Policies & Third Party Notices

List of Rowan Dartington policies

Order Execution Policy (formerly Best Execution Policy)
Management of conflicts of interest
Complaints policy
Client money notice
Shareholder Engagement Disclosure Statement
Investment Firm Prudential Regime Public Disclosures
Candidate privacy policy
Central securities depositories regulation (CSDR) article 38(5) and article 38(6) participant disclosure
Whistleblowing Policy
Third Party Notices

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:

Counterparty	UK Equities	International Equities	Exchange Traded products	Government and Corporate Bonds	Structured Finance Products
Peel Hunt Ltd	✓	✓	✓	✓
Stifel Nicolaus Bank	✓	✓	✓
Winterflood Secs Ltd	✓	✓	✓	✓
Singer CM	✓		✓	✓
Berensberg	✓
Marex	✓
Investec	✓		✓
Jefferies	✓		✓
Numis Deutsche	✓
Shore Capital	✓
Cavendish Securities	✓
Cannaccord Genuit	✓		✓	✓
Davy	✓	✓
JP Morgan	✓				✓
Panmure Liberum	✓	✓
beOptiver	✓		✓	✓
Jane Street	✓		✓	✓
FlowTrader			✓
Bridport				✓	✓
Guy Butler				✓	✓
NcL Capital Markets				✓
Barclays Investment Bank					✓
Credit Suisse					✓
Atlantic House					✓

Glossary

Term	Definition
Best Execution	The process of achieving the best price for a retail client for a transaction (whether buying or selling) of a particular type and size.
Bond	A type of debt security, usually a negotiable certificate, used as evidence of a loan to the issuer. The issuer promises to pay the holder its face value plus (usually) amounts of interest at future dates.
Collective investment scheme or collective investment (‘CIS’)	A fund where investors’ money is pooled together and managed with a shared investment aim.
Counterparty	This is the person or organisation who is the other party in a financial arrangement.
CREST	An electronic settlement system that allows for the exchange of securities and cash in real time. It's used to settle a variety of international securities, including those in the United Kingdom and Ireland.
Dark Pool	Private exchange for trading securities that is not accessible to the general public. Dark pools are used by institutional investors to make large trades without affecting the market or getting unfavourable prices.
Equity	Also known as an ordinary share. It gives the person who holds the share (the shareholder) the right to take advantage of the residual assets of a company and have voting rights. Shareholders will usually receive a dividend. The amount they receive will depend on the profitability of the company. It is another term for a stock or a share.
Exchange Traded Fund (ETF)	An investment fund that tracks an index (such as a stock or bond index), a commodity or a basket of assets. ETFs are traded on a stock exchange.
Execution Venue	The location where a financial transaction or trade takes place
Financial Conduct Authority (‘FCA’)	The FCA is a regulatory body which supervises financial services firms and is responsible for making rules and for enforcing and overseeing financial regulation. The FCA is responsible for regulating how business in retail and wholesale markets is carried out (commonly known as conduct of business). Its aim is to make sure that firms put the wellbeing of their customers at the heart of what they do. For example, they oversee consumer protection and will make sure that financial markets operate with honesty.
Gilt or gilt-edged security	The name for a bond (fixed-interest security) issued by the UK Government through the Debt Management Office. Originally, the certificates for these bonds were printed with gold (or gilt) edges. The sale of gilts helps the UK Government fund the difference between what it spends and what it receives in taxes, for example. There are two types of gilts – conventional and index-linked. Both types are quoted on the London Stock Exchange.
Government stock	A bond sold by the Government to pay for its budget deficit.
Illiquid stock	Investments that cannot be easily sold.
Markets in Financial Instruments Directive (‘MiFID’)	A directive (European law) that aims to integrate the European Union’s financial markets and to increase the amount of cross-border investment.
Limit Price (or limit order)	A pre-determined price at which we will execute your order to buy or sell a security, ensuring the trade is only executed at that price or a better one (cheaper for buying, higher for selling).
Multilateral trading facility (MTF)	A trading system operated by an investment firm or a market operator, which brings together multiple third-party buyers and sellers of financial instruments in accordance with that MTF’s rules, protocols or operating procedures.
Order Management System (OMS)	a digital way to manage the lifecycle of an order. It tracks all the information and processes, including order entry, fulfilment, and settlement of your order.
Organised Trading Facility (OTF)	a type of European multilateral trading venue where contracts for the exchange of non-equities such as bonds, structured finance products, emission allowances or derivatives are formed.
Retail Service provider (RSP)	A company that acts as an intermediary between retail investors and stock exchanges, executing trades on behalf of the investor. RSPs are also known as market makers and are typically investment banks or brokerage houses.
Systematic Internaliser	A systematic internaliser is an investment firm that deals on its own account by executing client orders outside a trading venue
Undertakings for collective investment in transferable securities (‘UCITS’)	A type of collective investment or fund that, once authorised in one member state, can be marketed freely across the European Union.

