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Introduction

Foresight Advisors Limited (FAL), incorporated as a Private Limited Company in England and Wales (Companies House number: 13806331), is authorised and regulated (FRN: 975877) by the Financial Conduct Authority (FCA) in the United Kingdom to provide investment intermediation. FAL’s registered office is Salisbury House, London Wall, London, EC2M 5PS, and its place of business is 10 Woodlands Ride, Ascot, SL5 9HN, UK. FAL is registered with the Information Commissioner’s Office under number ZB304671.

Regulatory Context

In accordance with MIFIDPRU 8 the regulatory aim of the disclosures is to enable stakeholders and market participants an insight into how FAL is run. They also aim to help stakeholders make more informed decisions about their relationship with FAL.

Frequency

FAL will be making these MIFIDPRU disclosures at least annually. The disclosures will be as at the Accounting Reference Date (“ARD”) and published on the date FAL publishes its annual financial statements.

In particular circumstances (e.g. major change to FAL’s business model or merger), we will make more frequent public disclosures.

Proportionality

The level of detail provided in the qualitative disclosures is proportionate to FAL’s size and internal organisation and the nature, scope and complexity of FAL’s business activities.

Media and Location

The disclosure will be published on FAL’s website and free to obtain.

Changes to Information disclosed

FAL confirms that there are no significant changes to the information disclosed, when compared with the previous disclosure periods.

Verification

The information in this document has not been audited by FAL’s external auditors, as this is not a requirement, does not constitute any form of financial statement and must not be relied upon in making any judgement on FAL.

Background to FAL

Background

FAL is incorporated in the UK and is authorised and regulated by the FCA as an SNI MIFIDPRU investment manager and advisory firm and is therefore subject to the FCA’s Prudential Sourcebook for MiFID Investment Firms (“MIFIDPRU”). FAL meets all the criteria for small and non-interconnected (“SNI”) investment firms, detailed in MIFIDPRU 1.2, and is categorised as an ‘SNI investment firm’.

As an ‘SNI investment firm’ authorised and regulated by the FCA, FAL is required under Chapter 8 of MIFIDPRU to publish key information to assist users of its accounts and encourage market discipline.

FAL acts solely as an agent, so the main protection to our customers is provided through client money and asset arrangements. FAL’s most significant risks have been identified as business and operational risks. FAL has assessed business and operational risks in its ICARA Process and set out appropriate actions to manage them.

These disclosures are made by FAL on a solo basis as required by MIFIDPRU 8.1.7R.

In accordance with MIFIDPRU 8.1, as an ‘SNI investment firm’, the information which FAL is required to publish is limited to information relating to its remuneration policies and practices (per MIFIDPRU 8.6). Given FAL is an SNI firm, it can apply proportionality to its remuneration arrangements.

MIFIDPRU 8.6 – Remuneration

Qualitative Disclosure Text

The purpose of FAL’s remuneration policy is to set out how our firm will provide remuneration in form and amounts that are consistent with the FCA’s Remuneration Code (SYSC 19G), with the main objective of the financial incentives being to attract, motivate and maintain high-calibre employees.

The remuneration strategy has been designed to ensure consistency with the risk profiles and rules to ensure no conflict of interest between FAL’s staff and its clients and compliance with the conduct of business rules.

The decisions of the governing body/ Remuneration Committee on setting remuneration are based on risk management, supporting business strategy, objectives, values and interests and avoiding conflicts of interest, and measurement of performance. The leading rationale of the decision-making is to achieve the main objective of FA, and its clients, while remaining consistent with the risk profile of FAL’s business strategy.

FAL’s governing body considers remuneration in the context of a broader agenda, including retention, recruitment, motivation and talent development and the external market environment. It also receives updates on regulatory developments, general remuneration issues, and market and benchmarking data.

The various components of total remuneration, which comprise base salary and variable bonus, are considered and balanced appropriately regarding the overall firm performance.

