List of Rowan Dartington policies

1. Order Execution Policy (formerly Best Execution Policy)
2. Conflicts of Interest Policy
3. Complaints policy
4. Client money notice
5. Shareholder Engagement Disclosure Statement
6. Investment Firm Prudential Regime Public Disclosures
7. Candidate privacy policy
8. Central securities depositories regulation (CSDR) article 38(5) and article 38(6) participant disclosure
9. Whistleblowing Policy
10. Third Party Notices
11. Performance Disclaimer

1. ORDER EXECUTION POLICY (formerly Best Execution Policy)

This Policy sets out how Rowan Dartington (“we” or “us”) will ensure that we will obtain the best possible result for you when executing trades on your behalf when required under the EU Markets in Instruments Financial Directive (‘MiFID’) and corresponding rules of the Financial Conduct Authority (‘FCA’). We appreciate that some of the terms used in this policy may not be familiar to everyone - to help with your understanding of this policy, we have included a glossary of key terms and definitions, at the back of this policy.

Best Execution  

We will take steps to achieve the best possible result, subject to different factors which are dependent on the financial instrument and the type of market on which the order is executed. We will treat all client orders the same for the purposes of achieving best execution or getting the best possible result for you when carrying out trades.

Factors When Executing Your Order

The relative importance of the execution factors below will be determined by us based on market experience and judgement of our investment professionals in light of all available information at the time of the order.  

When executing client orders, we will take account of the following execution factors, in no particular order: 

• size and nature of the order – where an order is larger than the normal market size it will affect the method of execution
• price – the price in the market
• costs - the additional charges for using a particular venue such as the third-party brokerage charges, exchange fees, any settlement cost and FX charges
• speed of execution – will depend on the liquidity and volatility of markets
• likelihood of execution and settlement - reflecting the market liquidity and settlement performance of the counterparty
• type and characteristics of the financial instrument
• characteristics of the possible venue
• any other factor considered relevant to the management of the order.

The best possible result will normally be determined in terms of the total consideration, being the price of the instrument and the costs of the transaction, those costs being all expenses incurred which are directly related to the execution of the order. However, there may be circumstances in which this is not the primary consideration. Where the instrument is illiquid or the size of the order unusual relative to the normal, then other factors may take precedence, although we will also have to use our judgement in assessing whether particular trading strategies may move the market (incur implicit costs). Alternatively, we may have to execute the order over the course of a number of working days in order to complete it. Likewise, the characteristics of an order may require us to transmit an order to a counterparty to execute on our behalf, rather than dealing directly with that counterparty (for example, orders in securities traded on overseas markets).

Our Dealing Arrangements    

UK Equities

In normal market conditions and for orders concerning liquid (i.e. frequently traded) UK equities, we will use our order management system to identify the best available terms by polling a variety of execution venues including the RSP network. Large or illiquid orders will be executed on a manual basis by our in-house dealing team. In such cases our dealers will source the best available terms by comparing the prices offered by a variety of market participants (including other regulated firms and MTFs) with reference to market data.

Overseas/International Equities 

These will normally be executed on the following basis:

• For CREST deliverable securities, we will use our order management system to identify the best available terms by polling available execution venues. Larger orders will be executed on a manual basis as per the arrangements for UK equity orders and through our network of market counterparties.
• For overseas delivery securities (traded locally in the relevant domestic market), we will use our order management system to identify the best available terms by polling available execution venues (including other regulated firms). Large or illiquid orders will be executed on a manual basis using our network of local market participants (including MTFs) to source the best available terms.

Collective Investment Schemes / UCITS

We execute orders in collective investment schemes / UCITS either directly with the fund manager or through a third party. Orders are executed on negotiated terms, not generally available to individual clients.

Debt Securities

For smaller debt security orders, we will use our order management system to source the best available terms from a variety of bond market participants. For larger orders and less liquid bond instruments, we will utilise its network of Tier 1 and secondary market participants to source the best available terms. UK Government Bond orders (gilts) may be executed via our order management system or on a negotiated basis via our network of market counterparties.

Exchange Traded Funds (ETFs)

In normal market conditions and for liquid ETF orders, we will use our order management system to identify the best available terms by polling available execution venues. Larger or less liquid orders will be executed on a manual basis as per the arrangements for UK equity orders.

Structured Products

Structured products are executed with the product provider concerned. In such cases the Product Provider is the sole execution venue for that product. We follow an established internal process to analyse and compare market data, ensuring a fair price is obtained for our clients.

