Legal

1. Regulatory
2. Terms & Conditions
3. Artorius Wealth Management Limited - Pillar III Disclosure
4. Best Execution Policy

1. Regulatory

Artorius Wealth Management Ltd is authorised and regulated by the Financial Conduct Authority. You can check this on the FCA Register at www.fca.org.uk/register (Firm Reference Number 677055). Artorius is a trading name of Artorius Wealth Management Limited.

Artorius Wealth Switzerland AG is a provider of wealth management services to the benefit of private individuals and is an active member of the Swiss Association of Asset Managers (“SAAM”) – a Swiss self-regulating organization recognized by the Swiss Financial Market Supervisory Authority (“FINMA”). The services provided are not subject to prudential regulation by FINMA but only subject to a limited regulation, namely Swiss anti-money laundering regulation and SAAM's FINMA approved Swiss Code of Conduct for Independent Asset Managers (“SAAM Code of Conduct”). This website is intended to be image advertising. It is not intended, and must not be construed as, providing regulated investment advice.

Complaints

If you have a complaint about the advice you receive from us or a product you bought through us, please contact our Compliance Team at: 2nd Floor, The Boardwalk, 21 Little Peter Street, Manchester M15 4PS. or email compliance@artorius.com

We are covered by the Financial Ombudsman Service (FOS). The FOS is available to settle certain complaints you make if they cannot be settled through our own complaints procedures. The contact details of the FOS are as follows: The Financial Ombudsman Service, Exchange Tower, Harbour Exchange, London E14 9SR, Website: www.financial-ombudsman.org, phone: (0)800 0 234 567.

2. Terms & Conditions

Please read these Terms carefully before viewing this Site. They set out the Terms and Conditions on which we make this Site and its content available to you.

By viewing or using this Site you agree that you have read and agree to be bound by these Terms (as amended and posted on this Site from time to time). You may use this Site only if you agree to be bound by these Terms.

This Site is directed at UK investors and qualified investors in Switzerland and is provided for information purposes only.

Nothing in these Terms shall restrict our duties to you under the Financial Services and Markets Act 2000.

Companies within the Artorius Group that do not carry out services subject to the Financial Services and Markets Act 2000 (the ‘Act’), either because they are not subject to the Act or are not performed in the UK, will not have the protections afforded by the Act.

1 - Definitions

In these Terms, unless the context otherwise requires, the following words have the following meanings: “Artorius ”, “we”, “us”, “our” is the provider of the artorius.com website. Artorius is the trading name of Artorius Wealth Investment Management Limited, a company registered in England & Wales, registered number 09285538, registered address 2nd Floor, 21 Little Peter Street, Manchester, M15 4PS. Authorised and regulated by the Financial Conduct Authority with register number 677055. “you”, “your” refers to you, the client, potential client or any other visitor to the site “FCA” refers to the Financial Conduct Authority. The FCA’s address is: 12 Endeavour Square, London E20 1JN. “Site” refers to all content hosted on this Site. “Terms” refers to these Terms & Conditions.

2 - Site Terms and Conditions

2.1 These Terms set out the basis on which you may use the Site, made available to you by Artorius.
No one else apart from us and you has any rights under, or may enforce, these Terms.

3 - Copyright

3.1 All copyright and other intellectual property rights in the information, design, text and graphics of the Site, and the selection or arrangement thereof, is owned by us or our licensors. All rights are reserved. You may store electronically (e.g. on a hard drive) and print in hard copy portions of the Site solely for your non-business related purpose of using the Site to seek information of the kind shown by the Site. Any other use of materials or content on the Site (including reproduction for purposes other than that noted above, amendment, updating, distribution or republication) without our prior written consent is prohibited. All product and firm names and logos mentioned on the Site are the trade marks, service marks or trade names of their respective owners, including us.

4 - Data Protection

4.1 Please see the Artorius Privacy Policy for information relating to the collection and use of your personal information.

5 - Cookies

5.1 Please refer to our Privacy Notice for information on cookies and their use on this Site.

6 - Limitation of Liability

6.1 We do not accept responsibility, nor will we be liable, for any failure of operation of the Site which arises as a result of:

a) errors in data transmission; or

b) machine or software malfunction; or

c) from your operating error (other than any such failure occurring as a result of our fraud, negligence or wilful default).

