Terms and conditions

Any reference to “EQ”,  “we”, “us” or “our” means EQ Investors Limited.
Not all products and services on this site are regulated by the Financial Conduct Authority.Access and use of the EQ website (“website”) is subject to the following terms and conditions of use (“terms of use”). Before using the website, you should read the terms of use and by proceeding you are deemed to have read and understood the terms of use and signify your acceptance of the same.

Accuracy

EQ takes all reasonable steps to ensure that any information, data, services, systems, articles, bulletins and other content (“content”) published from time to time on the Website is accurate and complete and complies with relevant English legislation and regulations as at the date of issue.

However, we regret that no liability can be accepted for any errors or omissions. We reserve the right at any time to change the content, presentation, performance, facilities and availability of all or part of the pages of this site at our sole discretion and without prior notice. We reserve the right at any time, and without prior notice, to remove or cease to supply any product or service contained on this website. In the event of any such change or removal we shall not be liable to you in any way whatsoever for such change or removal.

Whilst we take all reasonable steps to ensure that the information on the website is accurate and up to date, neither EQ nor its suppliers warrant that it is. You acknowledge and agree that neither EQ nor its suppliers have any control over the accuracy or completeness of third party data and all liability in respect of the same is expressly excluded to the maximum extent permitted by law.

Advice

The content of the website is intended for general information only and should not be construed as advice under the Financial Services and Markets Act 2000. The Website does not constitute financial, investment or tax advice and does not give you advice that relates to your specific circumstances. We recommend that you take appropriate professional and legal advice before entering into any binding contracts.

It is important that you do not rely solely upon the content to make investment decisions. This site should not be regarded as an offer or solicitation to sell investments in any jurisdiction. The provision of details, products or services on these pages are not, and should not, be construed as an offer for us to sell or for you to buy such products or services from us, and we may in our absolute discretion accept or reject any offer from you.

If you intend to act on any information on the website you should first confirm the details of the product or service (including costs and key features) with the product provider. If you are in any doubt as to the suitability of a product or service that you are intending to purchase or any aspect of your personal finances, we recommend that you seek independent financial advice first.

If you would like  financial advice, you can ring 020 7488 7110 between 08:30 am – 5.00 pm, Monday to Friday and one of our advisers will contact you at your convenience to discuss your requirements.

The website does not constitute an offer to buy, sell or provide any financial products or services, nor does the website comprise any form of investment advertisement.

Use of the website and content

You may use the website and content for your own private, non-professional use only. You may not use, copy, disseminate, distribute or re-sell the website or content (or any part thereof) for any commercial use or purpose whatsoever without our prior written consent. In particular, you may not use the website or content for carrying out or offering investment business as defined in the Financial Services and Markets Act 2000 in any capacity.

If you copy, frame, cache, deep link or set up a direct feed to any of the pages of the website, these terms of use and the privacy policy will continue to apply.

We reserve the right to collect information about numbers of users of this site and individual pages for the purpose only of developing and customising this website to better meet our clients’ needs. We accept no responsibility for information outside our web pages that may be accessed by hypertext link from these pages or for these other sites not being available at all times. The links to any other sites are provided for general information purposes only and the sites concerned and their contents are not endorsed or promoted by us in any way, unless otherwise stated. Please note that when you click on any external site hypertext link, you will leave our site and access the external site at your own risk. We will accept no responsibility or liability in respect of the material on any such other website. You may not create a hyper text link to this website without the prior written approval of EQ.

The website and content has been specifically designed for use solely in the United Kingdom and relates to products and services available to residents and nationals of the United Kingdom only. You must not use the website or content in countries where it is restricted or prohibited by local laws, regulations, codes or customs. We also recommend that non-UK residents and nationals (including other EU citizens outside the UK) should refer to a source of financial information within their own country.

To the fullest extent allowed by law, you agree that we will not be liable to you or any third party for any consequential or incidental damages (including but not limited to loss of revenue, loss of profits, loss of anticipated savings, wasted expenditure, loss of privacy and loss of data) or any other indirect, special or punitive damages whatsoever that arise out of or are related to the site.

We reserve the right to change these terms and conditions at any time by posting changes on the website. It is your responsibility to review the terms and conditions regularly to ensure you are aware of the latest terms and conditions. Your use of this website after a change has been posted will be deemed to signify your acceptance of the modified terms and conditions. We recommend that you print off and retain for your records a copy of these terms and conditions from time to time.

Security

It is your sole responsibility to ensure the security of your ID and password and you agree not to disclose or permit to be disclosed your ID and password to any third party. We take all reasonable steps, including encryption, to ensure that your personal data is disclosed only to those specified by you. However, the internet is an open system and we cannot and do not guarantee that the personal data you have provided to us will not be intercepted or decrypted by others.

