1Issue 4 Autumn 2015

WMAJOURNALIssue 4 Autumn 2015

Defence against CybercrimeThe changing face of research25 facts celebrating 25 years of the WMAIndustry StatisticsThe importance of implementing a robust policy management programme

In this issue

2 WMA Journal@WMA_UK

08 The changing face of research: Quant is not enough

1225 years of the WMA:A look at 25 facts from the past 25 years and our anniversary drinks reception

14 Industry Statistics

04Foreword from the editor

16 The importance of implementing a robust policy management programme

06Liz Field, warns that employees and clients are the true priority for defence against cybercrime

Issue 4 Autumn 2015

3Issue 4 Autumn 2015

The Wealth Management Association (WMA) represents 183 firms. Of this number 107 are full members and 76

are associate members.

The 110 full members are wealth management and stockbroking firms that deal directly for individuals, trusts

and charities through a range of services spanning execution only, advisory and discretionary fund management.

WMA member firms look after

the wealth of over 4 million retail

investors.

The 76 associate member firms provide professional services to our full member firms.

Our member operate across more than 580 sites in the UK, Ireland, Channel Islands and Isle of Man, employing over 32 000 staff.

Member firms run 6 million client portfolios and carry out over 20 million trades a year.

At the end of 2014, the wealth management industry had £677 billion of assets under management, up 6% year on year, therefore outpacing the 4.2% market rise (as calculated by the FTSE WMA Balanced Index).

4 WMA Journal@WMA_UK

Join us at the WMA Summit and access cutting-edge industry opinion, debate key issues with leaders and network with senior representatives from the wealth management community

12 November 2015

Thank you to our sponsors

WMASUMMIT

2015

6 reasons to attend• Over 400 senior industry professions in attendance • Over 10 hours of networking opportunities• 6 hours of CPD• Hear the perspectives of over 30 leading

industry speakers• Diverse audience including delegates from

across the UK and beyond • A comprehensive programme tackling the

industry’s key issues

Cost:Members: £299 + VATNon-Members: £599 + VAT

To Book: Members: Book your place online or by emailing events@thewma.co.ukNon-Members: Book your place by emailing events@thewma.co.uk

Confirmed speakers includeSharon Bowles Non-Executive Director, LSE & Former MEP Stephen Ford Head of Investment Management, Brewin Dolphin John Griffith-Jones Chairman, Financial Conduct Authority Nick Hungerford Co-Founder & Chief Executive, Nutmeg Paul Killik Senior Partner, Killik & Co. Jon Moynihan Board Member, Business for Britain Michael Portillo British Journalist, Broadcaster & Former MP Tracey Reddings Managing Director, J.P. Morgan Private Bank Andrew Tarver Founder, BOLDROCKET

IT SOLUTIONS & SERVICES

5Issue 4 Autumn 2015

In this edition of the WMA Journal we not only look into history by celebrating our 25th anniversary

since the foundation year of 1990, but are bang up to date in focusing on the very modern threat to our community from cybercrime and on today’s dilemma about how to handle in regulatory terms the changing nature of research.

This mix of old and new characterises much of what we at WMA represent. Old fashioned virtues of knowing your customer and his or her needs and requirements well, and acting at all times in his or her best interests, combined with concerns about the impact of digital technology and MiFID II on firms, clients and business alike.

We aim to make sure that this full range of regulatory and other interests of our members is covered in the work we do, and that we maximise the numbers of “wins” we get for our community by securing where possible the best approach for us by legislators and regulators, eliminating the worst, and mitigating where neither extreme can be achieved. And we do so in part by explaining that those old fashioned virtues still apply in our neck of the financial services forest, so the authorities need have no doubt that the customer always comes first.

It is important as we go forward ever deeper into the digital era, where electronic means make the nature of retail investment business and the individual’s relationship with the external world change as we read this, to incorporate the good lessons from the past into the modern context. Our 25th anniversary is just the moment to remind ourselves of this.

John Barrass, Deputy Chief Executive of the Wealth Management Association

Would you like to contribute an article? Alongside updates from the WMA, the Journal includes several useful inputs from our associate member firms. These articles are an excellent opportunity to gain interesting insights into the wider industry and to learn more about WMA associate members. If you are an associate member who is interested in contributing to future editions of the Journal then please contact: Jason Baxter (jasonb@thewma.co.uk) or Sheena Gillett (sheenag@thewma.co.uk)

Foreword From The Editor

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With the headlines dominated by constant high profile

attacks, cybercrime has become an increasingly pressing issue for individuals and businesses alike. Wealth management firms are also at risk because of the large amounts of personal and financial information they hold for their clients.