The Rowan Dartington order execution policy dated March 2025

2. MANAGEMENT OF CONFLICTS OF INTEREST

What are conflicts of interest?

A conflict occurs where:

our (or any subsidiary /representatives of Rowan Dartington) interests conflict with the duty owed to you; or
where our duties to another client conflicts with our duty to you

In accordance with the requirements of the FCA (our regulator) we aim to treat you fairly by implementing adequate systems and controls to identify, monitor and manage these risks or any potential risks.

As the fair treatment of our clients is paramount to the ethical standard of Rowan Dartington it is incumbent on our Board and staff to consider and escalate any matter that they consider may conflict with our policies. The Risk Committee will review any new conflicts that have been identified.

About us

Rowan Dartington provide wealth management services, including investment advice and management as well as dealing and custodian services. We are part of the St. James’s Place Wealth Management Group.

Purpose of this information

To explain to you what policies we have in place to manage conflicts and highlight what principle conflicts exist and what is in place to mitigate them. Should you wish to discuss anything further, please contact your Investment Manager.

FCA Requirements

FCA Principle 8 – ‘A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client’. The SYSC Rules also require us to have adequate systems and controls to manage risks. The new MiFID Rules require us to formally document this. It is not sufficient that we rely solely on disclosure of conflicts in customer agreements etc.

Conflicts Inventory

Principal Conflicts

Management Arrangements

Conflict Risk

What we do

Suitability
i.e. Staff recommend services or transactions which are not appropriate for the client

We have a robust training programme in place for our advice processes to ensure that our Investment Managers and Advisers provide appropriate advice. Our monitoring programme provides a control mechanism to ensure processes are being consistently deployed and advice is suitable.

There are internal policies in place to deal with scenario’s that may cause conflict in advice processes, such as;

Commissions receive from third parties;
Staff having power of authority over an account i.e. Trustee, Executor, Director or Power of Attorney;
Interest payments

All staff are expected to disclose outside business interested.

Dealing and Trading

i.e. our staff may delay investments

We have a best execution policy which Investment Managers and Financial Advisers are expected to adhere to ensure that we act in your best interest.

Rowan Dartington have a transactional monitoring programme to review trades which have been completed to ensure best execution principles have been achieved.

Aggregation of orders

i.e. one client may be treated more favourably than an other

To mitigate this we may combine one client’s orders with another clients order. The intention is to ensure fairness to all clients when placing particular trades, particularly for discretionary clients. This could result in a less favourable price or increased trading costs. When undertaking trades of this nature we will ensure our clients best interests are considered.

Placings and new issues

i.e. one client may be treated more favourably than an other

Where we agree to take part in a new issue or placing, we will do this in combination with other client orders. If the allocation is scaled back it will be applied pro rata across all participating clients.

Sometimes staff may take part in these trades also. Where they do and where the allocation is scaled back, we will scale back staff orders before applying any scaling to our clients.

