A conflict of interest may arise where your interests may conflict with our interest, the interest of a member(s) of our staff or the interests of another client. In accordance with the FCA rules we will take all appropriate steps to identify and to prevent or manage conflicts of interest that may arise in the course of us providing our services. We maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to prevent conflicts of interest adversely affecting the interests of our clients. We have in place a conflicts of interest policy to identify, prevent and manage our actual or potential conflicts of interest, which is regularly reviewed, as well as a supporting register of conflicts. A summary of our conflicts of interest policy is set out below and further details are available on request.

Where the arrangements that we have in place are not sufficient to ensure with reasonable confidence that a risk of damage to you will be prevented we will disclose to you the general nature or sources of the conflict of interest or both and the steps we have taken to reduce the risks before we undertake the business for you.

Third party payments and benefits

In the course of providing our services to you we will not accept or retain any fee or commission from a third party. We may accept and retain minor non-monetary benefits where this is permitted by the FCA rules, for example, the provision of product-specific information from a product provider, participation in training events on the benefits and features of investments and de minimis hospitality or training facilities. We will only accept and retain minor non-monetary benefits where such acceptance would not prevent us acting in your best interests. We will disclose to you generic details of the amount of the minor non-monetary benefits we receive at least annually. Entertainment, hospitality and other inducements which the account executives may receive are recorded in the firm’s minor non-monetary benefits register and each is considered by our compliance department to ensure that it satisfies the requirements to be a minor non-monetary benefit, as described above. As S&T routes all its trades through one venue, PSL (see the best execution policy), there is very little risk that the account executives would be swayed by hospitality. For the avoidance of doubt, any third-party investment research that we receive and retain (apart from any such research capable of constituting a minor non-monetary benefit) will be paid for by us directly from our own resources and we will not operate a research payment account.

Summary of our Conflicts of Interest Policy

Our account executives are required to disregard any interest they have when making personal recommendations or dealing for you under their discretion. Certain account executives are also members of S&T and may indirectly receive increased annual remuneration based on increased profits that we generate. No members of staff share dealing commission and there are is no link between dealing activity and the remuneration staff receive. We have a robust independent compliance function which analyses portfolios and clients annual total expense ratios. Exceptions to a standard set by S&T are analysed by our partners. Our staff members can make personal account transactions. We have a personal account dealing policy of which all staff are aware. All personal trades conducted by staff members are recorded by the compliance department and analysed. Under no circumstances is a member of staff allowed to trade ahead of a live client order. Any recommendations we make will be based on our opinions and we may be influenced by external research; however, we have no ties with research providers meaning a stock is only recommended or traded under a discretionary agreement that we believe at the time

Other examples are that when we recommend a transaction to you or enter into a transaction for you, we or one of our associated companies could be:

• dealing as a principal for our or its own account by selling the investment concerned to you or buying it from you;
• matching your transaction with that of another client by acting on that client’s behalf as well as yours;
• buying or selling units in a collective investment scheme where we are, or an associated company is, a trustee, operator (or an adviser of the trustee or operator) of that scheme;
• buying investments where we are, or an associated company is involved in a new issue, rights issue, take-over or similar transaction concerning the investment;
• undertaking designated investment business for other clients;
• in receipt of instructions from another client to buy or sell the same investments; or
• acting as an adviser to the issuer of the relevant investments.

When we execute an order on your behalf we are under an obligation under the FCA rules to take all sufficient steps to obtain the best possible result for you taking into account relevant execution factors. In order to comply with our obligations in relation to best execution we have in place a best execution policy. We have provided below a summary of this policy which describes the policy that we have adopted to obtain best execution for you and for acting in your best interests in relation to orders that we place with other parties on your behalf. Full details are available on request. You should read our best execution policy and if there is anything in it which you do not understand you should ask us to explain it to you. By entering into the agreement with us you consent to our best execution policy.

Specific client instructions

If you provide us with a specific dealing instruction it may prevent us from following our best execution policy as we would usually do but, under FCA rules we will be deemed to have satisfied our obligations under our best execution policy to take all sufficient steps to obtain the best possible result for you in relation to that part of the order to which your instructions relate.