In fact, wealth managers and other companies in the financial services sector are more than twice as likely to be attacked than those in other industries. Thirty nine per cent of companies in the financial services sector suffered cyber attacks in 2014, compared to just 17 in other sectors, according to research from analysts PwC [1].

The industry has responded to the threat with increased investment – 38 per cent told PwC they are boosting spending on cyber protection this year [2]. This is a good start and investment must continue, but the WMA believes firms must also ensure both their staff and their clients are aware of the risks.

Liz Field, CEO Of The WMA, Warns That Employees And Clients Are The True Priority For Defence Against Cybercrime

Liz FieldCEO, Wealth Management Association

7Issue 4 Autumn 2015

Wealth management firms are an attractive target for cyber criminals because they hold a large and varied amount of personal information about their clients. Extremely sensitive data including bank account details, addresses, risk appetites and family information must be kept on file as standard, making every firm a potential source for criminals looking to access financial information and commit identity fraud.

While it is encouraging that so many firms are investing in more cyber security measures, this is meaningless if the human side of the business does not keep up. Spending a fortune on state-of-the-art security without investing in knowledge is akin to installing a bank vault and leaving the back door open.

We have seen our members increasingly implementing new cyber-security measures including encryption, coding and the use of complex passwords. Nonetheless,

research from IT trade association CompTIA has found that human error is the cause of 52 per cent of all security breaches [3].

Cybercrime has become increasingly lucrative as more data is created and stored, with the current amount of global data expected to increase 50 times over by 2020 [4]. Attacks are believed to cost the global economy more than half a billion dollars every year, with GCHQ estimating that eight out of ten leading British firms have suffered serious attacks.

The truth is that every employee of a wealth management firm is a potential security gap, and just one person not following procedure is enough to let hackers into the organisation. All firms should hold regular training programmes to educate employees about the risk posed by cybercrime, both at work and at home.

Social media is an especially big blind spot for many organisations, with employees being unaware of how easy it is to inadvertently leak sensitive information, or the danger posed to their firm and its clients if they are hacked themselves.

It is vital to constantly review and tighten procedures and protocols, as well as investigate new lines of defence, especially as firms increasingly digitise their offerings. Clients must also be brought up to speed on the risks facing their wealth and coached on taking steps to protect themselves.

The WMA is facilitating the sharing of safe practice information and awareness of cyber threats in order to help its member firms better cope with the threat of cybercrime. The association is working closely with experts in the field and with the National Crime Agency (NCA) to provide events and reference materials for its member firms this year.

[1] https://www.pwc.com/en_GX/gx/financial-services/publications/assets/pwc-gecs-2014-threats-to-the-financial-services-sector.pdf[2] http://www.pwc.co.uk/financial-services/issues/financial-services-firms-plan-to-increase-cyber-spending-cbi-pwc.jhtml[3] http://www.cbsnews.com/news/the-human-element-and-computer-security/[4] http://e27.co/worlds-data-volume-to-grow-40-per-year-50-times-by-2020-aureus-20150115-2/

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The Changing Face of Research: Quant Is Not EnoughFortuna AllFunds

9Issue 4 Autumn 2015

Changes which have affected the asset management industry

since the onset of the global financial crisis are also having a significant impact on the nature of Research and its place in the investment chain. Among many advisors and wealth managers, fund selection used to be undertaken by the in-house team, whose ‘day job’ was stock selection. This made sense, since stocks and shares used to comprise a far higher proportion of any investment portfolio than they do now.

However, there are now more funds listed than shares, and especially since the rise in passive strategies, there are more fund holdings than individual stocks in any pooled investment structure. To keep up with the proliferation of product implies a high level of resource, specialist skill at selecting funds, and a process which relies heavily on rigorous, independent Research.

Managing fund buylists

Allfunds Bank began investment research after having developed

a requirement to present mutual funds in a consistent way to clients. It then honed its fund selection skills and tools which enabled clients to determine exactly where managers create value, via performance and risk management. The AFB Platform now has more than £145bn assets under administration and offers close to 40,000 funds from 450 fund managers.

As ever, regulation has provided the impetus for changing Research models. Previously, wealth managers would tack fund selection onto equity research, producing a list of funds which they liked, but which were not necessarily consistently researched. In a post-RDR environment, that no longer satisfies higher levels of

governance, or investor demands. Financial advisors at all levels have to be able to demonstrate how they compile their buylist, as well as how it is monitored and reviewed.