6.2 You acknowledge that access to this Site may be disrupted and that this does not amount to a breach of these Terms.

7 - Regulatory

7.1 Please refer to the Regulatory section of this website above.

8 - Complaints

8.1 Please refer to the Regulatory section of this website above.

9 - Risk Warning

9.1 Past performance is not a guide to future performance. The value of investments and any income from them may fall as well as rise and investors may get back less than the amount originally invested. Information on this site should not be relied upon when making financial or investment decisions.

10 - Legal

10.1 While we take every care to ensure that the standard of the Site and its content remains high and to maintain the continuity of the Site, you should be aware that the internet is not an absolutely stable medium and you agree that the Site and its content is provided to you “as is” and that errors, omissions, interruptions of service and delays may occur at any time. We do not accept any ongoing obligation or responsibility to operate the Site (or any part of it) or to provide the services offered on the Site.

10.2 We make no representations or warranties about the accuracy, completeness, freedom from viruses, availability, reliability or suitability for any purpose of the information and related content and graphics published on the Site (including all texts, advertisements, links or other items) which may contain technical inaccuracies and typographical errors.

10.3 You agree that you shall not attempt to interfere with the proper working of the Site and, in particular, you shall not attempt to circumvent security, tamper with, hack into, or otherwise disrupt any computer system, server, website, router or any other internet connected device relating to the Site.

10.4 Unless otherwise specified all content and materials published on the Site are presented solely for your private, personal and non-commercial use. You assume total responsibility and risk for your use of the Site and use of all information contained within it.

10.5 The information given on the Site is for information only and does not constitute investment, legal, accounting or tax advice, or a representation that any investment or service is suitable or appropriate to your individual circumstances. Please seek professional advice before making any investment decision.

10.6 Nothing on the Site should be construed as a solicitation or offer, or recommendation, to buy or sell securities or any other investment or banking product, or to provide any investment advice or service.

10.7 Any views expressed on the Site may no longer be current or may be changed without notice. Views may or may not have been acted on by Artorius.

11 - Social Media

11.1 Links to social media accounts from this Site and links from social media accounts to this Site presented by Twitter, Facebook and LinkedIn are owned by third-parties unaffiliated to us. Artorius is not responsible for those third-parties’ privacy, security, or terms of use policies that control these services, nor their content. Use of social media sites is at your own risk.

11.2 Artorius tweets and posts are for information purposes only.

12 - Termination of Site

12.1 We reserve the right to terminate this Site at any time.

13 - General

13.1 We reserve the right to assign, transfer, novate or subcontract any or all of our rights and obligations under these Terms to the extent that it is necessary for us to provide the service. Your consent will be required where any such assignment may adversely affect the service provided to you. If we fail to enforce a right under these Terms, that failure will not prevent us from enforcing other rights or the same type of right on a later occasion. These Terms set out the entire agreement between the parties. This clause shall not apply to any statement, representation, or warranty made fraudulently, or to any provision of these Terms which was induced by fraud.

13.2 You agree that we may at any time appoint agents, subcontract, or outsource some or all of the services and functionality comprised in this Site.

13.3 You are liable for any telephone or other communication charges and any charges made by your internet service provider or any third party incurred as a result of you using the Site.

13.4 If we fail to exercise a right and/or remedy under these Terms, such failure will not prevent us from exercising other rights or remedies or the same type of right or remedy on a later occasion.

13.5 If any provision of these Terms is held to be unlawful, invalid, or unenforceable, that provision shall be deemed severed and the validity and enforceability of the remaining provisions of these Terms shall not be affected.

13.6 From time to time, we may amend, vary, modify or update these Terms. We will notify you of any change no later than thirty, (30) days before such change takes effect.

13.7 These Terms & Conditions shall be governed by and construed in accordance with English law and the parties agree to submit to the exclusive jurisdiction of the English courts.

3. Artorius Wealth Management Limited - Pillar III Disclosure November 2018

Regulatory Capital and Risk Management

Artorius Wealth Ltd (“AWL”) acquired Alfred Simmons Holdings Limited and its subsidiary Alfred Simmons Investment Management Ltd. FCA Change in Controller approval became effective on 7th April 2017 whereupon Alfred Simmons Investment Management Limited was renamed Artorius Wealth Management Limited (Firm Reference Number 677055).

Artorius Wealth Management Limited (“AWM”) is a BIPRU Limited Licence firm with a consolidation waiver, the direction is effective from 28/07/2017 and is valid until 31/12/2022. AWM may control and manage but cannot hold client money. AWM is classified as a flexible portfolio firm (a lower risk firm) in that it will be supervised through a combination of market based thematic work and programmes of communication, engagement and education.

