Evelyn Partners as a Distributor

We have been working over the past 3 months to develop a new Fair Value Framework, which is embedded in our updated Product Governance Framework. This work has resulted in the following key areas of activity:

• We have been updating our governance in relation to Fair Value and Products and Services, including increasing the role of the Product Services Oversight Committee (PSOC) and recruiting an individual responsible for overseeing the governance process for each product and service.

• Developing a Fair Value Framework that defines how Evelyn Partners assesses fair value for its own services, taking into account comparable competitor pricing, comparable pricing within our own Group, service and value add, and cost to serve amongst other things.

• Developing a Product Governance Framework which requires each product and service we provide to clients to be assessed against all Consumer Duty requirements and is built upon PROD requirements, with additional detail being included for Consumer Duty purposes. The Product Governance Framework requires a detailed assessment of the product or service against various metrics including: the intended target market; the intended distribution strategy; understanding where foreseeable harm could occur and how that is prevented; understanding how the product or service adequately deals with any potential client vulnerabilities, amongst other things. We have determined that in assessing products we distribute on behalf of manufacturers outside of our Group, we will rely on the manufacturer's assessment that the product represents Fair Value and we will rely on the manufacturers assessment of the target market and other aspects of the product. We therefore require you as a manufacturer, to provide us with adequate information to be able to make that informed assessment.

• Products we maintain on our panel will be scrutinised in more detail than products which form part of our investable universe.

• Where we have a distribution agreement with you, we are reviewing that agreement to determine whether the MI requirements in that document are sufficient or whether additional contractual requirements may be necessary. In advance of that assessment, we welcome information you can share with us, by the end of April 2023, as required pursuant to the Consumer Duty.

• Where we identify actual or potential harm resulting from a product we distribute on your behalf, or where we receive a complaint from a client in relation to a product or service we distribute on your behalf, we will provide you with details of this in a timely manner.

• We have been producing a new Information Summary for all manufacturers whose products and services we distribute, designed to support our manufacturers in understanding how we assess the target market the product or service is designed for, how we envisage sharing information if there are indicators of concern or complaints from consumers in relation to the product or service, and how we deal with suitability requirements and vulnerability. The Information Summary will be available to you via this portal as soon as possible and certainly before the deadline of 31st July 2023.

This page was last updated on 12/04/2023.