Where we believe that best execution can be achieved for you outside Regulated Markets or Multilateral Trading Facilities, it is our policy to do so.  

Execution Venues

We regularly assess the execution venues available and may add or delete venues in accordance with our obligation to provide you with the best possible execution result on a consistent basis. An up-to-date list of significant execution venues is attached below.  

The selection of counterparties and trade routing mechanisms is based on an assessment of factors such as market coverage, liquidity access, trading competitiveness, settlement risk and creditworthiness of the counterparties and quality and cost of clearing and settlement.

This enables us to obtain on a consistent basis the best possible result for the execution of transactions. In satisfying this policy, we may consider the use of one or more of the following venue types:

• Regulated Markets (e.g. London Stock Exchange or overseas equivalent)
• Multilateral Trading Facilities (e.g. Non-Exchange Financial Trading Venues)
• Systematic Internalisers (e.g. Market Makers)
• Third party investment firms and/or affiliates acting as Market Maker or other liquidity providers
• Non-EU entities performing similar functions

Our execution arrangements and venues are reviewed on at least an annual basis or whenever a material change occurs that affects our ability to obtain the best possible result for our client orders. We will inform you of any material changes to our execution arrangements or our Order Execution Policy.

When you give us specific instructions regarding the execution of an order, or part of an order, we will execute in accordance with those instructions. However, it is acceptable to postpone execution of an order, if this is considered to be in your best interests.

If you instruct us to execute an order for you at a limit price, we will still consider cost, speed, likelihood of execution and settlement. We are required to make your order public unless you expressly request otherwise. By agreeing to this Policy, you agree that we will not make your order public unless we consider it to be in your best interests to do so.

Specific instructions given by you, which may prevent us from following our execution policy to obtain the best possible results in respect of your instructions, will be confirmed to you prior to the execution of your trade. We will apply our policy to all other aspects of the trade.

Aggregation and allocation of orders

We may aggregate orders that you place with us with those of other clients, provided that:

• it is unlikely that the aggregation of the orders and transactions will work overall to the disadvantage of any client whose order is to be aggregated; and
• it is disclosed to each client whose order is to be aggregated that the effect of aggregation may work to that client's disadvantage in relation to a particular order.

The policy and procedures ensure no specific client is treated differently when consideration is given to the market impact and timeliness of the execution of orders. The order aggregation process through averaging as the security price moves over the period will ensure all clients receive the same price. The process treats all clients fairly to ensure overall no one client receives a better price and therefore disadvantage other clients.

If we aggregate multiple client orders, we will allocate all orders fairly, including where an aggregated order is partially executed, taking into account the volume and price of the orders.

Review and Monitoring

We will regularly monitor the quality of our execution against the factors detailed in this Policy to identify and, where appropriate, enhance our arrangements. This includes:

• discussions between our traders and counterparties on an order-by-order basis.  
• Information as published by the execution venues.  
• the use of transaction cost analysis tools to assess trading performance.  
• a formal review of counterparty financial strength and operational efficiency.  

This Policy will be reviewed and updated at least annually and was last reviewed in March 2025.

A Best Execution Governance Forum is responsible for oversight of the delivery of good client outcomes including delivery of best execution. The group receives management information including execution quality and adherence to policy.  

General

By signing the declaration in the account opening form, you consent to our Order Execution Policy including those sections that require your prior express consent. We are unable to open an account for you if you do not consent to this Policy. 

Counterparties 

The table below lists the counterparties on which we place general reliance: 

Glossary

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3. COMPLAINTS POLICY

Procedures

We are sorry you have cause to complain to Rowan Dartington.

Our aim is to resolve any client concerns fairly, effectively and promptly.

Rowan Dartington & Co Ltd always aims to provide the highest standard of service to its clients but on occasions we may fall short of this goal leaving clients and potential clients dissatisfied.

When we receive any letter, fax, email, telephone call or personal communication which expresses dissatisfaction about services which we have provided or failed to provide, we will attempt to resolve the matter promptly and fairly. Consumers will also be able to tell us at any point that they don’t want to take their complaint any further.

Where possible, please include the following details with your complaint:

• Your full name, address, account reference and your telephone number to contact you on;
• A full description of your complaint and any details you can provide on what you feel would be appropriate in order to resolve your complaint, and;
• Any relevant documentation you wish us to consider as part of the complaint investigation

If complaining on behalf of another person, you must be authorised to do so and we reserve the right to contact the individual who you are complaining on behalf of to confirm.

