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threesixty

Brewin Dolphin

Assessment Report

December 2015

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Brewin Dolphin

All reasonable precautions have been taken to ensure that the information contained is correct.

threesixty services LLP does not accept any responsibility for errors, inaccuracies, omissions or

inconsistencies. This information should not be considered as an endorsement as to individual

suitability of the firm for any individual retail or professional client. This information should not be

relied upon by third parties.

The information in this document is only for the use of FCA authorised individuals and should not

be distributed in whole or in part to any retail clients.

Background to the firm & contact details

Firm name Brewin Dolphin is an independent company, listed on the London Stock

Exchange. It has offices throughout the UK and the Channel Islands.

Details on the specific office locations can be found at the following link:

https://www.brewin.co.uk/about-us

Turnover The full financial results can be found on the Brewin Dolphin website:

www.brewinmedia.co.uk/investor-relations.aspx

Established since The Company was founded in 1762 and has been offering outsourced

discretionary services to financial advisers for over 25 years.

Funds under

management

Brewin Dolphin had £33.2bn of funds under management, as at 31st

December 2015

Contact details Robin Beer

Group Head of Intermediaries & Institutional

Tel: 0115 852 5580

Email: Robin.Beer@brewin.co.uk

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The firm’s investment philosophy

Brewin Dolphin provides an investment process which offers consistency and flexibility to suit

different market conditions. Brewin Dolphin use this framework to create portfolios which satisfy

the individual financial requirements of each client.

Brewin Dolphin’s investment philosophy is to pursue active investment in real assets with a bias

towards growth markets, sectors and companies. They are active fund managers, believing that

markets are semi efficient and that the influence of human emotion upon markets leads to

investment opportunities.

They primarily look for three desirable attributes that identify investments which will potentially

make money for clients:

Attractive valuations relative to prospects

Positive news flow

Price momentum

Key Characteristics:

The Financial Adviser remains the central focus of the client relationship and retains control

Brewin Dolphin enable financial advisers to act in an 'agent' capacity for their clients, whereby the

Adviser firm is the legal client, not the underlying client. This provides Advisers with the security that

they retain full control of the entire client relationship while outsourcing the DFM workload, and

also clearly defines the suitability responsibilities of each party.

Extensive network of offices for easier access

Brewin Dolphin’s national business development team and their extensive network of offices mean

they can service advisers and their clients face-to-face across the UK.

Independently owned: for more choice and fewer constraints

Brewin Dolphin has no ties to any financial institutions; they are independently owned and focus

only on their core business. They have no in-house funds, and they are free to search across the

market to find suitable investments for each client.

Transparent charging: so clients know what they pay

Brewin Dolphin operate a simple and transparent ‘fee only’ charging structure for clients of advisers,

with no transactional commissions.

Easily accessible, providing wide industry choice

Brewin Dolphin are on panels with a large number of SIPP and offshore bond providers.

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Discretionary services offered:

1. Model portfolios: Yes – five risk rated portfolios available within their Managed Portfolio

Service (MPS).

2. Bespoke portfolios: Yes.

3. Brewin Dolphin’s Managed Portfolio Service (MPS) is currently available via the following

third party platforms – Aegon, Ascentric, AXA Elevate, Aviva, Fusion, James Hay, Novia,

Nucleus, Standard Life and Zurich.

4. Brewin Dolphin’s propositions are available across a large number of product providers and

tax wrappers.

Description of the types of model and bespoke portfolios offered by

the firm

Brewin Dolphin has two core services for financial advisers, with each having its own distinct

characteristics:

Discretionary Management – a service suited to clients who require bespoke investment

management of their investments, with direct access to a dedicated investment manager

and broad range of investment vehicles

Managed Portfolio Service – which provides discretionary fund management to clients via a

range of 5 risk rated model portfolios.

These services are designed to allow Advisers to effectively outsource the day-to-day management

of their clients’ portfolios, freeing up time to focus on developing client relationships and growing

their business. Both services draw on the considerable resources and expertise of Brewin Dolphin’s

award-winning research team and adopt a disciplined approach to portfolio management.

