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Advice services

Throgmorton Private Capital Ltd is authorised and regulated by the Financial Conduct Authority (FCA). FCA Number 431157. You can check this on the FCA’s Register by visiting the FCA website, or by contacting the FCA on +44 (0)800 111 6768.

Throgmorton Private Capital Ltd is permitted to advise upon and arrange transactions on your behalf for investments and non-investment insurance contracts. 

Prior to providing you with any advice we will take time to understand your current needs, circumstances and attitude and tolerance to risk. Any advice provided to you will be confirmed in writing.

Investments and pensions

As independent financial advisers, we offer independent advice. This means that we offer unbiased, unrestricted advice based upon a comprehensive analysis of the whole of the market that gives due consideration to the full range of retail investment, pension and life products that may be suitable for you. 

We use a systematic investment process that has been designed to promote consistent and robust outcomes for our clients. As part of this process we have formed a panel of investment products and funds, after conducting whole of market quantitative and qualitative research and due diligence analysis. If suitable for your needs, we will select appropriate products from this panel when giving you advice. A copy of the panel is available on request.

If we feel your needs cannot be met by using products or funds from our Panel, after researching the whole marketplace we will recommend products that are better suited to your personal needs and objectives.

Non-investment insurance

We only offer products from a limited number of insurers for buildings and contents insurance. Ask us for a list of insurers from whom we offer insurance. Any non-investment insurance products that we arrange for you will not necessarily be kept under review.

Advice options

We offer a variety of advice options including:

  • Execution only (where we are instructed by you and no financial advice is sought or given)
  • Focused advice (advising you on limited aspects of financial planning only)
  • Full financial advice (a full financial review based upon all aspects of financial planning)
  • Ongoing Service (reviewing your financial situation and planning arrangements at least annually)

Investment objectives and restrictions

Following the issue of this document, any subsequent advice or recommendations offered to you will be based upon your stated objectives, your attitude and tolerance to investment risk and any restrictions you wish to place upon the type of investments, policies, or companies you are willing to consider. Details of your stated restrictions and objectives will be included in the Suitability Letter that we will issue to you to confirm our recommendation(s). Unless confirmed in writing to the contrary, we will assume that you do not wish to place any restrictions upon the advice that we give you.

Transacting business

By signing this Agreement, you are giving your Adviser permission to accept paper and electronic instructions to transact business on your behalf. This will be especially relevant to switching investment funds. To help prevent fraud, we will not accept electronic instructions to encash investments. We do not have call recording facilities and therefore verbal instructions cannot be accepted. Any instruction received will be considered to be genuinely given and duly authorised.

Termination of our services

You or we may terminate our authority to act on your behalf at any time. Notice of this termination must be given in writing. The termination will be without prejudice to the completion of transactions already initiated, if this is the case. Any transactions effected before termination and a due proportion of any charges for services accrued shall be settled to the date of this notification. This means that where we have agreed the services that we will provide for you and we have agreed to receive payment for these, either by means of a fee for investment business or by receiving commission from a provider for non-investment business you will have to pay us for any work we have completed up to the date of termination.

Client classification

Each client with whom Throgmorton Private Capital Ltd does business is categorised to identify the level of regulatory protection applied. We believe in providing clients with full regulatory protection and so normally classify all clients as ‘retail clients’ for investment business and as ‘consumers’ for non-investment insurance business, which means you are afforded all protections under the rules of the Financial Conduct Authority (FCA). Please note that should you wish to be considered as a different category of customer for investment business, such as a professional client or eligible counterparty, you must inform us in writing.

Your adviser will inform you should your circumstances dictate that we would need to classify you differently for non-investment insurance business.

In such circumstances, we will provide you with a new client agreement and you may lose a number of protections which will be outlined in that new agreement.

Where we categorise a client as anything other than ‘retail’ and or ‘consumer’, you may request re-categorisation to a category that provides a higher level of regulatory protection. We reserve the right to agree to any such recategorisationon a case-by-case basis. However, where we agree to do so, it does not mean that you will have a right to access the Financial Ombudsman Service (FOS).

Methods of communication

Unless you advise us otherwise, we will communicate with you via the following methods of communication: face to face, e-mail, telephone, letter and fax.

Client money

Throgmorton Private Capital Ltd does not hold client money, unless it is a cheque in settlement of our professional fees or disbursements. We do not handle cash.

