an introduction for clients overseas · gavin clark dippfs, certs cii (mp & er) uk registered...

An introduction for clients overseas

THE MARK JENNINGS PARTNERSHIP (MJP) LLP

2AN INTRODUCTION FOR CLIENTS OVERSEAS


Who we are

MARK JENNINGS CeMAP, AIFP, DipPFS UK Registered and Regulated Financial Adviser Principal Partner of The Mark Jennings Partnership (MJP) LLP Senior Partner Practice of St. James’s Place Wealth Management

GAVIN CLARK DipPFS, Certs CII (MP & ER) UK Registered and Regulated Financial Adviser Wealth Management Consultant

ANDREW LEWIN BSc (Hons), DipPFS, Cert CII (MP) UK Registered and Regulated Financial Adviser Wealth Management Consultant

DANIELLA BLACKMAN Assistant to the Principal Partner

POPPY SCHEMBRI Practice Administrator

LAUREN SIMPSON Practice Administrator

LISA WESTON Principal Administrator

MEGAN WILLIAMS Junior Secretary

We specialise in providing financial advice to Diplomats/Crown Servants posted both in the UK and overseas (FCO, DFID, SIS, IS, UKBA, DWP, MOD, Police) UK Military personnel, United Nations, European Commission and NATO Personnel.

We currently visit UK Embassies/High Commissions/Consulate Generals in the following countries/cities as well as being open to new posts (please note FCO travel advice is followed for every country);

USA New York, Washington, Boston and San Francisco.

SOUTH AMERICA Peru, Chile, Guatemala, Mexico and Argentina.

CARIBBEAN Jamaica and Barbados.

WESTERN EUROPE France, Italy, Greece, Belgium, Switzerland, Spain, Portugal, Hungary, Romania and Estonia.

EASTERN EUROPE Serbia, Kosovo, Ukraine, Georgia, Albania, Turkey (Istanbul & Ankara) and Tajikistan.

RUSSIA Moscow and St. Petersburg.

MIDDLE EAST Dubai, Jordan, Saudi Arabia, Abu Dhabi, Kuwait, Syria, Lebanon, Israel, Iraq, Iran,Oman and Yemen.

ASIA Singapore, Thailand, Malaysia, Taiwan, Korea (North and South), Indonesia, Hong Kong, China (Beijing and Shanghai), Japan (Tokyo), Pakistan (Islamabad only), Afghanistan, Sri Lanka, India (Mumbai, Chennai and New Delhi) and Bangladesh.

Worldwide financial service



AFRICA Egypt, The Gambia, Ghana, Nigeria (Abuja & Lagos), Zimbabwe, Zambia, Kenya, Tanzania, Tunisia, Ethiopia, Uganda, Sudan, Algiers, Sierra Leone, Mozambique, South Africa (Pretoria, Johannesburg and Cape Town).

AUSTRALASIA Australia (Canberra, Melbourne, Sydney and Cairns), New Zealand (Auckland and Wellington) and Pacific Islands.

We also advise UK based clients, be they non civil servants or returning civil servants.

Worldwide financial service

We are committed to providing the best advice for your financial planning for as long as you need it; wherever you need it.


We specialise in delivering financial planning services to our clients and help to develop a written Financial Action Plan (FAP) in consultation with our clients and then conducting reviews at regular intervals; providing a written report after each meeting (RAP).

Our advice is not free. Details of the charges we make for our advice and how it is paid for are set out in the ‘Key facts about our costs and services’ document you receive. The cost for our advice is paid for and afacilitated out of the overall charges levied on your investment. The advice charges will also be discussed with you and the specific amount charged will be provided on your personalised illustration.

We charge a retainer fee for our services; currently set at £897.00 per annum inc VAT at 20% (last reviewed 1st November 2012) for overseas based clients; reducing to £597.00 per annum inc VAT at 20% on your return to the UK.

We generally aim to see clients at least once a year at post; this of course is reliant on clients’ availability in your region.We offer a one off first meeting without charge or obligation (the cancellation fee is not applicable is this case). We also offer Skype and phone conferences as required.

The following services are included in your annual retainer fee and are separate to those offered as a representative of St. James’s Place. These services are not covered by the St. James’s Place Guarantee.

