Under MIFID II regulations, product governance requirements apply to both manufacturers (fund managers and platforms) and distributers (advisers and execution only platforms). To help meet these requirements and assist you in your due diligence, we have provided a summary of our product approval process below.
Summary
- Fair treatment of customers
We can demonstrate that the fair treatment of customers has been considered at every stage of the product lifecycle and through activity. - Conflicts of interest
Conflicts of interest (whether potential or actual) between all stakeholders are clearly identified, documented and effectively managed at all times and stages of the product lifecycle in line with the principles within the Quilter's platform Conflicts of Interest Policy. - Customer outcomes
Performance and reward strategies for staff, managements and distributors (including commission payments) are aligned with the principles of fair treatment of customers and do not result in unfair customer outcomes. - Target markets
We clearly identify target markets and develop distribution strategies for our products with clearly defined and evidenced customer need. All our products are designed to provide value for money to the target market in all reasonable circumstances. - Customer fairness
Potential risks to customers arising from purchasing our products are identified and assessed for customer fairness. - Regulation
Our products comply with all relevant regulation and legal requirements as applicable to the jurisdiction where it is to be sold. - Charging structures
Our charging structures for all our products are fair, appropriate for the intended target market, capable of clear explanation and consistent with regulatory requirements applicable to the markets in which the products are sold. - Product pricing
Our product pricing is set at a level which appropriately balances customer needs, the competitive environment and shareholder requirements and is aligned to our agreed business plan. We complete sensitivity testing on the key profitability metrics and identify the key risks affecting profitability. - Approval process
We maintain and follow a robust approval process for each new product or material product modification prior to marketing and selling the product to customers. - Post-sale
Customers should not face unreasonable post-sale barriers to change product, switch provider, submit a claim or make a complaint. - Marketing communications
The marketing material and communications issued by us to customers is clear, fair and not misleading and sufficient to ensure customers can make informed financial decisions in relation to our products. All communications consider customers’ information needs and comply with applicable regulations. - Product Review Framework
An appropriate Product Review Framework is in place facilitating an ongoing cycle of product reviews which assess how each product is performing and whether it is delivering fair outcomes to customers. - Due diligence
Distributors of our financial products ensure that appropriate product due diligence is undertaken, the target market is identified and the distributor obtains adequate guidance on customers for whom the product may not be compatible in order to ensure products are demonstrably matched to the needs of their customers. - Product governance
We ensure appropriate reporting is provided to the relevant governance forums and committees and to the relevant Boards in relation to product governance activity. - Risk reporting
Any breaches of this Policy are reported to the Quilter Policy Owner and Specialist in accordance with the risk reporting and escalation requirements set out by the Enterprise Risk Management Policy and Escalation Standards.