Firm performance and the individual’s input are significant contributors to determining variable bonus awards. The principal objective in determining variable bonus awards is to reward individual contributions to FAL whilst ensuring that such payments are warranted given business results. In this context, performance can include financial and non-financial measures, for example:

• measures relating to building and maintaining positive customer relationships and outcomes, such as positive customer feedback
• performance in line with firm strategy or values, for example, by displaying leadership, teamwork or creativity
• adherence to the firm’s risk management and compliance policies
• achieving targets relating to environmental, social and governance factors and diversity and inclusion

There is a focus on differentiation so that any rewards are determined according to the contribution of individuals. All staff may be subject to variable remuneration. However, bonus pools and individual awards are subject to the discretion of the Board, and it is possible that in any year, no variable bonus will be awarded, either at all or to particular individuals. FAL may also impose vesting, retention, and clawback mechanisms to take into account FAL’s business cycle.

Quantitative Disclosures

Total Remuneration         

Fixed Remuneration          

Variable Remuneration

Important Information

This website is issued and communicated by Foresight Advisors Limited (FAL), incorporated as a Private Limited Company in England and Wales (Companies House number: 13806331), and authorised and regulated by the Financial Conduct Authority (Registration number 975877). FAL’s registered office is Salisbury House, London Wall, London, EC2M 5PS and its place of business is 10 Woodlands Ride, Ascot, SL5 9HN, UK. FAL is registered with the Information Commissioner’s Office under number ZB304671.

This website and any information and or communication contained herein is intended for use by and directed at authorised financial institutions and intermediaries, either “exempt” investors that are investment professionals or high net worth entities falling within articles 19 or 49 of the Financial Services Markets Act (Financial Promotion) Order 2005, or deemed to meet the relevant qualifying investor categories as defined in the Financial Conduct Authority (“FCA”) Conduct of Business (“COBS”) Rules and categorised as Professional Clients and Eligible Counterparties as set out in the FCA COBS Rules. Please be aware that FAL is not authorised to deal with private individuals or private investors deemed to be Retail Clients as defined by the FCA’s COBS Rules. This website is not directed at members of the general public or Retail investors and the information contained in this website must not be used or relied upon by Retail investors.

This website is exclusively intended for persons and entities who are resident in or accessing the website from the United Kingdom.

The contents of this website have been prepared solely for information purposes and are not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to the applicable law or regulation.

This website should not be regarded as an invitation or inducement to engage in investment activity, as defined by the Financial Services and Markets Act 2000 (the “Act”) in the United Kingdom or in any other jurisdiction.

Important Information: Legal and regulatory Disclaimers

Any material and or information contained in this website are for information purposes only.
Your attention is drawn to the fact that specific services, financial instruments and or designated investments may either not be suitable for you, not available to you in the jurisdiction in which you are located, or may only be available through an entity that is authorised and licensed by the relevant regulatory authority to either provide or offer such services, financial instruments or designated investments in such a jurisdiction. Accordingly, certain protections accorded to you in the jurisdiction that you are located may not be applicable to the services, financial instruments or designated investments either provided or offered to you. The investments and products described in the following can only be marketed in certain jurisdictions. It is your responsibility to be aware of the applicable laws and regulations of your country of residence.

Warning: Seek Professional Advice

Please note that the investment products and investment services referred to in this website may not be suitable or appropriate for all investors. The information does not constitute advice, or a personal recommendation and you should therefore seek the advice of your own independent authorised financial adviser or intermediary as to the suitability and or appropriateness of any investment and or financial instrument mentioned in this website before reaching any investment decision on the basis of any material or information contained on this website. Accessing this website does not constitute an agreement whereby FAL is required to treat you as a client.

Warning: Investment Risk

You should be aware that there are significant risks associated with any investment strategy, financial instrument and or designated investment outlined in this website. Such strategies are intended solely for those investors that are eligible to be categorised as a Professional Client and that can accept the underlying risks associated with such investments. Investment in any strategy, financial instrument and or designated product contained herein, some of which may be unregulated collective investment schemes, are intended for a specific qualifying category of investor who have the financial understanding and experience to accept and deal with the risks associated with such an investment.

Warning: Past Performance

You are reminded that past performance should not be seen as an indication or a guarantee to future performance, and no representation or warranty, express or implied, is made regarding future performance. Investment in any financial instrument and/or designated investment involves risks, which may include potentially the loss of your original capital. The value of investments and the income from them may go down as well as up and are not guaranteed. You may not get back the amount you invested.