• Tax returns in retainer fee year • Tax investigation work for tax return submitted by the US • UK taxation including residence and

non-residence issues, rental income, operating under The Non Resident Land Lord Scheme

• Calculating rental income accounts • Vehicle financing solutions • Onshore and offshore banking • UK credit requirements • Creation of your Financial Action Plan (FAP) • Updating of your Reviewed Action Plan (RAP) annually

Services and fees



The following services are provided at additional cost to your retainer fee.

Tax returns outside your retainer year: £150.00 per tax year required, plus VAT

Tax investigation work instigated by HMRC: £105.00 per hour, plus VAT

Executorship charges: £3,000.00 one off, plus VAT

Credit checks: £25.00 per check, per agency, plus VAT

Principal Partner: £160 per hour, plus VAT

Wealth Management Consultants: £100 per hour, plus VAT

Para Planners: £80.00 per hour, plus VAT

Back office: £50.00 per hour, plus VAT

Cancellation Fee

We reserve the right to charge a cancellation fee if a meeting that has been booked and confirmed in writing/email is cancelled by the client(s) within five days of the scheduled meeting. The cancellation fee will be equal to the cost incurred by us when booking and pre-paying for flights, trains, ferries, hotels, pre-paid taxis and pre-paid drivers so as to allow us to attend the meeting venue. The cancellation fee will be capped to a maximum of 60% of the applicable retainer fee, being due in the client’s retainer year.

The cancellation fee is not applicable to all those clients whose meetings have been booked in England and Wales. Nor is it payable due to operational reasons or a medical emergency if the client’s meeting is cancelled at short notice.

Services and fees



As a Senior Partner Practice of St. James’s Place Wealth Management, we are able to offer specialist guidance and advice on all aspects of the following;

Please refer to the Services & Costs Disclosure Document for full details of the charges for our services.

Your home may be repossessed if you do not keep up repayments on your mortgage.

* Buy to let mortgages and trusts are not regulated by the Financial Conduct Authority.

• Residential mortgage and remortgage solutions

• Commercial lending/remortgaging

• Buy to let mortgage*/remortgaging

• Savings & investment planning – both onshore & offshore solutions

• Retirement planning

• UK trust* advice

• Inheritance Tax mitigation and estate planning solutions

• Retirement planning and solutions

• UK protection planning solutions

• OLAB (Overseas Life Assurance Business) compliant protection planning solutions

• General insurance requirements

• Regular updating of the financial arrangements listed above

Our specialist advice

St. James’s Place Wealth Management offers a wide range of high quality wealth management services to businesses and individuals. With £47.6 billion funds under management, St. James’s Place is well established as one of the UK’s leading wealth management organisations.



There is no notice period required by either party to cancel the annual appointment of the The Mark Jennings Partnership (MJP) LLP.

A request to cancel the services offered by us must be received in writing from each client. Likewise we will issue a letter of cancellation to a client(s) if we believe that there is no further benefit to the client in retaining us.

Your “retainer year” starts at the point of payment of the appropriate annual retainer fee.

Payment is by cheque or bank transfer only as we do not accept cash payment, credit or debit cards.

Your next payment falls due on the anniversary period; this being the 1st of the month in which your initial meeting took place with us. Receipt of the retainer fee by annual Standing Order automatically renews the service for 12 months.

In the event of a cancellation notice being received or served the client is responsible for cancelling the standing order.

No refund is payable if a cancellation notice is received after 6 months of your retainer year renewal. Any due refund is made at the beginning of the following month of payment.

In the event that we serve a cancellation notice a refund will be at our discretion.

Terms and conditions



Terms and conditions

In the event of a complaint in relation to the services offered by us as an Appointed Representative of St. James’s Place Wealth Management plc, please contact us...

...in writing to;

Client LiaisonSt. James’s Place, St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire GL7 1FP

Email: [email protected] Telephone: 01285 640302

If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.