Does the firm utilise Non Mainstream Pooled Investments (NMPIs)

Brewin Dolphin does not invest in Non Mainstream Pooled Investments (NPMIs) for clients of

Financial Advisers.

Does the firm manage any investment vehicle? e.g. an authorised/unauthorised Unit Trust, an Open Ended Investment Company (OEIC)

etc., which could be included in a client’s discretionary portfolio?

Brewin Dolphin do not operate any ‘in-house’ funds and are free to search across the market to find

suitable investments for each client.

Funds under management

As at 31st December 2015, Brewin Dolphin managed £33.2bn worth of funds for clients, of which

around 15% have been introduced by Financial Advisers.

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Charges

1. The firm charges the following for establishing / managing a model portfolio:

1.1. Establishment fee

Brewin Dolphin do not charge an establishment fee.

1.2. Annual management fees are a percentage of the amount invested

The management charge for the Managed Portfolio Service is 0.3% per annum.

This fee is subject to applicable taxes in line with UK legislation, such as VAT.

1.3. Platform charges

The Managed Portfolio Service is available through a variety of third party platforms, with

whom an Adviser firm would contract directly and negotiate the platform charge for their

clients.

1.4. Custodian charges

Brewin Dolphin do not levy any custodian charges.

1.5. Exit / transfer fees

Brewin Dolphin do not levy any exit/transfer fees.

1.6. Additional costs / charges if applicable

The Managed Portfolio Service (MPS) portfolios are constructed using collective

investments, therefore an Adviser should consider the underlying charges of these

investments when assessing the overall cost of the service for a client.

2. The firm charges the following for establishing / managing a bespoke portfolio:

2.1. Establishment fee

Brewin Dolphin do not charge an establishment fee.

2.2. Annual management fees are a percentage of the amount invested

Brewin Dolphin operate a transparent fee structure for clients of Financial Advisers, which is

inclusive of dealing costs, custody charges (see below), income payments and reporting

facilities. The structure also incorporates tiered fee rates, enabling clients who have in

excess of £1million invested to benefit from a reduced charging scale.

The management fee for a discretionary portfolio under £1 million in value is 1%* per

annum, subject to a minimum charge of £1,000*. However, Brewin Dolphin also offer

preferential terms to clients of Adviser firms who have introduced more than £10m in total

funds under management. The discretionary management fee for clients of these

‘partnership’ firms is 0.8%* per annum under £1 million in value, subject to a minimum

charge of £1,000*.

*UK VAT is applied on fees and charges in line with applicable legislation

2.3. Platform charges

Brewin Dolphin do not levy any platform charges.

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2.4. Custodian charges

Brewin Dolphin do not levy any separate custodian charges. However, in situations,

particularly with overseas investments, where additional non-standard charges may be

incurred in relation to a particular investment requested by the client, these may be passed

on to the client.

2.5. Exit / transfer fees

In the situation where a client requests an in-specie transfer out of the Brewin Dolphin

nominee system, a charge of £15* per line of UK stock would be levied or £25* per line for

an overseas stock.

*UK VAT is applied on fees and charges in line with applicable legislation

2.6. Additional costs / charges if applicable

Where collective investments are used in the construction of a portfolio, an Adviser should

consider the underlying charges of these investments when assessing the overall cost of the

service for a client.

Miscellaneous Charges

Not applicable

Adviser charging

The discretionary service provided by the firm facilitates adviser charging.

To authorise the payment of adviser charging The Brewin Dolphin Adviser Charging agreement

needs to be completed.

For any SIPP accounts, the SIPP Provider must also have a formal agreement in place with Brewin

Dolphin authorising them to facilitate Adviser Charging.

Please note that Brewin Dolphin are unable to facilitate Adviser Charging from within an Offshore

Bond.