How to make a complaint

You can refer your complaint to Rowan Dartington via any form of communication, but where possible, please use the following contact details:

Address: Complaints Team, Rowan Dartington, PO Box 13197, Chelmsford, CM99 2GG

Email: complaints@rowan-dartington.co.uk

Telephone: 0117 933 0050

Expressions of Dissatisfaction

Where possible, we will look to resolve the issue by close of business 3 days after receipt of your complaint and we will write out to you confirming resolution. You still have the right to refer your complaint to the Financial Ombudsman Service (details below) and/or the alternative dispute resolution (ADR) service should you not be happy with the outcome.

Acknowledgment of Complaints

Where it is not possible to resolve the issue within 3 business days, our Complaints department will complete an investigation.

If this applies, we aim to issue an acknowledgement to you within 5 business days, detailing our understanding of your concerns and confirming the next steps.

Complaint Resolution

We will collate all the documentary evidence relevant to your complaint and, where applicable, ask for the comments of any individual involved. It may also be necessary for us to contact third parties for information.

During the investigation

Once we have done this, we will review the evidence, make our assessment and let you know the outcome of our investigation in writing.

• Where your complaint has not been resolved within four weeks of receipt and we have not had regular communication with you (for example, during periods of high complaint volumes), we will issue a four week holding letter to explain why we need more time to complete the investigation and indicate when we expect to be able to respond fully.
• If our investigation is going to take longer than 8 weeks, we will write to you to explain why and let you know when we expect to be able to conclude matters. This letter will also inform you of your right to refer your complaint to the Financial Ombudsman Service (see ‘Your Rights’ below), if applicable.

At the end of the investigation

When we have finished our investigation we will write to you with our full response to the concerns you raised.

Our final response will set out:

• the facts which have been established during the investigation; and
• any resolution to be offered.

This resolution will consider:

• Fair compensation for actual or potential financial loss;
• Any reasonable costs you have claimed;
• Lost interest which could have accrued since the date on which any possible loss was suffered; and
• Fair redress for any inconvenience or distress.

Your Rights

If you are not completely happy with the outcome and resolution of your complaint, you have additional rights to independent review or assistance. These additional rights are set out below:

Financial Ombudsman Service

You have the right to refer a complaint directly to the Financial Ombudsman Service if we have had an opportunity to consider it and have either:

• Supplied you with a final response; or
• 8 weeks have elapsed since we have received your complaint and a final response has not been issued.

More information on the Financial Ombudsman Service can be found here: http://www.financial-ombudsman.org.uk or you can contact them using the below details:

Address: The Financial Ombudsman Service, Exchange Tower, London, E14 9SR

Email: complaint.info@financial-ombudsman.org.uk

Telephone (from within the UK): 0800 023 4567

Telephone (from outside the UK): +44207 964 0500

Within our final formal response letter to your complaint, we will include a link to the ‘Want to take your complaint further’ booklet (https://www.financial-ombudsman.org.uk/businesses/resolving-complaint/ordering-leaflet/leaflet).

Time limits for referral to the Ombudsman

In line with current rules, you will have six months from the date of our final reply to refer your complaint to the Financial Ombudsman Service if you remain unhappy with our response.

The Financial Ombudsman Service might not be able to consider your complaint if:

• What you are complaining about happened more than 6 years ago; and
• You are complaining more than three years after you realised (or should have realised) there was a problem.

If you do not refer your complaint in time, the Ombudsman will not have our permission to consider your complaint and will only be able to do so in very limited circumstances.  For example, if the Ombudsman believes that the delay was as a result of exceptional circumstances.

Alternative

If you remain unhappy and do not agree with the Financial Ombudsman’s final decision, you are able to:

• Utilise an alternative dispute resolution (ADR) entity (this gives you access to an independent professional to review or assist with your complaint);
• Potentially able to take civil action.

More information on ADR can be found on the Citizens Advice website:

www.citizensadvice.org.uk

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4. CLIENT MONEY NOTICE

As a firm which is both authorised and regulated by the Financial Conduct Authority (FCA), Rowan Dartington is required to comply with the rules prescribed in the FCA Handbook. The handbook details rules on handling both client assets and client money.

