Round Financial Limited (“we”, “us”, “Round” “the firm”) is a company registered in England and Wales (company number: 14609702). Round is an appointed representative of WealthKernel Limited which is authorised and regulated by the Financial Conduct Authority (FRN: 723719).
Round aims to to provide corporate treasury services through acting as a distributor of Money Market Funds an introducer to Insignis Cash
As an appointed representative of WealthKernel, Round provides investment services to Customers who are classified as Retail or Professional Clients for the purposes of the FCA Rules. All customers of Round will be SME entities/corporate, opposed to private individuals.
Our Commitment to Vulnerable Customers – The Financial Conduct Authority (FCA) requires all firms within financial services to recognise and understand the impact that life events, health, resilience, and financial capability may have on their customer’s needs. At Round, we’re committed to making sure that all or our customers, including vulnerable customers, are treated fairly and have equal access to Round’s products and services.
Whilst Round’ Target Market is SME corporates we have implemented a Vulnerable Customer policy within our business to ensure we can take steps to look after the interests of business owners or representatives during times of vulnerability. This policy sets out our expectations when dealing with vulnerable customers.
We acknowledge that vulnerability can take many forms, and is specific to each individual customer. You can let us know by emailing help@roundtreasury.com
Round is committed to ensuring that all customers, including vulnerable customers, are treated fairly, and have equal access to Round’s products and services.
The FCA’s definition of a vulnerable customer;
Is “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care”
The FCA considers that the following factors act as drivers to actual or potential vulnerability:
An individual may suffer from one or more of these types of vulnerability at the same time, which may make them especially susceptible to harm.
The FCA also has regard to the general principle that financial services firms should be expected to provide customers with a level of care that is appropriate, having regard, amongst other things, to the capabilities of the customers in question. The level of care appropriate for vulnerable customers may therefore be different from what is required for other customers.
Round’s Vulnerable customer policy acts in accordance with the Equality Act 2010, which provides it is illegal to discriminate and strengthens protection for specific protected characteristics. This means when a customer who has a disability is identified through ANNA’s operational processes or service, reasonable steps must be taken to ensure they are treated equally, fairly and with respect.
Round acts in accordance with the requirements of the General Data Protection Regulation (GDPR). In practice, this means that Round colleagues are required to obtain explicit consent from the customer regarding the recording of information, including where relevant the medical data (the vulnerability) and the duration of any vulnerability, for example, whether the vulnerability is thought to be temporary or permanent. Round will only record relevant and legitimate interest information to ensure data is accurate and reflective of the customer’s most recent circumstances.
Where possible Round will record any specific requests by a customer rather than the actual vulnerability. Round will be required to obtain the customer’s consent before making a record of the vulnerability .
Round will approach dealing with vulnerable customers on a case by case basis. In addition it will ensure they are identified and handled appropriately. Round’s approach to identifying vulnerable customers and the processes and controls that it has in place to protect customers throughout the lifecycle of their account will vary however its policy is as follows.
The FCA expects firms to be able to spot a vulnerable customer should they provide personal details during a call or in customer correspondence and respond appropriately to this information.
Round employees and contractors receive training for communicating with vulnerable customers to ensure they are empowered and trusted to be alert to the signs that the person they are talking to may not have the capacity, at that moment in time, to make a decision or provide the correct information. As such, relevant Round employees are expected to be able to confidently and competently effectively identify the customers’ needs and adjust their approach accordingly.
Vulnerabilities come in various forms and FCA identified 4 drivers of vulnerability and 23 indicators however not all of these will apply to Rounds SME customers.
Round and its employees will:
Round’s Compliance team will undertake regular reviews to report to the senior management any indicatoes of risk or breaches.
We will review and monitor on at least an annual basis the effectiveness of its order handling and best execution arrangements as documented in this Policy in order to:
We shall notify you of material changes to this Policy or once we have been notified of any changes to the Custodian’s best execution principles which may impact how your orders are transmitted and / or executed.
Customers are deemed to consent to this Policy when they agree to our Terms of Service.