Personal Account (staff) Dealing (PA)
i.e. Staff may deal on their own account ahead of clients and obtain better prices

All staff and connected parties are expected to comply with our Personal Account Dealing policy. This requires staff to obtain prior approval for trading.

The prior approval means that checks can be made to ensure that staff do not;

Trade ahead of clients
Trade ahead of any public announcements about the stock being traded

Staff remuneration
i.e. bonus and salary structures may entice staff to act inappropriately when managing client assets

We aim through our remuneration package to consider the long-term interests of our staff. These are designed to correlate with the interests and financial wellbeing of our clients, so to discourage inappropriate behaviour or excessive trading.

Therefore, activities are overseen and monitored.

Gifts and Hospitality (Inducements)
i.e. The integrity of either staff or suppliers is compromised by excessive inducements.

We have enforced internal policies, through training and monitoring, to ensure that gifts or hospitality received from or provided to clients, supplier, company and other are not excessive.

Staff are required to disclose where they receive or give gifts or hospitality when they are over a notional value. Where the triggers are met pre-approval will be required, via our Compliance and Risk Department, to accept or provide a benefit like this.

In all cases, there needs to be a business motive for the gift or hospitality which aim is to enhance the quality of service we provide to you.

We also maintain a register or gifts and hospitality received or provided which is overseen by the Compliance and Risk Department.

Research

i.e. our research team may be un-duly influenced to place stock or funds on to our core lists

Our research team are independent from other teams in the business. The remuneration package for these staff is designed not to influence their decision making process.

Any additions or deletions from the core list are discussed at either the Asset Allocation Committee or Investment Management Committee before the changes are made to the core list. This information will not be disclosed to staff ahead of formal announcement of the core stock list changes.

Disclosure

If we are unable to manage a conflict, or where we believe our measures and controls are not sufficient to protect your interest we will disclose the conflict to you. The aim of this is to allow you to make up your own mind as to whether to continue our business relationship with regard to the service or advice we provide you.

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, St. James’s Place House, 2610 The Quadrant, Aztec West, Bristol, BS32 4AQ

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.

If we are unable to resolve your complaint within 4 weeks of receipt we will send you a letter explaining why we need more time to complete our investigation and let you know when to expect our response.
If our investigation is going to take longer than 8 weeks, we will write to you again 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 compliant, you have additional rights to independent review or assistance. These additional rights are set out below:

Financial Ombudsmen 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 Ombudsmen 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

We will also issue you with a leaflet providing these details with our formal responses to your complaint.

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

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 April 2025

With effect from 1 April 2025, the rate of interest paid by Rowan Dartington on cash balances will reduce from 2.45% to 2.2% 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.

5. SHAREHOLDER ENGAGEMENT DISCLOSURE STATEMENT

Shareholder Engagement Statement Feb 24.pdf

6. Investment Firm Prudential Regime Public Disclosures

2023 RD IFPR Disclosure.pdf

7. CANDIDATE PRIVACY NOTICE

About Rowan Dartington

Rowan Dartington & Co Ltd (Company No. 2752304) has its registered office at St. James’s Place PLC Head Office: St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, United Kingdom.

Rowan Dartington is part of the St. James’s Place Wealth Management Group. Rowan Dartington is a member of the London Stock Exchange and is authorised and regulated by the Financial Conduct Authority (No. 155241).

Our processing of your personal information

Personal information means data which identifies you and relates to you as an individual. Rowan Dartington & Co. Limited will collect, use and store your personal information for a wide variety of reasons in connection with your development towards becoming an employee of Rowan Dartington & Co. Limited (collectively referred to as the ‘Purposes’ in this notice).

In accordance with its obligations Rowan Dartington & Co. Limited will ensure your personal information is:

Processed fairly and lawfully
Obtained and processed only for specified and lawful purposes
Adequate, relevant and not excessive
Accurate and kept up to date
Held securely and for no longer than is necessary
Not transferred to a country outside of the EEA unless there is an adequate level of protection in place or explicit consent is sought

We will review the nature of information being collected and held from time to time to ensure that these principles are being followed. Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also act as the data controller of their personal information and will be responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to the content of this notice.