Please note that the internet is not a totally reliable communication medium and is subject to failure of software or hardware outside the control of EQ which may lead to delays in, or total failure of communication data, messages or other material. We therefore do not warrant that the functions or materials accessible from or contained in this website will be uninterrupted or error free, or that defects will be corrected.

For further information on protection of personal data, click on our Privacy Policy.

Copyright in the pages of this site, in the screens displaying the pages and in the information and material contained therein and their arrangement, is owned by EQ unless otherwise indicated.

This website may not be reproduced or adapted in whole or in part without the prior consent of EQ, except for the purpose of accessing our services and for producing print outs for your own personal records. Any such copies must retain any copyright or other intellectual property notices contained in the original material.

Intellectual property rights

The trade marks, images, logos, trade names or similar on this website which identify EQ or third parties and their products and services are proprietary marks of EQ and/or the relevant third parties. No licence is granted to you in these terms and conditions to use any such marks.

Downloads

Please note that any software is downloaded at your own risk. We do not warrant the suitability of any such software, which is downloaded and accept no liability for any problems with your computer that may arise as a result. If you are in any doubt as to the suitability of software to be downloaded for your computer, it is recommended that you obtain specialist advice before downloading.

Some pages on the website may contain hypertext links to and from websites not operated or maintained by us (“Third Party Websites”). You are reminded that when you enter a third party website by means of hypertext links from the website, you will be subject to the terms and conditions of the third party website you are entering. Similarly, when you enter the website by means of hypertext links from a third party website, you will be subject to these terms of use.

Hypertext links to third party websites are provided for your convenience only. You acknowledge and agree that we are not responsible or liable in any way for the information or content displayed on such third party websites (including, without limitation, advertisements about investment products and services) and we do not endorse or make any recommendation about products and services that are advertised or promoted on such third party websites.

Some hypertext links on the website may take you to third party websites where advice or trading is available. You acknowledge and agree that we are not responsible or liable in any way with regard to any advice or trading which may be conducted on such third party websites.

Limitation of liability

Nothing in these terms of use restrict or exclude our liability to you for death or personal injury caused by our negligence.

Subject to the above, we shall not be liable for any loss, damages, costs, claims or expenses whatsoever arising from:

  • the acts, errors or omissions of third parties;
  • the accuracy or completeness of the website or content;
  • your failure to ensure the security of your ID and password; and
  • your use of the website and content otherwise than in accordance with these terms of use.

In no event shall we be liable for any indirect or consequential loss or damages whatsoever (including, without limitation, loss of profits) incurred by you or in respect of any claim made against you by any third party arising as a results of, or in connection with, your use of the website or content.

The website and content is provided ‘as is’. All warranties whether express or implied under law (including, without limitation, any warranties in relation to the content, information, data, services, interrupted use, errors, omissions, delays, termination of service, loss of data for any reason, fitness of purpose, infringement of third party property rights) are hereby expressly excluded to the fullest extent permitted by law.

You must not at any time:

  • prevent, restrict or inhibit any other authorised user from using the website or content;
  • post or transmit on the website any unlawful, fraudulent, libellous, defamatory, obscene, pornographic, profane, threatening, abusive, hateful, offensive, or otherwise objectionable information, content or materials of any kind (including, without limitation, any transmissions constituting or encouraging conduct that would constitute a criminal offence, give rise to civil liability, or otherwise violate any applicable laws, rules, regulations, codes of conduct or market conventions);
  • post or transmit on the website any advertisements, solicitations, chain letters, pyramid schemes, investment opportunities or schemes or other unsolicited commercial messages or engage in spamming or flooding; or
  • copy, upload, download, post, publish, transmit, reproduce or distribute in any way, content or any other information or material appearing on the website (including, without limitation, any text, data, software, graphics or programming code) without our prior written consent.

Governing law and jurisdiction

These terms of use are governed by the laws of England and Wales and you agree to submit to the exclusive jurisdiction of the courts of England and Wales.

Company registration and regulatory details

EQ Investors Limited is registered in England No.7223330 and its registered office is: 6th Floor, 60 Gracechurch Street, London, United Kingdom, EC3V 0HR.

EQ Investors Limited  is authorised and regulated by the Financial Conduct Authority.

Amendments

From time to time, we may change the terms of use, the privacy policy, and any other terms and conditions applicable to the website or to any services offered by EQ. By using the Website and such services, you are deemed to have accepted any such changes.

For more information please read the privacy policy.

Contacts

If you believe any information on this site is inaccurate or have any suggestions on how the content of this site could be improved please email us at enquiries@eqinvestors.co.uk or call us on 0845 362 8425.