Public limit orders

You instruct us, and any third party to whom we pass an instruction on your behalf, not to make public “client limit orders” in shares admitted to trading on a regulated market, multilateral trading facility or organised trading facility which are not immediately executed under prevailing market conditions, except where in our, or the third parties’ discretion, it is in your interest to make public all or part of a client limit order.

Summary of our best execution policy

When dealing on your behalf we will exercise our discretion in assessing the criteria that we need to consider to obtain the best possible result for you.

In our dealings for you as a retail client, the most influential factor in determining our final execution decision will be that of ‘total consideration’; this represents the price of the financial instrument and the costs related to the execution.

Depending on the characteristics of the financial instrument concerned we will also consider the following criteria:

• Certainty of execution
• Order size
• Speed of execution
• Settlement
• Any other relevant criteria to the execution of the order.

We transmit all orders to one venue, Pershing Securities (“PSL”) who have demonstrated that they enable us to provide the best possible results for the execution of our clients’ orders on a consistent basis. PSL has access to the widest range possible of venues and markets to provide us with best execution. Additionally, PSL reports to us its results including detailed analysis of each trade placed on our behalf which demonstrate how PSL achieved the best possible result.

The choice of venue we have chosen will be reviewed not less than on an annual basis.

All orders received and decisions to trade will be transmitted to PSL in an orderly, prompt and timely manner. Orders received by post, fax or email will be executed as soon as reasonably possible after receipt of the order.

Instructions received or decisions to trade at a time when the stock market on which the instrument is traded on is closed will be executed as soon as that market re-opens. Dealing instructions can only be considered and dealt with during our normal business hours.

We will aim to place any Unit Trust/OEIC orders received before 10.45am on the same day pricing point. Orders received after 10.45am will (in most cases) be placed at a pricing point of the following business day. Some Unit Trust/OEIC’s may price earlier than midday or on certain days, weeks or months; these orders will be placed for the next available pricing point.

This policy came into force on 3rd January 2018, by instructing us to trade or allowing us to trade with discretion for you on or after this date indicates to us that you agree to this policy. It replaces all previous policies and will be monitored for effectiveness on a regular basis. You will be notified by a durable medium should the policy change in the future.

Monitoring

We will monitor both our compliance with our Best Execution Policy, and the quality of execution of third parties to whom we have passed orders at least annually. We will advise you of any material changes to our Best Execution Policy as necessary.

The FCA rules require that we must obtain your consent to our execution policy. Unless you have provided a written objection to us adopting this policy, we will deem you to have provided such consent for us to continue to trade on your behalf. Should you require any further information or assistance in relation to the Execution Policy please contact your S & T executive.

This website has been designed for information only. Any content herein must not be distributed, published, reproduced or disclosed (in whole or in part) to any other person.

Introduction

S&T Asset Management LLP is a ‘data controller’ and is registered with the Information Commissioner’s Office under reference Z2035631 (‘we’, ‘our’, us’). This Privacy Notice is intended for our clients, whose personal data we process in the course of providing our services (‘you’, ‘your’). We are required to inform all persons for whom we hold personal data of how we collect and use their personal data. We also need to provide you with other privacy information, including details of your rights under the EU General Data Protection Regulation (GDPR). This Privacy Notice will have effect from 25 May 2018 when the GDPR takes effect.

How we collect your personal data

We collect your personal data in various ways, principally from:

• You, when you:
• complete our client agreement (including the client agreement questionnaire)
• send us a letter or email
• speak to us over the telephone or by a face to face meeting.

If we receive personal data from you verbally, we may make a written or electronic record of this.

• Third parties, where you have given signed written authority for them to provide personal data about you to us. An example of such a third party may be your IFA, your accountant, or a relative.
• Other sources, such as from public records, for example where we verify your address or your connection with a corporate entity using postcode checker websites or the Companies House website.