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Investment instruments used

1. Retail investment products (RIPs):

a. A life policy: Yes

b. A unit: Yes

c. A stakeholder pension scheme (including a group stakeholder pension scheme) : No

d. A personal pension scheme (including a group personal pension scheme) : Yes

e. An interest in an investment trust savings scheme: No

f. A security in an investment trust: Yes

g. Any other designated investment which offers exposure to underlying financial

assets, in a packaged form which modifies that exposure when compared with a

direct holding in the financial asset: Yes

h. A structured capital-at-risk product: Yes

2. Direct Equities: Yes

3. Exchange Traded Products (ETPs): Yes

4. Unregulated Collective Investment schemes (UCIS)/Non Mainstream Pooled Investments

(NMPI): No

5. Gilts: Yes

6. Corporate Bonds: Yes

7. Venture Capital Trusts (VCTs): No

8. Enterprise Investment Schemes (EIS): No

Relationship with the client

Brewin Dolphin enable Financial Advisers to act in an 'Agent' capacity for their clients, whereby the

Adviser firm is their legal client and not the underlying client. This provides Advisers with the

security that they retain full control of the entire client relationship whilst outsourcing the DFM

workload and also clearly defines the suitability responsibilities of each party.

The referring/introducing financial adviser acts as agent for the client. As such the

referring/introducing financial adviser is responsible for know your client, the client’s attitude to

risk/capacity for loss/investment objectives etc. and the suitability of the discretionary management

service provided by Brewin Dolphin.

Minimum Investment:

Model portfolios = £2,000 (with the exception of £10,000 if held via AXA Elevate)

Bespoke portfolios = £150,000

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Benchmarks:

1. Brewin Dolphin has a process to determine what is an appropriate “bench mark” for its

model portfolio/s.

These are clearly shown and measured on the monthly factsheets produced as part of the

Managed Portfolio Service. The portfolios have also been formally risk mapped to

Distribution Technology and Finametrica.

2. Brewin Dolphin has a process to determine what is an appropriate “bench mark” for its

bespoke portfolio/s.

Each risk category is aligned to a specific default benchmark. However, it is possible for a

bespoke benchmark to be used, where required.

Platforms/custodians currently available:

The firm currently uses the following platforms/custodians:

Platform/Custodian Model Portfolios Bespoke Portfolios

Aegon Y N

Ascentric Y N

Aviva Y N

AXA Elevate Y N

Fusion Y N

James Hay Y N

Novia Y N

Nucleus Y N

Standard Life Y N

Zurich Y N

Brewin Dolphin is prepared to consider using other platforms/custodians chosen by the

referring/introducing financial adviser.

Brewin Dolphin’s bespoke/tailored proposition can be accessed through a wide range of tax

wrappers, including the following:

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Platform/Custodian Product

AEGON SIPP & Offshore Bond

AJ Bell SIPP

SIPPCentre SIPP

AXA Wealth SIPP

Legal & General SIPP & Offshore Bond

Suffolk Life SIPP

Prudential SIPP & Offshore Bond

Clerical Medical SIPP & Offshore Bond

Curtis Banks SIPP

IPS SIPP

James Hay SIPP

Scottish Life SIPP

Scottish Widows SIPP

Standard Life SIPP & Offshore Bond

LV SIPP

Zurich SIPP & Offshore Bond

Royal Skandia Offshore Bond

Lombard Offshore Bond

Royal London Offshore Bond

Canada Life Offshore Bond

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Investment Managers & Advisers

Brewin Dolphin employ approximately 1,700 staff, including over 400 fully qualified Investment

Managers, a dedicated award winning Research department and a National Business Development

team, who provide specialist support to Financial Advisers across the UK.

Personal Recommendations:

Brewin Dolphin do not make personal recommendations when engaging with a Financial Adviser

firm on an ‘Agent’ basis; they purely undertake the role of a Discretionary Investment Manager.

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Scope of threesixty’s services LLP work:

The aim of the work undertaken by threesixty services LLP (threesixty), was to assess, at a high level,

the adequacy of the controls and procedures the firm has established to mitigate the regulatory and

business risks arising from the provision of its discretionary management service to intermediaries.

Areas covered Scope of work

Client and

referring/introducing

intermediary

communications and

financial promotions.