Privacy Policy

Data protection

EQ Investors is committed to providing the highest level of privacy and security for its users and complies with all relevant Data Protection legislation, including the Data Protection Act 1998 (The Act).

The Act lays down eight fundamental principles, which ensure we handle your personal data correctly in accordance with The Act. One such principle states that information must be processed fairly and lawfully. This means that you are entitled to know how we intend to use any personal information you provide. You can then decide whether you wish to provide any such information to us.

If you choose to complete one of our online forms, the personal information you provide will be used solely by EQ Investors to enable us to answer your queries. Occasionally, we may contact you by letter, telephone, e-mail or otherwise to inform you about other products and services which may interest you. If you do not wish to receive this information please contact us at the address below or e-mail us at enquiries@eqinvestors.co.uk

You have a right to request a copy of the personal data we hold about you. If you require a copy please write to the Data Controller at EQ Investors, Centennium House, 100 Lower Thames Street, London EC3R 6DL. We reserve the right to charge the maximum fee payable in terms of the Data Protection Act 1998. If you believe that the information we hold about you is inaccurate you may write to us and ask us to correct it.

Owing to the global nature of the internet, the information you provide may be transferred in transit to countries outside the European Economic Area that do not have similar protections in place regarding your data and its use as set out in this policy. However, we have taken all reasonable steps to maintain the security of your personal information. By submitting your information you consent to these transfers.

E-mail / telephone calls

Please note that there is no guarantee that any e-mail sent will be received, or that the contents of any such e-mail will remain private during internet transmission. If you have any such concerns, you may prefer to use the telephone or postal system instead.

Cookies

What is a cookie?

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can remember who you are.

A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number.

Two types of cookies are used on this website:

Session cookies
These are temporary cookies that remain in the cookie file of your browser until you leave the site.

Persistent cookies
These remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). Most major websites use cookies. Cookies cannot be used by themselves to identify you.

How do we use cookies on our site and what information do we collect?

Session cookies                                                                                                
To allow you to use our tools. These session cookies contain no personal information and are destroyed once you close your browser.

Persistent cookies
To compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve the structure of our website. We cannot identify you personally in this way.

Can I disable cookies?

You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use certain tools or services if cookies are disabled.

What can I do to stop cookies being installed on my browser?

In Internet Explorer 8.0: Go to the ‘Tools’ menu, Click on ‘Internet Options’, Click the ‘Security’ tab, Highlight the ‘Internet’ zone (selected by default), Select security level ‘High’ for this zone, Click on ‘OK’

If you are using Firefox 1.5 +: Go to the ‘Tools’ in menu bar, Click on ‘Options’, Click on the ‘Privacy’ option and click the ‘Cookies’ tab. Use the options within here to determine which settings you prefer.

Social Media Policy

EQ Investors (EQ) believes in putting the interests of clients ahead of all other considerations. That is why we have embraced social media, it allows us to inform, assist and, importantly, engage with existing and prospective clients.

Our social media channels (including Twitter, Facebook, LinkedIn and Google+) are for information purposes only. The information should not be considered as investment advice, or a recommendation of any particular strategy or investment product.

Retweets, likes or other onwards sharing of content are not endorsements.

We welcome feedback and ideas from all our followers, and endeavour to join the conversation where possible.

If you have a specific query, please contact us.

This policy is effective as of 1 May 2015.

Pillar 3 Disclosures

Background

The Capital Requirements Directive (‘the Directive’) of the European Union is the regulatory capital framework used across Europe governing how much capital financial services firms must retain. In the United Kingdom, this is supervised by the Financial Conduct Authority (‘FCA’) using rules and guidance as outlined within the General Prudential Sourcebook (‘GENPRU’) and the Prudential Sourcebook for Banks, Building Societies and Investment Firms (‘BIPRU’) of the FCA’s Handbook. The FCA framework consists of three ‘Pillars’:

  • Pillar 1 –  sets out the minimum capital requirements that firms are required to meet for credit, market and operational risk;
  • Pillar 2 – requires firms to take a view on whether additional capital should be held against any  risks not covered by Pillar 1; and
  • Pillar 3– requires firms to publish certain details of its risks, capital and risk management process.

This document contains the Pillar 3 disclosure for EQ Investors Limited. This Pillar 3 Disclosure has been subject to internal review procedures. The information has not been audited by the firm’s external auditors.

Disclosure policy

The rules in BIPRU 11 provide that the firm may omit one or more of the required disclosures if it believes that the information is immaterial. Materiality is based on the criteria that the omission or misstatement of material information would be likely to change or influence the assessment or decision of a user relying on that information for the purposes of making economic decisions. Where the firm considers a disclosure to be immaterial, this will be stated in the relevant section.

