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Business Practices & Code of Ethics


The Company will comply with all regulations of the Financial Conduct Authority (FCA) and do so in an open manner. We will also comply with the spirit of the regulators. This applies to all relevant regulators not just the FCA.

As the Company is a small enterprise it will outsource some regulatory work to a professional compliance firm.  


Company & Client Data & Information

We recognise that the data we hold could be of use to criminals and do our upmost to protect the information. Access to information is protected by strong passwords and a two-step verification process.


Business Continuity

We recognise that as the company has only one chartered financial planner. In view of this we have an arrangement with another firm of chartered financial planners (Cestrian Financial Planning Services Ltd – FCA Reference No. 115045). To act as a locum.


Skills & Knowledge

All staff will be required to improve their technical knowledge relevant to the business we undertake.



At our first meeting or at the first opportunity clients will be given our combined client agreement / key facts about our services and costs.


Financial Crime

All staff and advisors are made aware of the possibility of financial crime. In particular no instructions to change a bank account are taken or made without the account first being verified.


Conflicts of interest

All staff and advisors are trained to recognise conflicts of interest or the potential for such. Where identified the conflict of interest will be disclosed to the other party where applicable.



We treat complaints very seriously.  A complaints procedure is in place and all staff are required to make themselves familiar with this along with the FCA rules definition of a complaint. In the event that a client should wish to make a compliant, we explain clearly in our combined client agreement / key facts document how they can register a complaint.


If we are unable to resolve a complaint, you may wish to contact the Financial Ombudsman Service:


The Financial Ombudsman Service (FOS) is an agency for arbitrating on unresolved complaints between regulated firms and their clients.

Full details of the FOS can be found on its website at



Treating Customers Fairly

Treating customers fairly is a key part of our corporate culture. Our marketed and sold products have been designed to meet the needs of identified consumer groups and are targeted accordingly. We provide clear appropriate information before, during and after a point of sale.

We provide suitable advice which takes into account a customer’s circumstances and do not face unreasonable post-sale barriers.




We maintain the following compliance related registers;

  • New Business, pension transfers, high risk business, execution only, NTU & cancelled policies, replacement policies (i.e. clients advised to cancel, surrender, make paid-up)

  • Complaints

Key Performance Indicators

We create Key Performance Indicators (KPIs) annually

These take into account;

  • Persistency

  • NTU / Cancellation Rates

  • Business & Provider Spread

  • High Risk Business

  • Complaints and Breaches

  • On-going service provision

  • File check assessments

Code of Ethics

Graham Carter & Co is committed to providing the highest standards of professionalism and service for all of our customers.  We have adopted the Chartered Insurance Institutes (CII) Code of Ethics in full, which means the Company and all its staff must adhere to the following;


  1. Comply with this Code and all relevant laws and regulations.

  2. Act with the highest ethical standards and integrity.

  3. Act in the best interests of each client

  4. Provide a high standard of service.

  5. Treat people fairly regardless of; age; disability; gender reassignment; pregnancy and maternity; marriage and civil partnership; race; religion and belief; sex and sexual orientation.



Comply with the Code and all relevant laws and regulation


  • dealing with the CII in an open, clear and co-operative manner

  • dealing with regulators in an open, clear and co-operative manner

  • ensuring regulators and the CII are treated courteously and not in a vexatious or frivolous manner and that all queries are dealt with promptly

  • meeting our Continuing Professional Development (CPD) requirements

  • working not only within the law but also within the spirit of the law

  • if within our control, making sure our organisation is suitably regulated and has effective compliance arrangements

  • ensuring, where required, we are individually authorised or regulated; and

  • report any breaches of the Code to the CII



Act with the highest ethical standards and integrity

This includes, but is not limited to:


  • being honest and trustworthy

  • being reliable, dependable and respectful

  • not taking unfair advantage of a client, a colleague or a third party

  • not bringing the financial services industry or the CII into disrepute whether through our actions in work or outside work

  • not offering or accepting gifts, hospitality or services which could or might appear to, imply an improper obligation

  • promoting professional standards within the industry

  • encouraging our organisation to produce and ethical code

  • making sure our CII membership or chartered status is described correctly

  • informing the CII of any change in our work circumstances which affect our membership or chartered status

  • operating both professionally and in a financially responsible manner including avoiding personal insolvency


Act in the best interests of each client


  • encouraging our organisation to put fair treatment of clients at the centre of our corporate culture

  • basing our decisions on a clear understanding of client needs, priorities, concerns and circumstances

  • giving our client all the information, of which we are aware, which is needed for our client to make an informed decision provided that information is not confidential to another client

  • making sure the promises we make to our clients about a product’s performance and the after sale service are true

  • respecting confidential information of clients, former clients and potential clients

  • ensure we do not use information from work improperly and/or to our personal or business advantage

  • turning down work where a conflict of interest exists between ourselves and our employer and the client and

  • refusing to act where a conflict of interest exists, save where acting in these circumstances is expressly permitted by a regulator


Provide a high standard of service


  • communicating with each client in a way that is accurate and straightforward and expressed in a way that the individual client can understand

  • being transparent about fees and other costs

  • making sure reasonable steps are taken to ensure all advice is accurate and suitable for the individual client

  • obtaining and providing clear information before, during and after the point of sale

  • ensuring adequate and correct records are kept

  • acting with skill, care and diligence

  • acting only within our ability and authorisation and seeking help where necessary

  • ensuring our knowledge and expertise is kept up-to-date and relevant to our work

  • ensuing those who work for the Company have appropriate training and supervision and contribute to their learning and development; and

  • if it is within our control, make sure our firm has a clear written complaints procedure which is followed


Treat people fairly regardless of age, disability, gender reassignment, pregnancy and maternity; marriage and civil partnership; race; religion and belief; sex; and sexual orientation.  This includes but is not limited to:


  • treating each person as an individual

  • challenging and reporting unlawful or otherwise unfair discriminatory behaviour and practice

  • always action openly and fairly and treating employers, employees, colleagues, clients, potential clients and suppliers with equal respect and opportunity

  • making reasonable adjustments to assist people with disabilities or particular needs you may deal with at work

  • encourage our organisation to produce and promote an equality and diversity policy setting out how our business plans to promote equality, diversity and inclusion, prevent discrimination and deal with any instances of discrimination which might happen; and

  • if it is within our control, make sure processes and procedures do not discriminate


We take our commitments to being an ethical practice extremely seriously. If a client ever feels that we have failed to live up to the standards set in the code of ethics, we encourage them to contact us to resolve any issues they may have.

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