AWM is authorised and regulated by the Financial Conduct Authority.

AWM provides wealth planning and advisory services, together with a discretionary management service, to High Net Worth and Ultra High Net Worth clients. Typically, clients have more than £3m investable assets. AWM clients tend to be of first generation wealth, self- generated through entrepreneurial business ownership or through working as senior financial professionals.

AWL is privately funded by HNW investors. It is committed to growing a business with a long-term focus that will provide succession-based planning advice and support to wealthy families (with investors in the business in many cases also being clients). No single investor owns over 10% of the business.

Consolidation Waiver

The Pillar 3 document has been updated in accordance with GENPRU 1.2.47 which gives firms with a consolidation waiver an exemption from preparing the ICAAP on a consolidation basis as required by BIPRU 8.2.1R, 8.2.2R, 8.3.1R and 8.3.2R which deals with the consolidation requirements for UK Groups.

The directors consider that AWM holds adequate level of capital to comfortably cover the base minimum requirement of €50k. Additionally, the directors have assessed the firm to ensure it could be wound down in an orderly fashion (which would in the main be within a 3-month period). Notably, in a wind down scenario all AWM client custodians have the capacity, if required, to take on client advice relationships. The Fixed Overhead Requirement exceeds the projected Wind Down budget of £687,000 which includes a contingency reserve of £75,000.

The directors have carried out some stress tests to provide assurances that the firm could continue to meet its capital requirements in adverse market conditions.

The directors consider AWM’s liquidity to be adequate for its size and for the complexity of its business. The AWM balance sheet shows net assets of £3,414,000 and current financial resources of £3,337,000.

The directors have assessed AWM’s capital adequacy requirement, based on three months contracted fixed costs, to be £700,000.

The directors of AWM will maintain an ‘early warning system’ such that any reduction of the firm’s capital to below the 20% buffer will be identified (whilst remaining above the capital adequacy requirement of three months’ fixed costs), this will present the directors with ample opportunity to ensure that the firms liquidity always remains within the bounds of prudence and of the regulatory requirements within which they operate.

With a consolidation waiver in place and assuming AWM is operating under normal trading conditions and based on cautious estimates of turnover and costs, the directors confirm that AWM has capital in excess of its capital adequacy requirement.

Were AWM to undertake any acquisitions of books of business, the directors would consider further fund raising to strengthen the capital base of the firm if necessary, as appropriate to the circumstances of the time.

A Summary Of The Findings Of The ICAAP Analysis

Pillar 1 The directors have assessed the variable capital requirement to be in excess of the base capital requirement and are therefore using this to determine the regulatory capital requirement for AWM. The directors have identified 13 weeks’ worth of fixed overheads totalling £700,000. This includes all costs which would be required for the businesses to continue to operate. Under GENPRU 2.1.45R the Fixed Overhead Requirement disclosure is a proxy for the Pillar 1 Operational/Market and business risk calculation. As per MIPRU 3.2 a capital requirement of £25,000 is allowed for in respect of our PII excess within the capital requirement.

Pillar 2 The Pillar 2 requirements are discussed by the Risk and Governance committee which meets quarterly and assesses and evaluates the actual and perceived risks to the business. All risks are recorded on the Risk Register and those risks that could potentially impact upon the financials of the business (not covered within the normal capital adequacy requirements) where additional capital may be required are included above.
AWM is fundamentally risk averse and does not look to take on risks which could threaten its business, it is recognised that the fact that many clients will be ultra-high net worth does bring with it some significant risks. The Risk and Governance Committee has been set up to proactively identify any potential risks to the business and to ensure they are effectively monitored by management, mitigation or removal. The directors have undertaken stress testing on its core business model for AWM. The core ‘worst case stress test’ assumption is that a significant fall in markets would lead to a 12.5% fall in fee revenue. The rationale behind this assumption is that the firm will follow a relatively cautious and conservative investment policy using well diversified portfolios consisting of collectives managed across a range of assets. It is therefore assumed that 50% of client’s assets would be held in traditional risk assets, i.e. equities and related holdings, and those markets might fall 50% and remain depressed for a year. The other 50% is deemed, for the purposes of the stress testing scenario, to be held in lower risk collectives investing in assets such as cash, government securities and prime corporate bonds – source CIO Market Risk Report July 2017 & re-confirmed at September 2018. The directors have included a 25% market decline as a permanent Pillar 2 requirement for the both AWM within the business plan, calculated as 12.5% of recurring revenue on a rolling basis. This acknowledges that markets have seen a continual growth since 2008, and that a market correction could occur over the next 5 years. AWM and AWL Group would be able to support 12 months of revenue shock at the lowest point of the forecast capital cycle without reducing forecast operational costs.
This is deemed adequate by the directors and would be re-assessed if the business drivers changed or if a market fall took place over a prolonged period to confirm the below expectation, and if necessary draw upon contingency funding or re-shape the business as necessary.
The directors have assessed £90,000 of additional risks on the risk register which is lower than the FOR requirement and has therefore not been included.