The price and the value of investments and income derived from them can fall as well as rise. Stock markets are volatile and subject to fluctuations. All derivative instruments and alternative investments are highly volatile and certain investments may be illiquid, over-the-counter and/or in non-publicly quoted securities or instruments or in financially distressed companies or instruments.

Restrictions: on offer, solicitation and distribution

This website is not directed at, or intended for distribution to or use by, any person or entity that is a citizen or resident of or located in any jurisdiction where such distribution, publication, availability or use would be contrary to the applicable law or regulation or which would subject FAL to any registration or licensing requirement within such jurisdiction.

None of the information contained on this site constitutes an offer to buy or sell or a solicitation by or on behalf of FAL to buy or sell any security, product, service or investment.

The information on this website is subject to copyright with all rights reserved. It must not be reproduced, copied or redistributed in whole or in part. The information on this website is published in good faith but no representation or warranty, express or implied, is made by FAL or by any person as to its accuracy or completeness and it should not be relied on as such. FAL shall have no liability, save for any liability that it may have under the UK Financial Services and Markets Act 2000 (as amended from time to time), for any loss or damage arising out of the use of or reliance on the information provided including, without limitation, any loss of profit or any other damage, direct or consequential. No information on this website constitutes investment, tax, legal or any other advice. You may leave the FAL website when you access certain links. In so doing, you may be proceeding to the site of organisations that are not regulated under the UK Financial Services and Markets Act 2000. FAL has not examined any of these websites and does not assume any responsibility for the contents of such websites nor the services, products or items offered through such websites. FAL shall have no liability for any viruses, data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to, any direct, indirect or consequential damage, arising out of the use of the services provided herein.

Foresight Advisors Limited (FAL), incorporated as a Private Limited Company in England and Wales (Companies House number: 13806331), is authorised and regulated (FRN: 975877) by the Financial Conduct Authority (FCA) in the United Kingdom to provide investment intermediation. FAL’s registered office is Salisbury House, London Wall, London, EC2M 5PS, and its place of business is 10 Woodlands Ride, Ascot, SL5 9HN, UK. FAL is registered with the Information Commissioner’s Office under number ZB304671.

FAL is committed to the security, confidentiality, and protection of personal data. This policy sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us. By visiting our website, you accept and consent to the practices described in this policy.

This policy was last updated on 10th October 2023 and may be amended from time to time.

DATA PROTECTION REGULATION

FAL operates under the Data Protection Act 2018 (DPA) and the European General Data Protection Regulation (GDPR).

This policy explains how we process your information and rights under the DPA and GDPR.

The DPA and GDPR apply to the ‘personal data’ we process, and the data protection principles set out our primary responsibilities.

We must ensure that data will be:

• Processed lawfully, fairly and in a transparent manner.
  Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
• Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
  Accurate and, where necessary, kept up to date.
• Kept for no longer than is necessary for the purposes for which the personal data is processed.
• Processed in a manner that ensures appropriate security of the personal data.

PERSONAL DATA

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

If you are a customer, we collect information to assist in providing services to you. This information may include:

• Your full name, including title, maiden name, marital status, date of birth and gender.
• Contact details such as residential address, email, and telephone numbers.
• Financial information, including your bank accounts and details of investments held with us and elsewhere. We may also record details of financial transactions placed across your accounts, whether held with us or elsewhere.
• Identifiers such as your national insurance number or equivalent in overseas jurisdictions, tax reference, driving licence number, passport number, internet protocol address and our internal identifiers.
• Data used to access our client portal, such as username, password, online preferences, and usage information.
• Information required to conduct ‘know your client’ checks, such as details relating to your passport or other photographic identification, your credit history, current and previous addresses, and source of funds.
• Other information provided during your dealings with us.
• If you are a business associate, we collect information to monitor services we have contracted for or assess available services. This information may include:
• Your full name, including your title.
  Your occupation and job title.
• Contact details for you at your place of business, such as address, email, and telephone number.
  Other information provided during your dealings with us.

Please note we do not request any special categories of personal data. Under the DPA 2018, special category data is more sensitive and needs more protection. Categories include race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; sexual orientation.

When requested, you are not required to provide personal information; however, in doing so, we may not be able to proceed with a business relationship.