In the event of a complaint in relation to the services offered by us, which are separate to those offered as a Representative of St. James’s Place (as detailed on page 3 and 5), in the first instance you should notify the Principal Administrator in writing (by email, fax or post) at any of the following addresses:

Miss Lisa WestonThe Mark Jennings Partnership (MJP) LLP, Windmill Cottage, Forge LaneLeeds, Kent ME171RT

E-mail: [email protected]: 01622 861663Telephone: 01622 861604



As a result of UK legislation covering a range of professional services providers, financial adviser firms are bound by stringent Anti-Money Laundering Regulations. These regulations require us to undertake enhanced due diligence into the identity of our clients and we must hold evidence to support this.

The traditional view of the relationship between adviser and their clients has been that the adviser has a duty of confidentiality in relation to his client’s affairs and may not disclose information about his client to any third party save very limited circumstances.

We regret that we are unable to receive or make payments of sums in cash. Monies received in a transaction must be in the form of a personal cheque or cheques issued on the bank of the named client. We are not able to accept monies tendered to us by a third party on behalf of the named client.

We hope that these restrictions will not cause our clients any inconvenience but we are sure you will appreciate the reasons for them, which we feel are in the best interests of both our clients and our firm.

Our firm’s retainer with you is entered into on the basis that you consent to and join in with any disclosure we may need to make to the statutory authorities and by signing your Fee Charging Agreement (FCA) you also accept our terms of business. Such consent is effective from that time.

Prevention of money laundering



The Data Protection Act regulates how we use your personal information and protects you from misuse of your personal details. The act is administered and enforced by the Information Commissioner - an independent authority who is appointed by the Queen and reports directly to parliament.

The details of the Data Protection Act are quite complex, but at the heart of it are eight common sense rules known as the Data Protection Principles.

These require personal information to be:

Data Protection Act 1998

• fairly and lawfully processed; • processed for limited purposes; • adequate, relevant and not excessive; • accurate; • not kept longer than necessary;

• processed in accordance with your rights;

• kept secure; • not transferred abroad without

adequate protection.



The Act provides stronger protection for sensitive information about your ethnic origins, political opinions, religious beliefs, trade union membership, health, sexual life and any criminal history.

The Act, with some exceptions, gives you the right to find out what information is held about you by us. This is known as the ‘right of subject access’. On written request, you are entitled to be supplied with a copy of all the information we hold about you.

We charge a fee for providing the information, up to a maximum of £10 in most instances. Details of the Information Commissioners Office are;

Information Commissioner’s OfficeWycliffe House, Wafer Lane, Cheshire, SK9 5AF

Tel: 01625 545745 (General Enquiries)01625 545740 (Notification Helpline)Fax: 01625 545510Web: www.ico.gov.uk

Statement for The Mark Jennings Partnership (MJP) LLP

1. Scope

This statement sets out the principles that we will follow to meet its obligations under the Data Protection Act 1998.

It applies to:

• all clients, employees, temporary staff, and work placements;

• third parties acting in partnership with, or on behalf of us and when handling “The Mark Jennings Partnership (MJP) LLP owned” data.

We have to take account of data protection, covering both their roles as Financial Advisors and employer.

To provide efficient and effective services, we need to gather and process information about its staff, clients and third party organisations. This personal information will be collected in line with the Data Protection Act 1998 and related legislation.

Our duty to ensure that personal information is handled properly and in accordance with the law, whether the information is held in electronic format or as part of a manual record. This covers all the processes relating to the collection of personal information, including:

• the obtaining of personal data;

• the storage and security of personal data;

• the management, arrangement and accuracy of personal data;

• the archiving/disposal of personal data.

We are also responsible for ensuring that staff and clients have, on written request, appropriate access to personal information about them.





2. General principles

When handling personal information we acknowledge the rights of the individuals concerned, and will ensure that these rights are fully respected as defined by the Data Protection Act 1998.

We will apply the following principles of “good information handling” throughout our business areas by:

• specifying the purposes for which personal data is used at the point we collect it and restricting the use of the data to those purposes;

• ensuring that personal data is seen only by staff who need it to do their jobs and that appropriate security measures are in place to protect against damage, loss or abuse;

• collecting and processing personal data on a “need to know” basis, ensuring that it is fit for the purpose and is not excessive;

• ensuring that adequate steps are taken to keep the data accurate and up to date;

• having appropriate departmental deletion/archiving policies and ensuring information is kept or disposed of in line with these policies;

• having procedures to ensure that any sharing of personal data with relevant third parties is lawful and that suitable safeguards exist at all times;

• only processing personal information without the subject’s knowledge if this is necessary for purposes such as prevention of crime, complying with money laundering legislation or instructed to do so by a Government agency or department;

• normally providing to a person, on receiving a written request, any personal information held on him or her by The Mark Jennings Partnership (MJP) LLP;

• ensuring there are proper procedures for dealing with any complaints.