What personal information do we collect?

We have set out below the main categories of personal information which we may process on a day to day basis in connection with the purposes:

Name, gender, home address and telephone number, date of birth and marital status
Business contact information (including email address and telephone number)
Identification information including passport, driving license, national identity card (for non-UK nationals), government issued ID verification and address verification documents such as council tax letters, bank statements and evidence of benefit entitlement
Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process
Employment information such as job title, employment history, professional qualifications and accreditations
Note of discussions between trainees and Rowan Dartington employees
Records of work absences, holidays/paid time off, entitlement and requests, salary history and expectations, performance appraisals, letters of appreciation and commendation, and disciplinary and grievance procedures (including monitoring compliance with and enforcing our policies)
Training and development records
Information relating to performance of tasks and activities to be achieved via the programme
Notes of discussions with Rowan Dartington employees
Payment information
Emergency contact information
Voicemails, emails, correspondence, documents and other work product and communications created, stored or transmitted our networks, applications, devices, computers or communications equipment
Date of termination, reason for termination
Fitness and propriety information necessary for regulatory approval
Personal information which you otherwise voluntarily provide, for example when using your Rowan Dartington email account

Personal information provided by you may be mandatorily required for us to administer our relationship and/or to comply with statutory requirements relating to immigration or taxation. Failure to provide mandatory personal information may affect our ability to accomplish the purposes stated in this Notice and potentially affect your training and development.

The list set out above is not exhaustive and there may be other personal information which Rowan Dartington collects, stores and uses in the context of the relationship. We will update this Notice from time to time to reflect any notable changes in the categories of personal information which we process.

Most of the personal information which we process will be collected from you directly. In limited circumstances your personal information may be provided by third parties, such as former employers, official bodies (such as regulators or criminal record bureaus) or medical professionals.

For the purposes of our background checking carried out as part of our selection process we will also gather data from publicly available sources as the electoral roll, court judgements, insolvency registers, internet search engines and social media sites and/or engage a third party to conduct electronic ID checks, sanctions and politically exposed person checks.

What do we use your personal information for?

Rowan Dartington uses your personal information for a variety of purposes in connection with your training and development as summarised above. Most of this processing takes place to enable Rowan Dartington to perform its obligations under your contract and/or to comply with its legal obligations and we have set out below the main purposes for which personal information is processed:

Processing your application to join Rowan Dartington
Processing your application for examination registration
Processing, recording and storing your academic achievements including notification of results
Administration of your contract with Rowan Dartington, including remuneration agreements
For giving references about you if requested to do so by any third party
To establish your training and development needs
For the setting up and arrangement of any pension, private healthcare or similar arrangements which may be arranged by Rowan Dartington on your behalf
For legal, regulatory and compliance purposes (which may lead to disclosure to regulatory bodies or HMRC)
To establish contact in the case of an emergency (e.g. next of kin)
For the contact of credit reference agencies in connection with your application and whilst any loans provided to you by Rowan Dartington remain outstanding
The day to day management of tasks and responsibilities
To manage performance, including the conduct of regular reviews
Obtaining Financial Conduct Authority approval where necessary
Corporate travel and other reimbursable expenses (if applicable)
Conflicts of interest reporting
To address disciplinary and grievance issues
To protect our confidential and proprietary information and intellectual property
To monitor the proper use of our IT systems
To prevent fraud against the company and its clients
For succession planning

In addition, Rowan Dartington will process your personal information in pursuit of its legitimate interests provided this does not unduly impact your privacy rights; in these cases, we have specified below the processing and the nature of the legitimate interest in question:

In connection with the prospective transfer or sale of a business or group company, we may share personal information as part of the due diligence process and/or to facilitate a smooth transfer. In these cases, the information we share will be anonymised wherever possible, and it will be a condition that the recipient holds the information securely, use it only for the prescribed purposes and deletes/returns the information if the transfer or sale does not go ahead.
In specific cases Rowan Dartington, as part of the St James’s Place Group of companies, will carry out psychometric or job-related evaluations in order to facilitate development discussions and/or to evaluate you for potential alternative roles. Additional information about how your personal information is processed in the context of these evaluations will be available at the time of completion of any such valuation.