The risks of doing otherwise have become clear. With the

proliferating number of fund platforms, the assumption that all funds are bought through advisors is no longer valid. Given the vast global fund universe, few organisations have the resources to conduct proper due diligence on each product. The result is that many advisors simply revert to the financially strong, high-paying, well advertised big ‘brand’ names for their buylists.

Moral hazard

Such ‘pay to play’ is a moral hazard for the industry: the larger product

providers are recommended and grow assets under management, while managers with fewer and smaller funds struggle to get noticed at the very point where they tend to produce the best returns for their investors. A fresh, unconflicted and cost-effective solution is essential for a modern business model.

Is selecting a fund so much more complicated than buying a stock? The answer has to be yes, since the fund should be deconstructed to fully understand the client’s overall risk profile. A UK Equity fund, for example, may have considerable emerging markets exposure if it has FTSE100 stocks, and that may be duplicated elsewhere in the client portfolio.

Adding valueIn buoyant markets, small shifts in a

fund manager’s style and process may be ignored, as the rising tide floats all boats, but in a low-return market, every

basis point counts. Debate continues over the precise contribution to overall returns of each part of the fund selection process. Does asset allocation or stock selection add most value? Eighty percent of value may be derived from asset allocation and just 20% from stock picking, but in current conditions, few would forego that

20%.Clients are now increasingly only

prepared to pay for Alpha, so how

does independent Research deliver this? It inevitably starts with thorough quantitative analysis. Researchers can run the statistics, set up the algorithms and work out the equations. At Allfunds Bank, we would argue this is a necessary, but not sufficient step in the process. Research cannot begin and end with the industrialisation of Alpha. The Quant is not enough.

Investing, for all its global reach, remains a cottage industry, albeit a complex one. In a post crisis era, regulatory compliance and demonstrable governance are absolutely critical, delivered not via tickboxes and automation, but with holistic, intelligent analysis applied to each mandate. Wholesale outsourcing responsibility for this appraisal to a ratings system is also unacceptable.

The nature of Research is changing as investors and advisors demand more information before they select a fund, or a manager. Quantitative analysis remains the foundation for many decisions, but qualitative judgements are just as important.

“Debate continues over the precise contribution to overall returns of each part of the fund selection process.”

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Research challengesSo the demands on the Research

function continue to build up. It has to determine where quantitative processes are robust, but qualitative judgement is weak. It has to ascertain exactly how much Beta is hidden in the fund management process. It must point out opportunities, identifying the rare instances where value is undetected, the nature of that value generation, and match those moments to client needs.

The hazards of performance data, where a top quartile fund may drop quickly to bottom quartile, highlights the challenge of consistency. All marketing literature carries the warning that “past performance is no guide to future returns”, and yet managers and investors continue to act as if it does. The flaw in a purely quantitative process is that it is backward looking.

Experience shows that forward-looking qualitative judgement has to be wrapped around quantitative approaches. Not only is objective analysis probably not possible, but peer-tested subjective analysis can be valuable by bringing all-important experience to bear. Fund selection is not just about analysing future market trends, but also judging how a particular manager might perform in that future environment. Therein lies the Alpha.

Combining Quant and Qual

At AFB, we run a two part process – starting with compliance and

governance and the analysis of the objective numbers, and continuing with informed peer review. One team conducts the quantitative and qualitative assessment of both funds and fund management companies, and another takes that research and tailors it to individual client needs.

Our own capability is constantly under scrutiny. In December 2014 we attained the ISO 9001:2008 standard for our Research process from the British Standards Institute, recognition of our consistent approach to the Research function, which emphasises meeting customer requirements, adding value, monitoring performance and effectiveness as well as ensuring continual improvement.

Wealth managers know that a muddle-through approach to Research and fund selection is no longer adequate. Clients deserve a quality outsourced option, publicly recognised for its internal process disciplines, its content and customer service.

The flaw in a purely quantitative process is that it is backward looking

11Issue 4 Autumn 2015

Allfunds Investment Research Backs A Fund Through A Temporary Blip

Case study:

In 2013, the Jupiter European Growth fund experienced a performance blip, slipping down to third quintile in the Allfunds proprietary ranking tool. However, analyst Mark Hinton still recommended the fund for AFB’s Insight List demonstrating the importance of qualitative analysis. Over the five years to end June 2015, the fund is +33.9% ahead of the MSCI Europe Index. Since inclusion on the list in May 2013, it has outperformed the MSCI Europe Index by +10.9%.

• Manager Alexander Darwell’s philosophy and process is proven and has been consistently applied since 2007 for this fund and since 2001 for a similar Europe ex-UK strategy

• Regular meetings with Jupiter management and the fund manager demonstrated a clear understanding of the fund’s process, positioning and performance drivers

• The fund screened consistently well in the AFB proprietary ranking tool. It was 1st quintile in the peer group (Europe Growth funds) in the period up to inclusion in May 2013.