The categories of personal data we collect

Most of the categories of personal data we collect about you are listed in our client agreement questionnaire, which we ask you to complete and return to us. These categories of data include:

• Biographical and contact information, such as your name, date of birth, address, email address and telephone number;
• Financial and wealth related information, such as your plans, financial objectives, your attitude to financial risk and your knowledge and experience in the investments we may recommend; and
• Health information, such as any major health concerns that may affect your financial planning.

The legal grounds and purposes for processing your personal data

We may process your personal data because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. In this respect, we may use your personal data:

• to interact with you before you become our client, for example when you express your interest in our services (for example, to send you marketing material or answer enquiries about our services);
• once you have engaged us and become our client, to understand your financial position and to provide you with the services as set out in our Terms of Business or any other contractual document;
• for the purposes of processing subscriptions, dividend payments, transfers and redemptions and distributing financial statements, notices and performance reports;
• corresponding and interacting with you (or others acting on your behalf) about your services and including to deal with any concerns or feedback you may have; and
• maintaining records of your transactions.

We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data:

• to confirm your identity and carry out due diligence checks, including to confirm your source of wealth for anti-money laundering and ‘know your client’ purposes;
• to fulfil our tax reporting obligations, principally to HM Revenue and Customs (HMRC) but including under any reporting agreement entered into with a tax authority or revenue service from time to time;
• to meet our other compliance and regulatory obligations, including in order to comply with any requirement of any applicable statute, regulation or regulatory rule (for example, Financial Conduct Authority (FCA) rules) to which we are subject.

We may also process your personal data because it is necessary for our or a third party’s legitimate interests. Our ‘legitimate interests’ include our commercial interests in operating our business in a client focused manner, in accordance with all applicable legal and regulatory requirements. In this respect, we may use your personal data:

• outsourcing selected ‘back office’ functions to third parties (for example, Pershing Securities Limited (see below) and other suppliers of hosted software solutions or cloud storage providers) for the purposes of efficient, fast and secure access to data;
• to monitor and evaluate the performance and effectiveness of our services; and
• for our marketing purposes, including in order to keep you informed (typically by letter, telephone or email) of our services which may be of interest to you.

We may also process your personal data where:

• it is necessary for reasons of substantial public interest (for example, where the due diligence checks we carry out involve our processing data relating to criminal convictions and offences and we do not ask your consent because to do so might lead to a ‘tipping off’ offence under anti-money laundering legislation);
• it is necessary for the establishment, exercise or defence of legal claims (for example, to protect and defend our rights or property, and/or the rights or property of our clients, or of third parties); and
• we have your specific or, where necessary, explicit consent to do so (for example, where we process sensitive personal data concerning your health or medical conditions for the purpose of making adjustments when we meet with you or to provide you with a more responsive, tailored service).

Data retention

The personal data we hold about you will be held by us for as long as you continue to use our investment management services. Should you cease to use our investment management services we will continue to hold your data for a period of not less than seven years. Under certain circumstances financial information is required to be held by financial institutions for longer than seven years. If that were to be the case, we would inform you of this at the relevant time, i.e. seven years from the date our client / firm relationship ended.

Data accuracy

We will endeavour to ensure the personal data we hold about you is current and accurate by reviewing this data with you or a person you have designated to act on your behalf. This review will be carried out periodically and will be updated as you or your representative informs us of any changes. When we are informed that data we hold about you is inaccurate or has changed, we will make the changes to the data we hold about you and where required delete inaccurate data.

Data sharing with third parties

Some of the information we hold about you is shared with Pershing Securities Limited (PSL). They are required to know certain data about you to provide to us a back office clearing system and information portal. PSL is a data controller and is registered with the Information Commissioner Office under reference Z5888984. We will supply a copy of their privacy notice to you upon request.

Your personal data will never be passed to third parties without your consent, except where S&T use computer software or the services of third party IT support providers to manage client’s personal data (which is necessary for S&T’s legitimate interests, as described above).

The financial regulation authorities in the UK such as the Financial Conduct Authority (FCA) and HM Revenue and Customs (HMRC) require us to share with them certain information regarding financial transactions carried out in the UK. S&T must fully comply with these reporting requirements meaning certain personal data of our clients is shared securely with those regulatory authorities.

