provided. Do please contact us directly if you require any assistance immediately.

If you would like to have a chat about our governance procedures, structured products generally and / or any aspect of Tempo Structured Products with our Global Head of Structured Products, Chris Taylor, please tick the following box:

Please call me on the telephone number provided earlier in this form
Please email me using the email address provided earlier in this form