1. There are two ways in which intermediaries can engage Brewin

Dolphin Ltd (Brewin Dolphin) as a discretionary fund manager to

their clients. The intermediary is able to either become an

introducer to Brewin Dolphin, or the intermediary can operate as an

agent of the client. In relation to the respective regulatory

responsibilities of Brewin Dolphin and the intermediary;

a. In cases in which clients are introduced Brewin Dolphin will

be responsible for the suitability of the service, know your

client information, risk profile assessment, setting the

investment objectives and suitability of investments.

b. In cases in which the intermediary is the agent of its client

then Brewin Dolphin is only responsible for the suitability of

specific investments, and all other financial planning is the

responsibility of the intermediary

2. Intermediaries may only operate as agents once they have been

assessed for due diligence, and have agreed to follow Brewin

Dolphin’s processes in regard to the services offered to their clients.

3. Ongoing due diligence is undertaken on an annual basis on the

intermediary to ensure that the agreement is up to date, and that

the intermediary still holds the relevant FCA permissions.

4. Although in cases in which the intermediary operates as an agent

the relationship between Brewing Dolphin is with the agent, the

agreement between the parties includes Brewin Dolphin issuing a

Retail Client Terms and Conditions to the client of the intermediary.

5. A Terms of Business is signed between Brewin Dolphin and the

intermediary for both the Discretionary Management Service and

Managed Portfolio service which sets out the responsibilities of both

parties.

6. For the Discretionary Management Service an account opening form

is signed by both the intermediary and client.

7. An adviser charging form is required to be completed and signed by

both the intermediary, and client, as part of the account opening

pack.

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8. Brewin Dolphin have produced brochures explaining the different

services available for intermediaries and their clients, which can be

accessed on the firm’s website.

From a review of the agreements issued to the intermediary, and the

associated literature, it would appear that the respective roles of both

parties has been clearly set out.

In respect of the production of financial promotions Brewin Dolphin has

procedures in place to;

Approve all forms of communications/financial promotions; and

Ensure that they are fair, clear and not misleading.

1. There is an automated process in place for the approval and logging

of all financial promotions which is controlled by the compliance

team.

2. As part of the process, any individual within the company can submit

a promotion via Sharepoint, the firm’s extranet, for approval by a

Regional Marketing Manager.

3. A risk rating of High, Medium or Low determines how the promotion

is approved, and whether there needs to be a further check

undertaken by the compliance department.

4. The compliance department approve all promotions which are

classified as High Risk, and will check all promotions to ensure they

have been correctly risk rated by the Regional Marketing Manager.

5. A full audit history is maintained with all promotions logged on a

register, which can identify any trends that can be reported to the

Brewin Dolphin Board on a monthly basis.

Threesixty were not provided with an example of the financial

promotions register, however, we were supplied with a copy of the

internal procedures, and guidance on production and approval of

promotions. From a review of this and a discussion with a member of the

compliance team, there appears to be a clear process in place for

approving and recording all types of financial promotions.

Recruitment The recruitment procedures were discussed with Brewin Dolphin’s Head

of Resourcing and an overview was provided as to how staff are vetted

and recruited. This includes;

1. The recruitment of all staff must be authorised by senior

management which is in turn controlled by the London HR

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Department. Threesixty were supplied with a copy of the

Recruitment Authorisation form to review.

2. Brewin Dolphin use a range of employment agencies in the

recruitment process depending on the role of the job being filled.

3. The experience of the candidate is analysed as part of the screening

process, and case studies and technical tests set as part of verifying

the candidates past experience.

4. Brewin Dolphin utilise the services of an external company who

undertake the screening process which is then checked by the HR

department.

5. Verification checks are undertaken which includes an identity check,

Directorship check at Companies House, credit and DBS checks.

Reference requests cover the last 10 years of employment.

6. All Investment Managers must, as a minimum, be Level 7 qualified

and hold a Statement of Professional Standing (SPS) with the

Chartered Institute of Securities and Investments (CISI).

7. All recruits have a 3-6 month probationary period depending on the

role and this may be extended if required.

8. Threesixty were informed that Brewin Dolphin were in the process

of implementing a new HR software system which will improve

record keeping, and assessment of training of staff.