The details set out above are not exhaustive and Rowan Dartington may undertake additional processing of personal information in connection with the relationship. Rowan Dartington will update this notice from time to time to reflect any notable changes in the purposes for which it processes your personal information.

When we will share your personal information?

Financial institutions and other payment providers
Benefits providers
Background vetting specialists
Occupational health providers and other medical professionals
HMRC and/or any other applicable government body
Accountants, lawyers and other professional advisors
The Financial Conduct Authority and/or the Prudential Regulation Authority and/or any other applicable regulatory body
St. James’s Place Group of Companies
Third party training providers

Wherever possible, personal information is shared under the terms of a written agreement between Rowan Dartington and the third party which includes appropriate security measures to protect the personal information in line with this notice and our obligations. The third parties are permitted to use the personal information only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission.

What special category information do we process?

Certain categories of data are considered ‘special categories of personal information’ and are subject to additional safeguards. Rowan Dartington limits the special categories of personal information which it processes as follows:

Health Information

Rowan Dartington will process information about your physical or mental health in compliance with its legal and contractual obligations, in particular (i) to administer company and/or state sick pay; (ii) to facilitate the provision of benefits, such as private medical insurance; (iii) to comply with obligations owed to disabled candidates; (iv) to comply with health and safety obligations; and (v) to maintain a sickness absence record.

Criminal Record checks

We will conduct a criminal record check, which is called a Disclosure and Barring Service (DBS) check.

We will always treat special category information as confidential and it will only be shared internally where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical and organisational security measures designed to secure your personal information against accidental loss and unauthorised access, use, alteration or disclosure.

Special category information will typically be retained during an individual’s relationship with Rowan Dartington & Co. Limited. Following the termination of an individual’s relationship with Rowan Dartington, we will typically retain health information for 12 months subject to any exceptional circumstances and/or to comply with particular laws or regulations.

How long do we keep personal information for?

Rowan Dartington’s policy is to retain personal information only for as long as needed to fulfil the purpose(s) for which it was collected, or otherwise as required under applicable laws and regulations.

Under some circumstances we may anonymise your personal information so that it can no longer be associated with you. We reserve the right to retain and use such anonymous data for any legitimate business purpose without further notice.

Is my data secure?

We take the security of your data very seriously and have systems, procedures and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed and is not accessed by anyone other than employees in the performance of their duties.

We also have procedures in place to deal with any known or suspected personal data breaches and will our regulator and/or you if we are legally required to do so.

Cookies

This Rowan Dartington website uses cookies (small text files that are stored on your computer or in your browser) to help us to monitor how visitors use our site and allow us to maintain the optimum experience for website users. The website does not store or capture personal information about you when you visit it, it merely records traffic information about all of our visitors collectively, for example the number of visits the website receives. In order to respect our visitors’ rights of privacy, this information is anonymous, and no individual visitor can be identified from it.

You can disable and delete cookies by changing the appropriate setting within your browser’s ‘Help’, ‘Tools’ or ‘Settings’ menu. Please note that by disabling cookies you may not benefit from some of the features of our site. You can find out more about deleting or controlling cookies by visiting aboutcookies.org.

Automated Profiling

Rowan Dartington & Co. Limited does not rely on automated profiling for recruitment decisions. If this changes, we will contact you and give you the opportunity to object.

Your rights

You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in ways set out in this notice. Please contact us at any time using the details below in the contact us section if you wish to exercise any of these rights.