3. Data subject access requests

Under the Data Protection Act 1998 the data subject (the person about whom information is requested) has the right to know what personal information is held on our files about them, and we must respond within 40 calendar days. Staff will take all reasonable steps to help clients or individual staff members to exercise this right.

The Data Protection Act 1998 repeals the Access to Personal Files Act 1987 and most of the Access to Health Records Act 1990. It has created a single regime of access to records, and applies to both manual and computerised information. Our Data Security Officer will be notified of all requests when they are received and completed. If a “blanket request” for data is made, the Data Security Officer will coordinate the response. A central log of subject access requests will be maintained and evaluated regularly.

Requests for access to personal data from data subjects will be handled courteously, promptly and appropriately, ensuring that the data subject or their authorised third party has a legitimate right of access under the Act, that their request is validated, and that the information we provide is clear and unambiguous.

In the following circumstances we will refuse a request for information:

• The person or organisation that provided the information has exercised their right not to allow the data subject to have access to the information, e.g. medical reports.

• It would be unlawful for the data subject to see the information, e.g. legal proceedings or interference with a criminal investigation.

• We believe that showing the information may cause serious harm to the data subject or others.

• The information would identify someone who has not given us consent to release it.




4. Confidentiality of personal information

All activities that relate to personal data, including processing and storing, will have appropriate safeguards and controls to ensure that information is processed in a confidential manner and in compliance with the Act. Our Conditions of Employment require all staff to respect the confidentiality of personal information revealed to them in their work.

5. Security of personal information

Staff have a duty to ensure that personal information, whether held on computer, in case files or in any other manual record, is stored securely. The System Owner is responsible for the security of personal information held on computer systems. Service Managers are responsible for the security of files and other information held by their teams. Any breach of security must be reported to line management as soon as possible.

6. Accuracy of personal information

Adequate steps should be taken to confirm that personal data is current and relevant by:

• the data owner and team manager making regular reviews of the information to ensure it is kept up to date;

• routinely sharing data with data subjects to check its accuracy;

• ensuring that primary-source data is updated when the data subject informs the Council of any changes;

• carrying out regular audits to identify high-risk areas;

• implementing cross-checks to reduce the risk of errors.




7. Deletions and archiving

There is a clear distinction between deleting data and archiving. Data protection rules demand that data is not kept for longer than necessary and this implies deletion, i.e. the destruction of the data. Archiving does not destroy data, it simply removes it from a ‘live’ system to an alternative ‘storage area’ (either electronic, e.g. a CD, oractual, e.g. a basement room). The sole purpose of archiving is to improve the efficiency of a system. It does not itself satisfy data protection rules about keeping data.

The Data Protection Act 1998 says that personal data must not be kept for longer than is necessary for its purpose (The FCA and HMRC require us to keep records for a rolling 6 years). This principle requires us to introduce procedures covering the review of information held on files, especially if it holds sensitive personal information as part of the record and there are questions of confidentiality.

However, as a general principle, personal information should not be held for longer than six years after the client’s last contact with us. This period reflects the time within which, under the Limitation Act 1980, someone could take a civil action to court.




The Mark Jennings Partnership (MJP) LLPWindmill Cottage Forge Lane Leeds Kent ME17 1RT United Kingdom

Telephone: +44 (0) 1622 861604 Fax: +44 (0) 1622 861663 Email: [email protected]

The Partner Practice represents only St. James’s Place Wealth Management plc (which is authorised and regulatedby the Financial Conduct Authority) for the purpose of advising solely on the Group’s wealth management products and services,

more details of which are set out on the Group’s website www.sjp.co.uk/products. The ‘St. James’s Place Partnership’ and the title‘Partner Practice’ are marketing terms used to describe St. James’s Place representatives.

an introduction for clients overseas · gavin clark dippfs, certs cii (mp & er) uk registered...

Documents