9. Brewing Dolphin’s remuneration policy is that staff are paid a total

remuneration package which is set in January each year. The

Company operates a discretionary profit share scheme. Up to 10%

of any profit share/bonus awarded to members of staff may be

forfeited if specific TCF requirements are not achieved each year. In

addition, with certain key individuals a proportion of bonuses must

be paid by way of deferred shares in the company and held for a

minimum of three years.

In view of the confidentiality of employment records the threesixty’s

review did not involve an assessment of specific recruitment files.

However, based on the discussions and review of the associated

procedures, there appears to be a clear process in place.

Training and

competence (T&C)

Brewin Dolphin has in place a specific Investment Management T&C

scheme. The processes include:

1. A formal induction process for all newly appointed Investment

Managers (IM’s) which takes place over the course of two days.

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2. For trainee IMs, a four year programme includes attaining the

appropriate qualifications before being registered as an approved

person with the FCA. There is then a minimum of 12 months

increased supervision for each trainee IM which includes monthly

meetings with their line manager.

3. For Experienced IMs, they are subject to increased supervision for a

minimum of three months and all initial cases are reviewed by their

line manager.

4. As part of the IM’s competency assessments, the firm has used

professional actors to undertake role plays focusing on different

aspects of the sales process.

5. Once assessed as competent to perform the role, all IMs have an

interim competency based review every six months, and a formal

development annual review to determine any required training

needs.

6. Assessments of competency and ongoing supervision are the

responsibility of the line managers who are assisted in the process

by Competence and Development Partners who help facilitate

training and development generally.

7. All IMs must be members of the Chartered Institute of Securities and

Investments (CISI) and must hold a Statement of Professional

Standing (SPS) from the CISI.

8. The CISI’s online professional refresher modules are utilised as part

of the ongoing training of IM’s and all IM’s complete their CPD via

CISI which is reviewed on an ongoing basis.

9. A Management Information dashboard is utilised to link any issues

from the review of the MI at IM level which will then form part of

the IM’s development plan.

10. As noted above Brewin Dolphin are implementing a new HR

software system which will enhance the recording and monitoring of

training and development issues.

Based on the review of the T&C procedures and discussions with a

representative of the firm’s Learning, Development and & Competency

team, there appears to be a suitable framework for the induction and

ongoing monitoring and supervision of the firm’s Investment Managers.

Discretionary

management

procedures

1. Brewin Dolphin has procedures to control and monitor the

discretionary management services, it provides to

referring/introducing intermediaries.

2. The review undertaken included the following areas;

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2.1. The firm’s Discretionary Management Procedures

2.2. The firm’s investment philosophy/process

2.3. The workings of the investment committee

2.4. How investment decisions are made and implemented

3. To operate the discretionary management services, provided to

referring/introducing intermediaries Brewin Dolphin has;

3.1. A Group Asset Allocation Committee (AAC) with Terms of

Reference in place headed by the Head of Research. This

committee meets on a monthly basis, and looks at

macroeconomic trends and determines weightings in

investments in terms of assets and regions.

3.2. A meeting can be convened at any time by the chairman, or 3

members of the committee if required.

3.3. The AAC reports to the Internal Governance Committee.

3.4. A briefing note is distributed to the attendees after the AAC

meeting and then minutes are distributed to the members of

the Internal Governance Committee and Risk Management

Committee. Whilst threesixty were not provided with copies of

minutes we were given access to examples of the summary

provided to IMs after the meetings.

3.5. Following on from the asset allocation meeting the firm’s equity

strategists have a sector strategy meeting.

3.6. Each week there is also a detailed stock selection meeting.

3.7. Where fund changes are recommended or considered, these

are discussed at a weekly meeting of the fund analysts.

3.8. IMs are updated on recommendations for buy lists by a daily

conference call including all offices, and minutes of the call are

then emailed to all offices. Recommendations are also posted

on the interactive research portal along with supporting

documentary evidence.

3.9. Brewin Dolphin have implemented a Risk Monitoring System

(BITA) which is used to monitor the construction and ongoing

rebalancing of portfolios to ensure they are compliant with the

mandate, and the defined investment policies of the firm.