DATA CONTROLLER

A controller determines the purposes and means of processing personal data. For this policy, FAL is a data controller regarding any personal information we hold about you.

DATA PROCESSOR

Concerning personal data, a data processor means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

HOW WE OBTAIN YOUR PERSONAL DATA

We collect personal data through services that we provide and receive. Typically, it comes from the following sources:

• Contractual agreements or other material provided during our relationship.
• Correspondence received from you such as email, telephone conversations, letters, face-to-face discussions, text messages, contact through our website and other forms of communication. We may keep a record of all correspondence received. We are required to record telephone and electronic communications that contain order execution instructions.

We may use third-party firms for credit reference and money laundering checks depending on our business relationship.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We collect and use information to provide services to you or to receive services from you in accordance with contractual obligations. We only use your information for our legitimate interests or, in certain circumstances, for those of a third party.

Our legitimate interests are:

• To administer and operate customer account(s) and to provide investment management services.
  To provide information relevant to the services we provide.
• To facilitate our business operations and ensure compliance with any legal and regulatory requirements we are subject to.

DISCLOSURE OF YOUR INFORMATION

We may share your personal information with third-party associates who provide us with professional, legal, accounting, or other services. This may include providing personal data to third parties to comply with anti-money laundering regulations. Such processing may involve automated decision-making to confirm your identity.

All third parties are required to maintain the confidentiality of your personal data and treat it according to the law. Third parties are not permitted to use your data for any purpose other than that covered by their contractual arrangements with us.

We may disclose your personal information as required by, or to comply with, legal, regulatory, or statutory requirements or at the request of supervisory or governmental bodies.

Your personal data is not shared with any other organisations for marketing purposes and will not be used by us for marketing purposes unless you have provided explicit consent.

YOUR RIGHTS

Under the GDPR, you have the following rights in respect of the personal data we process:

• The right to be informed about how we use personal data.
• The right of access to the personal data we hold.
• The right to rectification where the data we hold is inaccurate or incomplete.
• The right to the erasure of personal data in certain circumstances.
• The right to restrict the processing of your personal data.
• The right to data portability, which, subject to several qualifying conditions, allows individuals to obtain and reuse their personal data for their own purposes across different services.
• The right to object to using your information, including the right to restrict marketing.
• The right to request that your personal information is transferred to a commonly used machine-readable format and provided to you or a third party.
• The right to object to using your information, including the right to restrict marketing.
• Rights concerning automated decision-making and profiling.
• The right to withdraw consent previously provided to us to handle your information.

For more information about the GDPR and your rights under the Data Protection law, please contact us using the contact details at the bottom of this policy.

If you are dissatisfied with how we have handled your information, you have a right to complain to the Information Commissioner’s Office – www.ico.org.uk / Tel: 0303 123 1113.

RETENTION OF YOUR DATA

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

After terminating contracts, we may retain data for six years to comply with legal and regulatory requirements. After the expiration of six years, your personal data will be deleted.

If required by statutory, regulatory, or governmental bodies, we may retain your personal data for over six years.

THIRD-PARTY WEBSITES

Our website may include links to others, but we are not responsible for the accuracy or completeness of information supplied by third-party sites. We suggest you read the individual privacy policies for any websites visited.

COOKIES

Cookies are information that a website transfers to your computer’s hard disk for record-keeping purposes. Cookies can make the internet more useful by storing information about your preferences on a particular site, such as your personal preference pages.

Cookies are industry standard, and most websites use them to provide useful features for their customers.

Cookies in and of themselves do not personally identify users, although they do identify a user’s computer.

Browsers recognise when a cookie is offered and permit you to refuse or accept it. We cannot see your IP address when you access our website; however, it may be used by Google Analytics to track user behaviour.

TRANSFERS ABROAD

The data we collect from you may be transferred to and stored at a destination outside the European Economic Area (‘EEA’). It may also be processed by staff operating outside the EEA who work for us or one of our third-party business associates. By submitting your personal data, you agree to this transfer, storing or processing. We will take all reasonable steps necessary to ensure that your data is treated securely and in accordance with this privacy policy.

CONTACT US

If you have any questions or wish to exercise any of the rights detailed above, please email compliance@foresightal.com or write to: Chief Compliance Officer, Foresight Advisors Limited, 10 Woodlands Ride, Ascot, SL5 9HN, UK.

