You’ll be aware from the definition of a breach that there are many conceivable instances where a breach could occur, but the most common breaches we have encountered, in no particular order, are listed below:

• Advertising – unapproved advert used
• Advertising – unapproved website or directory listing on the internet
• Sales Process – insufficient documentation retained to support your advice
• Sales Process – a ruling from our Advice Standards not followed correctly
• Data Protection – client documents stored on an incorrect record
• Data Protection – personal information shared with a third party not entitled to it
• Record Keeping – remedial work not carried out
• Record Keeping – a record of the sale not recorded on The Key within required timescales

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Please observe the FPG Complaints policy for full information

Early or Quick Resolution Complaints (formerly “non-reportable complaints”)

• If the complaint is generally “service based” and it can be resolved to the customer’s satisfaction within three business days of receipt, then these complaints can be dealt with by the AR Firm.
• These complaints still need to be recorded on your Complaints Log as FPG will need to inform the FCA on a 6 monthly basis.
• You must notify the customer of their FOS rights in your resolution communication and the client can then take their complaint directly to FOS should they so wish.
• If not resolved within three business days, all complaints (whether service or advice based) become reportable under FCA jurisdiction and will need to be handled by Pete Burgess.

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A conflict of interest arises when our dealings with clients could be affected by a personal interest or personal association. It becomes significant if an independent third party might reasonably take the view that there is a risk of the resultant actions (or those of a personal associate) being affected, whether or not they are actually affected.

Further Information Concerning ‘Conflicts of Interest’.

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Finance Planning recognises that a conflict of interest may arise where a payment or non-monetary benefit is offered or accepted by, or on behalf of, a Finance Planning Representative. Further, it is Finance Planning’s will to fully comply with the Bribery Act 2010 and create a zero-tolerance approach to corruption and bribery.

For more information on Inducements, gifts and hospitality please click here.

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This form is to be used when referring a case to FPG for guidance involving suspicious activity, including fraud, financial crime, money laundering or any other suspicions of criminality.

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When you do a Self Sale, you will need to confirm to Pete Burgess and/or your Supervisor that you realise you are doing the application on an Execution Only basis and that no advice will/has been given to you [or your partner, if applicable]. Also that in doing the application you understand that at no time in the future will you [or your partner, if applicable] be able to make a complaint to FPG, or about FPG, in regards to you [both] taking out the policy/ies.

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As part of that commitment, FPG encourages Advisers, ARs, employees or others with serious concerns about any aspect of work to come forward and express those concerns. We recognise that you will have a need to come forward on a confidential basis and want to make it clear that you can do so without fear of reprisal or victimisation.

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Any individual who accesses, uses or manages Personal Inform is responsible for reporting data breach and information security incidents immediately.

If the breach occurs or is discovered outside normal working hours, it must be reported as soon as is practicable.

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