4. Brewin Dolphin issues the required periodic valuations on a 6

monthly basis or more frequently if required by clients. These can

be accessed via an online client portal system.

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5. Based upon threesixty’s review of the firm’s procedures, workings of

the committees and the controls it has established the firm appears

to;

5.1. Have procedures and controls in place;

5.2. Documents the decisions of the committees;

Outsourcing It was confirmed during the scope of the assessment that Brewin

Dolphin do not outsource any critical functions as defined by the FCA as

part of the services offered to intermediaries. Therefore this part of the

assessment was not reviewed by threesixty.

Financial crime, anti

money laundering,

data security, fraud

and the Bribery Act

1. In adopting a risk based approach to dealing with financial crime the

Board of Brewin Dolphin have produced an Anti-Money laundering

statement.

2. Anti-Money laundering procedures are in place and are reviewed on

an annual basis, or where legislative or regulatory changes occur.

Threesixty were given access to procedure documents.

3. Brewin Dolphin undertake an electronic check of a client’s identity,

wherever possible, which includes a PEP and sanctions screening for

each client.

4. Where business is introduced via an intermediary as agent, Brewin

Dolphin rely on the intermediary to have verified the client’s identity

and will not accept third party verification certificates. Periodic

checks are undertaken on the information and identity supplied by

the intermediary to Brewin Dolphin.

5. Training on Financial Crime procedures forms part of the induction

process for all new staff, and is undertaken on annual basis in the

form of Computer Based Training (CBT) and an associated test and

internal checks undertaken to ensure all regions, branches and

individuals have undertaken the test by a set date.

6. A bi-annual money laundering report is produced and presented to

the Brewin Dolphin Board by the MLRO. Due to the confidential

nature of the report, this was not provided for review.

7. Written procedures are in place for the recording of any gifts and

hospitality received by Brewin Dolphin employees with gifts over a

certain value requiring pre-approval.

8. The firm has in place an Anti- Bribery & Corruption Policy and the

policy is reviewed annually. There are two levels of training that are

undertaken every year for all staff –Generic and Focused. The

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focused training is provided to staff where they are more likely to be

exposed to bribery risks.

9. A review of the firm’s Data Security arrangements and procedures is

undertaken on an annual basis and threesixty were provided with

the latest version to review and as part of this;

9.1. Monitoring of the policy is carried out by the ICT Security and

Information Officer, who reports to the Head of Risk and

Regulation.

9.2. Mandatory eLearning modules are made available to all staff

to carry out on an annual basis.

9.3. A Data Security Response team is in place whose main duties

are to ensure that corporate, client and personal data is safe

and secure.

Complaints Brewin Dolphin has in place comprehensive internal and external written

complaints procedures with separate procedures for persons who are

responsible for handling the complaints. The processes include the

following aspects.

1. Complaints are handled by the Head of Client Services who deals

with the complaints independently, and has the autonomy to look at

the root cause of the complaint and outcome free of any internal

conflict.

2. An internal complaints form must be completed for each complaint

received and this is then sent to the Regulation & Risk team record

the complaint.

3. The complaint is logged onto a database and an internal report can

be created which acts as the firms register which assists with looking

at the root analysis overview.

4. Each complaint is subject to a four eyes check in terms of the overall

overview and outcome. A further check of cases are then

undertaken via an internal audit.

5. Weekly updates and progress reports are made on all complaints

and a report made to senior management.

6. An internal spreadsheet is maintained for all branches with a risk

rating applied to each branch in terms of the date of the last

training, and whether there are any specific training needs required.

As a minimum, all branches receive internal training at least every

three years.

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7. There is a Regulatory Guidance log which looks at information and

reports produced by FOS as an example, and also how the firm has

dealt with complaints in the past.

8. As part of the Terms of Business provided to intermediaries, details

on the complaints procedure are provided that intermediaries

should follow, and the rights afforded to them under FOS where

they are acting as an agent for their client.

It is the firm’s policy not to disclose to third parties the number of

complaints that have been received, and due to the confidential nature

of the information threesixty were not given access to specific files on

complaints.

