Conduct Risk

Conduct Risk Policy

Robert G Sinclair & Co is committed to ensuring that all customers and clients who come into contact with us receive the best customer experience. This is achieved through adherence to our Treating Customers Fairly Policy and our Conduct Risk Policy.

Our Conduct Risk Policy shall function to ensure that the customer experience is central to our ever day work.  We seek to ensure that the customer does not incur any risk from any conduct of our office or staff.

Our 10 Conduct Risk Principles are:

  1. Integrity – We must conduct our business with integrity, we must not prioritise profits over ethics and commercial interests over consumer interests.
  2. Skill, care and diligence – We must conduct our business with due skill, care and diligence.
  3. Management and control – We must take reasonable care to organise and control our affairs responsibly and effectively with adequate risk management systems in place.
  4. Market conduct – We must observe proper standards of market conduct
  5. Customers’ interests – We must pay due regard to the interests of our customers and treat them fairly.
  6. Communications with clients – We must pay due regard to the information needs of our clients and communicate information to them in a way that is clear, fair and not misleading.
  7. Conflicts of interest – We must manage conflicts of interest fairly, both between ourselves and our customers and between a customer and another client.
  8. Customers: relationship of trust – We must take reasonable care to ensure the suitability of our advice and discretionary decisions for any customer who is entitle to rely upon our judgement.
  9. Relations with regulators – We must deal with our regulators in an open and cooperative way.  We must disclose to the appropriate regulator anything relating to the firm of which that regulator would reasonably expect notice.
  10. Governance arrangements – We must have robust governance arrangement in place which include a clear organisational structure with well defined, transparent and consistent lines of responsibility and effective processes to identify, manage, monitor and report the risks we are or might be exposed to.

These Conduct Risk principles are embedded into all aspects of our business via:

  • Conduct Risk training, competence and awareness raising initiatives;
  • Performance management of all team members to ensure that the right values and good behaviours are achieved and maintained;
  • Conduct Risk within our business is closely managed and monitored by the Conduct Risk Committee and the Conduct Risk Manager.

Robert G Sinclair & Co pays due regard to the interests of its customers and is committed to treating them fairly at all times.

We make Conduct Risk clear.

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