Vulnerable Customer Policy

Introduction

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).

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Background

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.

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Purpose

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.

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Vulnerable Customer Policy

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.

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Please let us know if you are experiencing any indications of vulnerability

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

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Introduction

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:

1. Health – health conditions or illnesses that affect the ability to carry out day to day tasks, both permanently and on a temporary basis
2. Life events – major life events such as bereavement or relationship breakdown
3. Resilience – low ability to withstand financial or emotional shocks
4. Capability – low knowledge of financial matters or low confidence in managing money

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.

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GDPR and Equality Act 2010

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 .

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Process and control

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:

1. Ensure they listen to what the customer is saying or writing, and look out for triggers or clues to vulnerability
2. Take reasonable steps understand the issue and reasons behind any difficulties the customer may be facing,
3. Set expectations clearly – whether this be over the duration of the process, or for the service as a whole
4. Apply discretion or adapt the existing process where appropriate
5. Where relevant clarify understanding asking questions such as ‘is there anything else you would like me to repeat or explain?
6. Ensure there are no barriers to the appropriate and fair treatment of a customer, including barriers to support throughout the product lifecycle and handling complaints
7. Where vulnerability is identified, this will be recorded accurately, sensitively and regularly reviewed for relevance in compliance with relevant GDPR rules.

Round’s Compliance team will undertake regular  reviews to report to the senior management any indicatoes of risk or breaches.

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Policy Review

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:

• identify and implement any required amendments to this Policy;
• ensure the Policy is fit for purpose; and
• ensure the Policy reflects any changes to Applicable Law.

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.

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Consent

Customers are deemed to consent to this Policy when they agree to our Terms of Service.

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