• The reason for the fund’s temporary performance dip – its quality bias and structural underweight to cyclicals in a strongly rising market – was clearly explained.

• The fund performance rebounded strongly as quality growth stocks regained favour. It is benefitting from the weak euro, and has good exposure to global growth outside of Europe.

• The fund’s AFB ranking returned to 1st quintile from H2 2014 and has remained there through 2015. The fund is top quartile over 1, 3 and 5 years, and since April 2007 when Darwell became manager.

Why the fund was selected in 2013 and remains a High Conviction ‘Insight’ fund:

Jupiter European Growth fund:

Five years relative performance (to end June 2015) vs MSCI Europe, and AFB Quantitative Quantile Ranking evolution

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25 Facts Celebrating 25 Years: 1990–2015

In 1991, there were 3.3 million trades in

the UK by full service wealth manager firms; in 2014 there were 6.43 million

In 1994, APCIMS’ membership was expanded from only private client

investment managers and stockbrokers to also including portfolio management firms whose clients are predominantly private investors

In 1998, the year online trading launched, there were 7

million online trades in the UK; in 2013 there were over 10.5 million

The association has been

campaigning to the Chancellor for the removal of stamp duty on share trades since 1994

The FTSE WMA Growth, Income

and Balanced Indices were launched in 1997

In 1999, only 83% of

APCIMS members had a website; today all WMA members have a website

A P C I M S / W M A merged with the

European Association of Securities Dealers (EASD) in 2002, and remained a joint association until 2008

APCIMS/WMA has had an Annual

Conference every year for the last 18 years

A P C I M S / W M A launched the

online “find a broker or wealth manager” facility in 1996, which still exists today

In 1998, APCIMS firms employed

more than 12,000 people; today WMA firms employ about 30,000 staff

In 2003, A P C I M S / W M A

member firms had £240 billion of client assets under management or administration; this figure is now over £670 billion

In 1991, there were 3.7 million

execution only trades in the UK; in 2014 there were 17.04 million

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In 2003, APCIMS responded to 21

consultations; in 2014, WMA responded to 25 consultations

A P C I M S /WMA has

had 6 Chairmen in its 25 year history

The WMA is currently supported by more

than 250 committee and advisory board members

The FTSE WMA C o n s e r v a t i v e

and Global Growth Indices were launched in 2012

A P C I M S /WMA has

had 6 CEOs in its 25 year history

Regulation has consistently been

stated as one of the biggest concerns facing APCIMS/WMA members

APCIMS was rebranded as

Wealth Management Association (WMA) in 2013

The longest serving CEO was Angela Knight,

who was CEO for over 9 years (1997-2006)

WMA staff visit key influencers in

Europe at least once a month, and have been working with EU regulators and policymakers since inception

Wider Share Ownership

Council (WSOC) launched in 2014

APCIMS/WMA have always operated on a

strong committee structure since inception in 1990

A P C I M S /WMA has

regularly produced a directory of its members since inception in 1990

W M A m e m b e r

firms operate from over 580 sites in the UK, Ireland, Isle of Man, Channel Islands and international locations

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WMA welcomed over 300 guests to help celebrate its 25th anniversary held at the Paternoster Chop House, just steps from the London Stock Exchange from which the embryonic WMA emerged.

The event brought together prominent guests including member firms, members of parliament, MEPs, media, regula-tors, government officials and other key industry figures.

WMA CEO Liz Field started proceedings by discussing how for the last 25 years, the WMA has been working to ensure that political business and regulatory changes are appropriate and reflective of the needs of its members firms and through them the needs of the private investor.

Guests then had a look back over the quarter century with a video showing WMA’s journey so far and heard from the first Chairman of APCIMS/WMA John Cobb and also its longest standing Chief Executive, Angela Knight.

Paul Killik, Senior Partner at a member firm and a WMA board member then highlighted some of the key changes and developments in the wealth management industry over the last 25 years with fascinating insights from an individual who has been involved with APCIMS/WMA since the organisation began.

WMA 25th Anniversary Drinks Reception

WMA welcomed over 300 guests to help celebrate its 25th anniversary held at the Paternoster Chop House, just steps from the London Stock Exchange from which the embryonic WMA emerged.

The event brought together prominent guests including member firms, members of parliament, MEPs, media, regulators, government officials and other key industry figures.