Banks Used by Rowan Dartington for holding Client Money

Please note that Rowan Dartington maintain Client Money accounts with:

- Bank of New York Mellon

- Bank of Scotland Plc

- Barclays Bank Plc

- Lloyds Bank Plc

- National Westminster Bank Plc

If you hold client money with us, the amount held will form part of the compensation limit for any claim you make under the Financial Services Compensation Scheme (FSCS) and should be considered alongside any other cash holdings you have.

For more information please refer to the FSCS website at https://www.fscs.org.uk/.

Rate change with effect from 1 January 2026

With effect from 1 January 2026, the rate of interest paid by Rowan Dartington on cash balances will reduce from 1.7% to 1.6% gross.

Interest will be calculated on daily balances and paid quarterly in arrears, within five working days of the end of the quarter. Individual products, such as General Investment Accounts, ISA and JISA accounts, will be treated separately for the purposes of calculating and paying interest.

Interest will be paid on cash balances held in GBP, EUR, USD, SGD & AUD subject to a de minimis of 1 currency unit, e.g. £1, €1, $1 etc. Interest will be paid on all products where a balance in either stock or cash is held at the end of the quarter.

As interest is paid gross, it is your responsibility to report and pay any tax due under self-assessment to HM Revenue and Customs (HMRC) or any other relevant tax authority.

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5. SHAREHOLDER ENGAGEMENT DISCLOSURE STATEMENT

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8. CENTRAL SECURITIES DEPOSITORIES REGULATION (CSDR) ARTICLE 38(5) AND ARTICLE 38(6) PARTICIPANT DISCLOSURE

Introduction

The Central Securities Depository Regulation (CSDR) is an EU regulation that governs how Central Securities Depositories (CSDs) and their participants operate. Rowan Dartington is a direct participant of CREST (Euroclear) as our CSD.

Rowan Dartington can offer our clients the choice between holding their qualifying assets at CREST with all other clients in an Omnibus Segregated Account (OSA), which is our default option for all clients, or in an Individual Client Segregated Account (ICSA) at separate cost.

We have clarified the levels of protection and the costs associated with the different levels of segregation that we provide in respect of securities that we hold directly for clients with our CSD, in the two disclosures linked below.

How the omnibus vs segregated accounts work and costs involved

We make two types of accounts with CREST available to clients:

• Omnibus Segregated Accounts (“OSAs”). These are used to hold the securities of a number of clients on a collective basis and are Rowan Dartington’s default account. We record each client’s individual entitlement to securities that Rowan Dartington holds for that client; and
• Individual Client Segregated Accounts (“ICSAs”). This account type is used to hold the securities of a single client and therefore held separately from the securities of other clients.

There is no difference with either of these accounts as to how we manage and look after your investments.

It is only possible to segregate listed assets that settle in CREST, the UK settlement system.

If you decide you would like to have your assets held in an individual segregated account, there will be an additional charge, details of which can be found in our CSDR Article 38 Costs Disclosure Document which can be found below.

Please ensure you have read our terms and conditions for the service and our Article 38(6) CSDR Participant Disclosure Document, as this sets out how segregation of assets interacts with English Insolvency Law.

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11. Performance Disclaimer

Past performance is not a reliable guide to future performance. The value of shares and the income from them can fall as well as rise and investors may get back less than they originally invested. The sterling value of overseas investments, and the income from them, is subject to foreign exchange fluctuations.

ARC Indices are published monthly by Asset Risk Consultants. They are an independent organisation who gather real portfolio data from over 100 subscribing Discretionary Fund Managers in the industry. The ARC indices are estimates within the latest calendar quarter which are finalised retrospectively when the quarterly data is received from subscribers. The estimates are updated on approximately the 6th working day of each month and will reflect the previous months data until that date.

ARC categories differ from Rowan Dartington risk categories and should therefore be used for guidance, in tandem with the other Indices to put the portfolio performance in perspective.

We have opted to include ARC as they are an industry standard peer comparator which allows us to measure our performance against other portfolio providers.

We include benchmark indices to provide a clear point of comparison for your portfolio’s performance. These indices represent the broader market or a specific asset class and help you see how your investments are doing relative to general market trends.

Whilst every effort is made to ensure that the schedules within this performance report contain a complete and accurate record of your holdings, we are unable to accept any liability for inaccuracy and omissions for holdings in your own name.

Any commissions, fees or other charges included within these performance figures have been previously agreed with you and notified to you on contract notes, our rate card, our terms of business or by invoice.

This performance report includes portfolio management fees but excludes adviser fees. Transactions are included as at the trade or transfer date.

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