We respect your rights and will always consider and assess them but please be aware that there may be some instances where we cannot comply with a request, for example when we have our own legal obligations, but we will write to you to let you know.

The right to access your personal information

You are entitled to a copy of the personal information we hold about you and certain details of how we use it.

We are happy to provide you with such details but in the interests of confidentiality, we follow strict disclosure procedures, which may mean that we will require proof of identity from your prior to disclosing such information.

We will usually provide your personal information to you in writing unless you request otherwise. Where your request has been made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible.

If you would like to request a copy of the information we hold, please do so in writing to:

Data Protection Specialist
Compliance & Risk
Rowan Dartington & Co. Limited
St. James’s Place House
2610 The Quadrant, Aztec West
Bristol
BS32 4AQ

The right to rectification

Please help us to keep your personal information accurate and up to date. If you believe there are any inaccuracies, discrepancies or gaps in the information we hold about you, please contact us and ask us to update or amend it.

The right to restriction of processing

In certain circumstances, you have the right to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to use your personal information.

The right to withdraw consent

Where we rely on your consent to process your personal information, you have the right to withdraw such consent to further use of your personal information.

The right to erasure

You are entitled to request your personal information to be deleted in circumstances such as where we no longer need your personal information for the purpose we originally collected it. When you exercise this right, we need to consider other factors such as our own regulatory obligation, to assess whether we can comply with your request.

The right to data portability

In certain circumstances, you can request that we transfer personal information that you have provided to us to a third party.

When you exercise this right, we need to consider other factors such as our own regulatory obligations, to assess whether we can comply with your request

If you fail to provide us with personal data

You are under no statutory or contractual obligation to provide data to Rowan Dartington & Co. Limited during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

If your application is successful, it will be a condition of any job offer that you provide evidence of your right to work in the UK and satisfactory references.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

The right to lodge a complaint with the Information Commissioner’s Office (ICO)

If you believe we have breached data protection laws when using your personal information, you have a right to complain to the ICO.

You can visit the ICO’s website at https://ico.org.uk/ for more information. Please note lodging a complaint will not affect any other legal rights or remedies that you have.

Contacting us

If you would like any further information about any of the matters in this notice or if you have any other questions about how we collect, store or use your personal information, you may contact our Data Protection Specialist at Rowan Dartington & Co. Limited, Compliance and Risk, St. James’s Place House, 2610 The Quadrant, Aztec West, Bristol, BS32 4AQL or compliance@rowan-dartington.co.uk

Updates to this notice

From time to time we may need to make changes to this notice, for example, as a result of changes to the law, technologies or other developments. We will provide you with the most up to date notice and you can check our website periodically to view it.

This notice was last updated on 9 July 2024.

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.

Costs Disclosure Document.pdf

Participant Disclosure Document.PDF

9. WHISTLEBLOWING POLICY

We believe that, as a company, we have a collective responsibility to ensure we comply with relevant rules and regulations and that the company's good reputation is not jeopardised by the actions of any individual within it. If you become aware of any wrongdoing connected to Rowan Dartington, we therefore encourage you to report it to us as soon as possible.

Anyone can “blow the whistle” if they suspect any wrongdoing regardless of their location, jurisdiction or the nature of their connection to Rowan Dartington. This therefore includes anyone external to the firm as well as those who are employees of or otherwise connected to the Group. Should you wish to make a whistleblowing report to Rowan Dartington, and you are happy to disclose your identity to the firm, you may make an initial report to Richard Westlake, via telephone 07971 477236, or email r.westlake@rowan-dartington.co.uk.

Should you wish to remain anonymous to Rowan Dartington, please make your report by following our Group Policy which you can find here.

We know that it can take courage to speak up and we’ll do whatever we can to support and protect you from retaliation for reporting your concerns to us in good faith. If someone from Rowan Dartington or the St. James’s Place Group tries to deter you from speaking up, that’s a disciplinary offence in itself and we will deal with it seriously.