International transfers

Where relevant for your services, your personal data may be transferred to and processed outside of the European Economic Area (‘EEA’) in countries or territories that do not provide the same level of protection for personal data as the EEA does. Where this happens, we will put appropriate measures in place to ensure the adequate protection of your personal data when it is transferred outside of the EEA, as required by the GDPR.

In these circumstances, your personal data will only be transferred on one of the following grounds:

• the country or territory to which the transfer is made ensures an adequate level of protection for personal data;
• S&T and the recipient of the personal data outside the EEA have signed a form of model data protection clauses (standard contractual clauses) approved by the European Commission; or
• there exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent to make the transfer).

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard contractual clauses which S&T has entered into with recipients of your personal data) by contacting us using the details set out below.

Your rights in relation to your personal data

The GDPR gives individuals the following rights in relation to personal data held about them. Please note that the below rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

1.The right to rectification of incorrect or incomplete data

Having accurate information about you is required to enable us to provide suitable investment management services; we will correct, rectify and complete your personal data held with us immediately upon request.

2.The right to require us to erase your personal data or to object to our data processing activities on grounds relating to your specific situation and to request that we restrict or cease processing your personal data in certain circumstances, for example, where that information is no longer needed

While we will endeavour to comply with all such requests, please note that we will be unable to continue to provide investment management services to you without holding certain of your personal data and without processing your personal data in certain ways. For example, we must retain certain financial records and personal data in order to comply with our legal and regulatory obligations, as described above.

3.The right to data portability

Upon written request we will provide to you or to an organisation of your choice some or all the personal data you have provided to us, in a format which will allow another organisation to reuse your personal data.

4.The right of access to, and copies of, the personal data we hold about you, by making a ‘data subject access request (DSAR)’

You have the right to submit to us a DSAR (in writing) regarding the personal data we hold about you. We will not charge you to make this information available to you and will provide it within one month of your request. You have the right to request this information from us in either hard copy or electronically. The information we will provide will comply fully with the requirements (and applying any exceptions and exclusions) as set out in Article 15 of the GDPR.

5.Where our data processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal.

Complaints

If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner. You can find out more about your rights under the GDPR (and other data protection legislation) from the Information Commissioner’s Office website available at: www.ico.org.uk.

Contact us

If you have any queries about this Privacy Notice or how we process your personal data, or if you wish to exercise any of your rights under GDPR, please contact us at either:

Head Office

S&T Wealth Management
43-45 Market Street
Marple
Stockport
SK6 7AA

Tel: 0161 484 6789

Email: info@sandtwealth.com

Or

South West Office

S&T Wealth Management
The Knapp
Powerstock
Bridport
Dorset
DT6 3TF

Tel: 01308 485708

S&T Wealth Management is a trading name of S&T Asset Management LLP.

S&T Asset Management LLP is a limited liability partnership registered in England and Wales. Incorporation Number OC344828.Authorised and Regulated by the Financial Conduct Authority under reference 501695.

Registered Office: Aston House, Cornwall Avenue, London, N3 1LF

VAT No: 990 6486 74

GIIN: 9XU5CC.99999.SL.826

All formal complaints should in the first instance be made in writing to us at 43- 45 Market Street, Marple, Stockport, SK6 7AA. This firm adheres to an internal complaints procedure, a copy of which is available upon request. Complaints will be dealt with in accordance with the FCA rules. You may also have a right to complain directly to the Financial Ombudsman Service. Further information is available on request from us and from www.financialombudsman.org.uk or contact the Financial Ombudsman Service on 0800 023 4567 or 0300 123 9123

or by email at:

complaint.info@financialombudsman.org.uk.

The LLP is authorised and regulated by the Financial Conduct Authority (“FCA”). Under the FCA capital adequacy rules the LLP is classified as a BIPRU 50k firm. This means that the base capital requirement is 50,000 Euros. The LLP is also subject to an expenditure requirement which is a quarter of the relevant expenditure for the previous financial year.