Risk Management Framework

The directors of AWM has prepared detailed procedures to cover the governance and regulatory aspects of its business. These include:

  • A comprehensive governance structure designed to accommodate a rapidly expanding business
  • A compliance manual summarising the regulatory processes and procedures
  • A compliance monitoring programme which has been designed around risks considered to be relevant to the firm. This is updated on an on-going basis through a process taking input from the Risk and Governance committee. The compliance monitoring programme also highlights the processes in place which are designed to mitigate identified risks.
  • A Risk and Governance Committee chaired by the COO which meets quarterly and whose remit is to assess and analyse all risks to the group and ensure remedial measures are put in place where required. The risks facing the firm are identified and considered both from the perspective of the likelihood of them occurring and from the perspective of their potential impact on the firm should they occur. This high-level risk register plan is reviewed at least quarterly but more frequently if needed.
  • Investment in IT infrastructure to provide disaster recovery, efficient operations and high-quality investment research and monitoring, client risk profiling and a client database.
  • A Client Experience Committee Group, chaired by the CEO whose remit is to review the advice policy of the business and outcomes of the policy for clients ensuring the clients’ interests are considered always with emphasis placed on treating the customers fairly. The mechanisms in place provide a decision-making forum where representatives of the firm can discuss advice propositions and technical points which may affect sales and operations with the aim of ensuring that clients receive the most appropriate advice and experience.
  • An Investment Committee, chaired by the CEO whose remit is to review and assess new market developments / trends that may affect our investment strategy. The committee also ensures that our current house view and investment strategies remain fit for purpose identifying any changes which may be needed. An additional important role of the committee is to accurately measure the performance of client portfolios ensuring they remain within their risk tolerances.
  • A Remuneration Committee chaired by the CEO whose remit is to review, assess and approve remuneration structures and any incentive schemes having due regard to best practice and relevant legal and regulatory requirements.

The group employs a Group Compliance Officer and a Finance Team, providing required in- house risk management on a daily basis.

Business Planning

The firm has a comprehensive business plan which focuses on the delivery of quality services to our clients by means of advisory and discretionary services. The plan also covers the firm’s revenue and cost budgets associated with developing its position in the marketplace.

The business plan is reviewed annually by the AWL and AWM board , whilst the costs and revenues associated with developing the firm’s position in the marketplace will be reviewed monthly as part of the firm’s financial reporting process. The implications of the firm’s business plan and the consequences of any review are fed into the firm’s ICAAP & Pillar 3 process.

Capital Management

AWM is deemed to be a BIPRU firm, however based on the requirement for three months fixed overheads; the firm’s capital requirement will be significantly in excess of the minimum requirement of €50k. The Finance Team prepares monthly management accounts, including a Balance Sheet, Profit & Loss Account plus confirmation of adequate regulatory capital & liquidity. The capital requirement is currently met using cash reserves.

The directors monitor the capital positions on a monthly basis. Monthly management accounts are drawn up by the Finance Team and approved by the directors.

Liquidity Management

The firm’s liquidity tolerance The Firm has a conservative approach to liquidity management, holding cash to the equivalent of at least three months’ fixed costs with a 20% buffer, as measured under ICAAP, in immediate access bank accounts.

Management of liquidity tolerance The firm produces a profit and loss account & balance sheet on a monthly basis, and a monthly liquidity multiple which is signed off by the senior manager responsible. The firm re-calculates on a quarterly basis its three-month fixed cost cash flow requirement, and the firm’s three-month capital requirement is noted on the firm’s monthly management accounts balance sheet.

Liquidity sign off The directors discuss and sign off the firm’s management accounts on a monthly basis.

Material Risks

Risk Management Process The firm has a formal process for the consideration and identification of risk which is considered by the firm’s Compliance.