Data protection

You may be assured that we will treat all personal data and sensitive personal data as confidential and will not process it other than for a legitimate purpose. Steps will be taken to ensure that the information is accurate, kept up to date and not kept longer than is necessary. Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss, or destruction, or damage to the data. The information you have provided is subject to the Data Protection Act 1998. By signing this document you consent to us, or any company associated with us, for processing, manually and by electronic means, your personal data and sensitive personal data for the purposes of providing advice, administration and management.

If, at any time, you wish us, or any company associated with us, to cease processing your personal data and sensitive personal data, or contacting you for marketing purposes, please contact the Data Protection Officer on +44 (0) 1304 371 753, or in writing at Throgmorton Private Capital Ltd. 31-33 High Street, Deal, Kent CT14 6EL. Subject to certain exceptions, you are entitled to have access to your personal data and sensitive personal data held by us and any company associated with us. You may be charged a fee (subject to the statutory maximum) for supplying you with such data. For details of our Data Protection Statement and policy, please see our Data Protection Statement and Consent Form, which is incorporated into our Financial Review Document (Fact Find).


If you wish to register a complaint against us, please contact us in writing at the above address or telephone us on: +44 (0)1304 371753. If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service (FOS) at

Compensation arrangements

We are covered by the Financial Services Compensation Scheme (FSCS). You may be entitled to compensation from the Scheme if we cannot meet our obligations. This depends on the type of business we advise you about and/or arrange and the circumstances of the claim. If you would like further information, details are available at or telephone 0800 678 1100.


Most types of investment business are covered under the FSCS for 100% of the first £50,000. The maximum compensation is £50,000.

Insurance and pensions

Advising upon and arranging insurance and pensions is covered under the FSCS for the full value of claim with no upper limit.

Self invested personal pensions (SIPPs)

Please note that advising upon and arranging SIPPs may not be covered up to the full value of the claim. Depending upon the type of investment(s) within a SIPP, cover may be:

  • up to the full value of the claim, or
  • only up to a maximum of 100% of the first £50,000, or 
  • up to £75,000 if the money is held in a deposit based investment, or 
  • there may be no cover under the FSCS whatsoever

Deposit based investments

Most types of deposit based investments are covered under the FSCS for 100% of the first £75,000 with each bank or banking group. The maximum compensation is £75,000 per individual client.

Further information about compensation scheme arrangements is available from the FSCS.

Accounting to you

We will forward to you all documents showing ownership of your investments as soon as practicable after we receive them; where a number of documents relating to a series of transactions is involved, we will normally hold each document until the series is complete and then forward them to you.

Conflicts of interest

Throgmorton Private Capital Ltd. offer independent financial advice in accordance with this agreement. Occasions may arise where we or one of our other clients have some form of interest in business that we are transacting for you. If this happens, or we become aware that our interests, or those of one of our other clients conflict with your interests, we will inform you in writing and obtain your consent before we carry out your instructions and detail the steps we will take to ensure your fair treatment.

We have arrangements in place to ensure that our clients are treated fairly and we have a conflict of interest policy in place to help us manage the risks. Further details of our conflict of interest policy are available on request.

Best execution

It is our policy to transact your business in order to achieve the best results in terms of the nature of the products selected, transaction charges, administration and service excellence. Further details of our policy regarding Best Execution are available on request.

Rights to change your mind

We will inform you of your statutory right to change your mind. The Distance Marketing Directive normally grants you 30 days in which to cancel a life or pension contract. However, there may be occasions where no statutory rights are granted, although this will be explained to you before any contract is arranged on your behalf.

Refunds and cancellation policy

Our fees are payable subsequent to our professional advice services being provided and are therefore not refundable in normal circumstances. Fees paid in respect of Ongoing Service are not refundable. However, any ongoing services may be cancelled at any time upon request. Please also see ‘Rights to change your mind’ above, in respect of cancelling individual products or policies.

Should a refund be required due to any element of dissatisfaction on your part, this should be addressed via our normal Complaints Procedure as noted above. We will always try to resolve the issue to your satisfaction.

Information from third parties

We will endeavour to provide our services and advice as soon as is practical, but are often dependent upon the provision of information from third parties. We will keep you informed of progress in the preparation of our services and advice.

Governing Law

These terms shall be governed by the laws of England & Wales.

Dispute resolution mechanism

Any dispute arising out of or in connection with this contract, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration under the London Court of International Arbitration (LCIA) Rules, which Rules are deemed to be incorporated by reference into this clause.

The number of arbitrators shall be one. The seat, or legal place, of arbitration shall be London. The language used in the arbitral proceedings shall be English. The governing Law of the contract shall be the substantive Law of England & Wales.