Distribution governance

We aim to ensure that 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 approach to robust governance, and in line with the FCA’s Product Intervention and Product Governance Sourcebook (‘PROD’), we place significant emphasis on the governance of our distribution, i.e. the way that we engage with and support the professional advisers who use our products.

An important initial aspect of our procedures is our Distribution Governance – Distributor Due Diligence Questionnaire (‘DG-DDDQ’). We require this questionnaire to be completed by all firms, in all instances, when they start using our products, as a condition of our Terms of Business. Where a firm has not completed our DG-DDDQ, we require individual professional advisers to complete the Individual Adviser Level DG-DDDQ, pending the Firm Level DG-DDDQ being completed.

FIRM LEVEL DG-DDDQ INDIVIDUAL ADVISER LEVEL DG-DDDQ
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In addition, as part of our ongoing distribution governance procedures, we ask professional adviser firms to complete our Distribution Governance – Mutual Annual Reporting (‘DG-MAR’), which operates in conjunction with our DG-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.

FIRM LEVEL DG-MAR INDIVIDUAL ADVISER LEVEL DG-MAR
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Regardless of the regulatory requirement, we believe that distribution governance is best practice, for client-centric reasons and outcomes. The information that is provided through our distribution governance procedures not only helps fulfil mutual governance requirements, importantly it also contributes to our target market identification and product development processes.

If you require any assistance, please contact us.