The firm’s risk management process consists of the following steps.

a) Compliance monitor the risks faced by the firm on an ongoing basis and will recommend any changes that should be made to the firm’s compliance monitoring programme, risk register, systems and controls and other means of managing or mitigating risk. These recommendations are made to the Risk & Governance committee, which will determine the acceptance or otherwise of these controls and recommendations. b) Annually, the firm will arrange for the compliance monitoring programme to be formally reviewed by an external source. The next review is in November and will be conducted by Threesixty Compliance Services. The firms risk register is reviewed quarterly by the R&G committee. c) Risk management and control is the responsibility of all staff, escalating ultimately to the directors. Compliance will be expected to ensure that specific actions which have been agreed to manage and mitigate risk are implemented, under supervision by the directors. d) Wherever possible, risk management processes will be embedded into the day to day management of the firm.

The firm has identified some of the material risks which will have a significant effect, now and, or in the future on the firm’s ability to achieve its business goals and objectives. These risks are listed below however, please read this in conjunction with the risk register.

Competition Risk AWM operates in a competitive environment and faces the risk of client loss from a failure to respond to market changes. AWM seeks to minimise this risk through its investment in its staff. AWM regularly reviews and benchmarks its remuneration packages in order to retain and recruit high quality staff.

4. Best Execution Policy

Overview

It’s in the interests of our clients and our firm that we obtain the best possible result when placing orders for execution on behalf of our clients, with third parties, such as platforms, fund managers or stockbrokers. We’re required to take all sufficient steps to provide best execution when carrying out such transactions and, on your request, to provide you with a copy of the policy that we have adopted to achieve that objective.
This best execution policy applies to orders in investments such as funds and other securities. You should read this policy in conjunction with your client agreement.
Execution venues and third parties An execution venue is effectively a trading venue such as a regulated stock market where investment transactions are executed. Our firm doesn’t execute orders or deals directly with execution venues. Instead, we’ll place orders on behalf of our clients with appropriate third parties as explained below: - Investments on a platform or with a custodian bank: for investments held on our preferred platform(s) (an online investment administration service) or custodian bank, client orders will be placed directly with the relevant platform. These are Credit Suisse & Seven Investment Management in the UK and UBS, Lombard Odier, Julius Baer and Credit Suisse in Zurich. - Investments not on a platform: for investments held directly with individual fund managers, client orders will be placed directly with the relevant fund manager for the particular investment. - Stocks and shares: we use our client’s custodian or platform, as above.

We’ll regularly assess the third parties available to us to identify those that will enable us, on a consistent basis, to obtain the best possible result when arranging the execution of your orders. The above list will then be updated, where necessary, following such assessment.
The third parties have responsibilities in relation to best execution and client order handling themselves. We’ll also undertake periodic monitoring to ensure that they’re meeting the relevant requirements.

Execution Factors

When transmitting orders to a third party, we’ll make every effort to ensure the best possible result for our clients taking into account the following factors: - Price - Cost - Speed - Likelihood of execution and settlement - Size - Nature of the order - Any other considerations relevant to the execution of the order For retail clients, the price and cost of execution of the order will normally be the most important aspect in obtaining the best possible result. We’ll therefore assume that this is the most important outcome for your transaction unless you tell us otherwise. Client specific instructions If you’ve given instructions that price is not the most important factor in executing your instructions, we’ll make every effort to comply with your instructions but cannot guarantee this. This may be due to either the nature of the order, or the type of investment you wish to trade in. We’ll make all decisions as to where the orders are placed and won’t usually accept specific instructions from clients regarding which third parties to use, such as a particular broker. If we do accept any client specific instructions you should be aware that this may prevent us from following the processes set out in this policy which have been designed to obtain the best possible results for the execution of those orders in respect of the elements covered by those specific instructions.

Charges

It’s our policy that commission and charging structures won’t influence either the selection of third parties to which we place client orders, or the order flow that follows as a result of the execution process. We’ll therefore not discriminate between the third parties used to arrange execution of your orders.

Monitoring and Review of our Execution Policy

We’ll regularly monitor the effectiveness of our best execution policy to identify and, where appropriate, correct any deficiencies. In particular, this will cover the third parties to which we transmit client orders in terms of their quality of execution. This review will be carried out regularly (on at least an annual basis) or whenever a material change occurs that affects our ability to continue to obtain the best possible result for our clients.
Publishing trading volumes On an annual basis we’ll publish details on our website of the top five entities to which client orders have been transmitted, by volume and information on the quality of execution obtained. Staff understanding All relevant staff are made aware of this policy to highlight and emphasise the importance of best execution.