Business continuity/

disaster recovery

1. Brewin Dolphin has a Business Continuity & Crisis Management Plan

in place for each office.

2. The Plans are reviewed on an ongoing basis with a version control in

place outlining the dates and changes that have taken place.

3. All offices have plan owners who are responsible for invoking and

testing the plan.

4. The Head of Business Continuity visits each office on at least an

annual basis to ensure the plan has been tested, and to provide any

additional guidance and feedback.

5. The frequency of tests conducted by each office is dependent on the

assessment of risk and impact of any potential failure of an office on

the overall business. Offices are categorised as A – High Impact e.g.

London , Edinburgh and Newcastle at which tests would be held

quarterly, and other offices which are categorised as B (six monthly

reviews ) and C (annual reviews).

6. The plans include provision for staff to either work remotely or

transfer to nearby offices in the event of a crisis event at their

respective office.

7. A test report is produced which outlines the nature of the test along

with any lessons learnt and actions/recommendations.

Systems and controls 1. Brewin Dolphin has implemented a framework of committees

ultimately reporting to its holding board to ensure the monitoring of

business and communication of issues throughout the organisation.

This framework includes for example an Executive Committee and a

series of sub-committees such as, Audit Committee, Remuneration

Committee, Nomination Committee, Risk Committee and a Risk

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Management Committee. The reporting lines of the committees and

sub-committees are defined.

2. Brewin Dolphin have adopted the concept of three lines of defence

in relation to regulation and risk. The first line being line

management. The second line being the internal regulation and

compliance teams. The third line of defence being the internal and

external audit functions, and Group Holdings Board including non-

executive directors who aim to provide the independent challenge

to the first and second line policies and procedures.

3. There is an MI Dashboard in place which is reviewed by region,

branch and then drilled down at an individual level. The Head of

each branch provides comments on the MI that has been reviewed

which is in turn reviewed and challenged where appropriate by the

Regional Director.

4. Each department within Brewin Dolphin produces a report to the

Board on a monthly basis, which highlights any gaps and appropriate

MI for the Board to consider and review. Due to the confidential

nature of the reports, these were not provided for review.

5. A Risk & Control Assessment (RACA) is in place which reviews the

risks to the business and a net risk assessment is then undertaken

for each risk. This provides a net impact risk score and the likelihood

of this actually materialising.

6. The firm has in place a TCF policy which sets out the firm’s approach

to ensuring the delivery of fair outcomes for its clients.

7. The Board sets the firm’s TCF requirements at the start of each year.

8. There is a Conflicts of Interest Policy and a Conflicts of Interest

Register in place to log any identified conflicts. Due to the

confidential nature of the content of the register, this was not

provided for review.

9. There is an order execution policy in place which is regularly

reviewed and updated as appropriate.

10. A Professional Indemnity Insurance policy with £100m limit of

indemnity is in place which covers Brewin Dolphin as part of a Group

policy.

threesixty has only reviewed those documents made available on our audit. We have not

investigated their efficacy and practical use. All reasonable precautions have been taken to ensure

that the information contained is correct, threesixty services LLP does not accept any responsibility

for errors, inaccuracies, omissions or any inconsistencies. This information should not be relied upon

by third parties, and should not be considered as an endorsement as to individual suitability of the

firm for a financial advisers’ clients.

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Third Party References/Testimonials:

The following references/testimonials have been made about the firm:

“It is an outstanding achievement for any firm to win three categories of the Citywire Investment

Performance awards. Our independent awards recognise firms that are producing great risk-

adjusted performance on behalf of their clients, on a consistent basis.” Citywire

“Although normally associated with segregated portfolio management, Brewin Dolphin has created

a Managed Fund Service, which benefits from its substantial, centralised research effort to meet the

needs of both large and small clients across the country. The outstanding risk adjusted performance

of each MFS strategy has resulted in Brewin Dolphin being judged the winner of the Cautious and

Balanced performance category and the Overall Award for Best Large Firm.” Asset Risk Consultants

(ARC)

threesixty has not verified these references/testimonials.

Useful Links

www.brewin.co.uk/financial-advisers