The firm is also permitted to omit one or more of the required disclosures where it believes that the information is regarded as proprietary or confidential. Proprietary information is that which, if it were shared, would undermine the firm’s competitive position. Information is considered to be confidential where there are obligations binding the firm to confidentiality with its clients, suppliers and counterparties.

Where the firm has omitted information for any of the above reasons, a statement explaining this will be provided in the relevant section.

Unless stated as otherwise, all figures contained in this disclosure are based on the firm’s audited annual reports for the year ending 30th April 2016.

Frequency

These Pillar 3 Disclosures will be reviewed on an annual basis as a minimum. The disclosures will be published as soon as is practical following the finalisation of the firm’s Internal Capital Adequacy Assessment Process (ICAAP) and the publication of its annual reports.

The firm’s Pillar 3 Disclosure reports are published on the website.

Scope and application of directive requirements

The disclosures in this document are made in respect of EQ Investors Ltd (“the Firm”) which provides financial advice and discretionary investment management services. The Firm is authorised and regulated by the Financial Conduct Authority and is classified by the FCA as a Limited Licence Firm.

Risk management objectives and policies

The Firm’s risk management framework reflects the FCA requirement that they must manage a number of different categories of risk. These include liquidity risk, operational risk, credit risk, reputational risk, business risk, market risk, interest rate risk and concentration risk.

i. Liquidity risk

The Firm generates cash from its operations and holds sufficient cash reserves to meet the continued operating needs of the business. This is supported by a robust budgeting and forecasting process which has the full involvement of directors.

ii. Operational risk

Operational risk is defined as the potential risk of financial loss or impairment to reputation resulting from inadequate or failed internal processes and systems.  The firm does not handle client money and uses 3rd party custodians, all regulated by the FCA.

The Risk Assessment Committee meets quarterly to review the Risks matrix and that disaster & continuity plans are in place.

iii. Credit risk

The Firm does not undertake any lending activity. The major assets on the Firm’s balance sheets are bank deposits; commission due from fund managers, intercompany debt representing amounts due from the holding company and outstanding investment management invoices.  Most of these amounts are due from institutions that are regulated by the FCA.

iv. Reputational risk

The Firm is potentially exposed to Reputational risk in the event that clients’ funds are invested in unsuitable investments. All investments are reviewed by the inhouse investment team and any recommendations must be derived from the Approved List.

v. Business risk

The Firm’s Pillar 2 business risk principally takes the form of a fall in assets under management either due to a market downturn or a loss of clients through reputational risk that leads to a significant reduction in revenue. To mitigate business risk, the Finance team regularly analyses various different economic scenarios to model the impact of economic downturns on our financial position. The exposure to business risk is hedged, to a degree, by clients’ portfolios having significant exposure to both bonds and equities.

vi. Market risk

The Firm does not have any foreign exchange exposures nor does it have permission to engage in proprietary trading book activities and are therefore not directly exposed to market risk. Company revenues are linked to market movements and these have been addressed within business risk.

vii. Interest rate risk

The Firm has no borrowings and no exposure to interest rate risk.

viii. Concentration risk

The Firm has a wide client base and diverse revenue streams and is not reliant on the income generated by a single client or single revenue stream.

Capital adequacy

The firm’s capital requirement under GENPRU has been determined as the Fixed Overhead Requirement (FOR). Our Pillar 1 requirement is based on expenses for the year ended 30th April 2016.

The Pillar 1 requirement was £1,310,000. This is the FOR which currently exceeds the firm’s credit risk and operational risk requirements. As at 30th April 2016 EQ Investors Ltd had total Tier 1 regulatory capital of £2,037,000, against a requirement of £1,310,000 representing a surplus of £727,000.

The annual Internal Capital Adequacy Assessment Process identifies credit risk, business risk and operational risk capital requirements and will determine future capital requirements for the Firms.

Remuneration Code Disclosure

Introduction

The Capital Requirements Directive (CRD) of the European Union and the FCA Code on Remuneration require regulated investment firms to establish and maintain remuneration policies, procedures and practices that are consistent with and promote sound and effective risk management. The Code also requires firms to report annually on their remuneration policy for employees termed Code Staff. Code Staff can generally be defined as employees who perform a significant influence function, senior management and other staff who have a material impact on the risk profile of the business.

How the firm’s remuneration is determined

The Board reviews remuneration annually for all staff. Basic salaries are reviewed in line with individual performance and agreed by the Remuneration Committee. Bonuses and pension contributions are discretionary and agreed by the Remuneration Committee linked to the firm’s overall financial position.

Quantitative disclosure

In the year ended 30th April 2016 the Firm defined its Code Staff as the Boards of Directors.  The aggregate annual remuneration for Code Staff for the year was £1,005,000.