Introduction

Foreign Currency Innovations Limited (FCI) is authorised and regulated in the United Kingdom by the Financial Conduct Authority (FCA) under firm reference number 616985. The Company’s Principal and Registered Office is at Suite 1C, Union House 117 High Street, Billericay, Essex CM12 9AH (registered company number 07274218).

The FCA’s Treating Customers Fairly (TCF) initiative is primarily based on the obligation set out in the Individual Conduct Rules. Rule 4 (replacing Principle 6) requires the firm’s individuals to pay due regard to the interests of its clients and treat them fairly. FCI is fully committed to TCF and this Policy has been designed to demonstrate the application of TCF during the course of our day to day activities.

FCI values all of its clients and constantly strives to ensure that all receive a user-friendly, reliable and high quality service. As part of FCI’s overall approach to business, FCI is fully committed to treating customers fairly and as such endeavour to meet clients’ expectations

TCF is embedded throughout the FCA’s Handbook and FCI supports the TCF initiative and satisfies the FCA’s six core consumer outcomes which explain what it wants TCF to achieve for consumers. These are:

• Consumers can be confident they are dealing with firms where TCF is central to the corporate culture.
• Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and targeted accordingly.
• Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
• Consumers are provided with products that perform as firms have led them to expect and the associated service is both of an acceptable standard and as they have been led to expect.
• Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

Our TCF Mission Statement

We will act with integrity in everything that we do and aim to be in partnership with our clients.

Our TCF Principles

• Ascertaining the appropriateness of FCI’s service provision for each new applicant before offering them an account so as to ensure, for the benefit of the applicant, that it is in line with their knowledge and experience.
• Ensure that you are made aware of the inherent risks of transacting in FX and CFDs.
• Ensure that any conflicts of interest are managed fairly.
• Customers will be provided with clear information and kept appropriately informed before, during and after the point of sale. This includes
• Our level of service and product performance will meet the expectations of our customers as far as reasonably possible.
• We will ensure that there is no barrier for customers to express their requests, concerns or complaints, and will always be responsive to them.
• Products and services will be designed to meet the needs of clients.
• Taking all measures possible to provide an uninterrupted trading service with competitive spreads / charges.
• Assessing and implementing our TCF Principles.

Marketing

All FCI’s financial promotions and marketing literature are reviewed to ensure that they are appropriate for the target audience and are presented in a clear, fair and not misleading manner.

Sales & Management

FCI obtain a detailed understanding of the clients’ investment objectives, their level of expertise and their attitude to risk so that their products are suitable. We ensure that our clients understand the risks involved with any service or product offered and are aware of all applicable charges.

We classify all our clients correctly to ensure they are offered the appropriate level of protection. Investment and asset allocation decisions are regularly reviewed by the relevant committee.

Post-Sale Information and Support

FCI strives to keep its clients informed at all times. Appropriate records are provided as required and on an ongoing basis. We have appropriate capacity and processing arrangements in place to ensure continuous support and no post-sale barriers.

Policies and Procedures

FCI has a number of policies and procedures that are relevant to the fair treatment of clients and also achieve adherence to FCA requirements, these are (this not an exhaustive list):

• Order Execution Policy
• Conflicts of Interest Policy
• Data Protection Policy
• Personal Account Dealing Policy
• Training and Competence Policy
• Complaint Handling Procedures
• Financial Promotions Procedures
• Financial Promotions Procedures
• Compliance Manual
• Management Information

FCI produces MI in order to assess its performance against TCF principles. We ensure that MI is accurate, timely, consistent and relevant in order to assist the business in making informed decisions in the best interests of our clients. FCI produces MI reports which are reviewed regularly by senior managers, directors and board members in various committee meetings.

Awareness/Training

FCI ensures that all advisers and staff are familiar with the fundamental principles of TCF. In addition, where applicable, advisers and staff are trained in order to suitably advise on and efficiently explain and provide our products and services. We make sure that all of our advisers and staff achieve the necessary qualifications and training in order to carry out their job functions with the required competence level. We undertake regular monitoring and assessment of our advisers and staff so that we can be certain of their competence.

Compliance

FCI has a compliance team who is independent and regularly monitors all key areas of regulatory compliance including TCF.

Remuneration

FCI operates a remuneration model that mitigates sales bias and rewards non-sales staff in a way that would not negatively impact the treatment of its clients.

Complaints

FCI aims to provide excellent customer service and complaint handling is a major component of its TCF measures. We deal with customer complaints fairly and objectively and attempt to put things right as quickly as possible, in accordance with the rules laid down by the FCA. All complaints are recorded and monitored by our compliance team and reported and analysed in company MI and management meetings.

Conclusion

FCI’s culture is and has been throughout the years in line with the outcomes stipulated by the FCA’s TCF initiative. However, we frequently review our policies, procedures and practices to ensure that TCF remains a crucial part of our business.

We ask our clients to provide us feedback, sometimes formally through customer surveys, so that we can improve our service. The information we collate from our clients can be reflected in company MI and reviewed by senior managers, directors and board members to help shape any strategic decisions.

If clients or applicants for an account have any questions on FCI’s Treating Customers Fairly Policy please contact the Compliance Department (compliance@fci-ltd.co.uk)

Ways that you can help us:

In order that we can provide you with the highest possible standards of service, we would kindly ask you to:

• Inform us of any changes to your work or home contact details.
• Let us know if there are any areas of the service and products that we provide that you do not understand or require clarification.