Disclosure to Complainants

How to complain, and how Foresight Advisors Limited (FAL) will respond. 

Foresight Advisors Limited (FAL), incorporated as a Private Limited Company in England and Wales (Companies House number: 13806331), is authorised and regulated (FRN: 975877) by the Financial Conduct Authority (FCA) in the United Kingdom to provide investment intermediation. FAL’s registered office is Salisbury House, London Wall, London, EC2M 5PS, and its place of business is 10 Woodlands Ride, Ascot, SL5 9HN, UK. FAL is registered with the Information Commissioner’s Office under number ZB304671.

FAL is required to have in place effective and transparent procedures for the reasonable and prompt handling of complaints in relation to this service.

This section sets out the complaints handling procedures that FAL will follow in the event that you make a complaint.

Does this policy apply to you?

FAL’s services are available to consumers and individuals, businesses, and organisations that may not be consumers. FAL must therefore establish whether you are an ‘eligible complainant’ or not.

The definition of a consumer for regulatory purposes refers to any natural person acting outside of his trade, business or profession.

It is important to note that FAL will treat all complainants equally. However, only eligible complainants will be able to refer complaints to the Financial Ombudsman Service (FOS) if they are not satisfied with how FAL handled your complaint.

How can you make a complaint?

You can make a complaint by any reasonable means – for example, by letter, email, telephone or in person. It is free of charge to complain.

To make a complaint, please contact:

Title:  Chief Compliance Officer
Address:  Woodlands House, 10 Woodlands Ride, Ascot, SL5 9HN, UNITED KINGDOM
Email Address:  compliance@foresightal.com
Phone Number:  +447885728163

What will happen once we have received your complaint?

Your complaint will be reviewed by the Chief Compliance Officer of FAL, as soon as possible. In the event that (s)he is involved in the subject matter of the complaint, your complaint will be referred to another member of FAL’s senior management team.

FAL will promptly acknowledge your complaint in writing or by email. In this acknowledgement, FAL will provide the name and title of the person handling your complaint. FAL will give this individual the authority necessary to investigate and settle the complaint. FAL will also include a copy of this policy at this time.

Investigating and resolving your complaint

FAL will investigate your complaint competently, diligently and impartially to decide whether the complaint should be upheld and whether any remedial action and/or redress may be appropriate. FAL will set out our conclusions in a final response to you.

If FAL decides that redress is appropriate, FAL will aim to provide you with fair compensation for any acts or omissions for which FAL is responsible. If you accept our offer, FAL will promptly provide the compensation to you.

Our timetable for responding to you

Once FAL has acknowledged your complaint, FAL will keep you informed of our progress. If FAL can quickly resolve your complaint, FAL will send you a Summary Resolution Communication, which will:

1. Acknowledge your complaint and confirm that FAL now consider it to be resolved;
2. Explain that you may still be able to refer your complaint to the FOS if you subsequently disagree with our decision, and the timescales you have for doing this; and
3. Provide information about how to contact the FOS.

If FAL is not able to resolve your complaint quickly, FAL will, within eight weeks of receiving your complaint, send you either a final response or a written response that explains why FAL is not able to make a final response to you and when FAL expect to provide one.

Our response will also inform you that if you remain dissatisfied, you may refer the complaint to the FOS; and enclose a copy of or an electronic link to, the FOS standard explanatory leaflet.

Financial Ombudsman Service

If you are an eligible complainant, you can refer a complaint to the FOS if you are not satisfied with the outcome of your complaint. Your rights are set out in the FOS’s leaflet “Your Complaint and the Ombudsman”, which FAL will provide to you as part of the Complaints process. Please remember that if you wish to refer a complaint to the FOS, you must do so within six months of the date of our final response.

Closing complaints

FAL will regard your complaint as closed in the following circumstances:

1. once FAL have sent you a final response;
2. where you have told the firm in writing that you accept an earlier response that FAL have sent to you; or
3. if you refer your complaint to the FOS, when the FOS informs the firm that the complaint has been closed.

Questions

If you have any questions about our complaints process, please contact FAL’s Chief Compliance Officer via any of the contact methods listed above.

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