WMA CEO Liz Field started proceedings by discussing how for the last 25 years, the WMA has been working to ensure that political business and regulatory changes are appropriate and reflective of the needs of its members firms and through them the needs of the private investor.

Guests then had a look back over the quarter century with a video showing WMA’s journey so far and heard from the first Chairman of APCIMS/WMA John Cobb and also its longest standing Chief Executive, Angela Knight.

Paul Killik, Senior Partner at a member firm and a WMA board member then highlighted some of the key changes and developments in the wealth management industry over the last 25 years with fascinating insights from an individual who has been involved with APCIMS/WMA since the organisation began.

15Issue 4 Autumn 2015

16 WMA Journal@WMA_UK

The second quarter of 2015 showed less promising results than the first quarter of the year, although year on year comparisons prove more encouraging. Investment assets for Wealth Managers fell slightly by 2.1% but increased for Execution Only Stockbrokers by 2.3%, leading to an overall total investment asset value of £732bn, a 1.3% drop on Q1. However, this is compared to a market decrease of 3.4% as measured by the FTSE WMA Balanced Index. The industry also outperformed the market year on year, (an 8% increase against 3.7%).

Trade volumes fell by 3.4% last quarter, although they increased year on year by a healthy 14.2%. Commissions reduced for both Execution Only Stockbrokers and Wealth Managers (down 8.8% in total) as a result of the lower volumes and continued movement towards fee-based charging.

Total revenues were down 4.9% on the previous quarter and by 0.2% year on year, one of the few key statistics to fall on a yearly basis. Profit margins also decreased for both Execution Only Stockbrokers and Wealth Managers, although Wealth Manager profit margins dropped at a greater rate.

Total costs were down 1.8% quarter on quarter, as a result of improvements in efficiency and lower trade volumes. This softened the blow on profit margins of reduced total revenue across the industry.

The following excerpt is taken from ComPeer’s quarterly update of the UK Wealth Management Industry report

Quarterly Update: Quarter 2 2015

Industry Statistics

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18 WMA Journal@WMA_UK

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Issue 4 Autumn 2015

WMAJOURNALIssue 4 Autumn 2015

Defence against Cybercrime

The changing face of research

25 facts celebrating 25 years of the WMA

Industry Statistics

The importance of implementing a robust

policy management programme

In this issue

Stay up to date with the WMA across social media

19Issue 4 Autumn 2015

Wealth Management Association organisations continue to

face a tsunami of regularity pressure and scrutiny, placing an ever-increasing burden of responsibility on compliance teams.

Penalties for non-compliance include eye-watering fines,

reputational damage and in extreme cases, the closure of business.

A sea change in director accountability now makes Board

Members responsible for the actions of employees and while the majority of organisations have taken steps to meet this requirement, many are failing to adopt adequate methods to demonstrate Best Practice and distance themselves from the actions of rogue individuals.

Ensuring all employees, supply chain partners and agents across a global

workforce have read, understood and signed-up to key policies can be a logistical nightmare and major challenge for any regulated company.

As relentless regulatory and security demand continues to drive the

cost of compliance upwards, those using traditional and time-consuming methods to communicate policies and procedures are increasingly buckling under the financial strain.

It is no longer possible to simply ignore a Policy or Procedure and

hope it goes away or worse still, claim that it was not received in the first place.

The key function of policy compliance is to:

• Ensure the correct policies reach the right people at the right time;• Ensure employees read, understand and sign-up to key policies;• Identify employees who have not adhered to a policy; • Regularly review, assess and update policies;• Provide senior management with detailed reports and a clear audit.

By Tim Wilson, Sales Manager - Wealth and Investment Management, Hitec

The Importance Of Implementing A Robust Policy Management Programme

20 WMA Journal@WMA_UK

Why should companies divert precious resources away from key business areas and allocate them on creating and communicating policies?

ReputationA robust policy management system reduces the chance of litigation and the negative impact on reputation by keeping an accurate audit trail. Goals Setting positive goals and communicating them to your workforce can help imbue a positive, “can-do” culture within an organisation. CultureCommunicating a clear policy that outlines what is expected from employees and how they conduct themselves, helps to shape appropriate behaviour. Many of the world’s most successful organisations are characterised by a clear, well established, ethical culture. AccountabilityWell drafted and effectively deployed policies help to embed Best Practice, strengthening accountability by ensuring people sign up to relevant policies and procedures and leaving a clear audit trail. AgilityA good Policy Management system enables organisations to react swiftly to changing market conditions and regulatory mandates. Time-ManagementEffectively communicating policies achieves internal efficiencies, saving money by driving down administration time and cutting costs by automating a previously labour intensive process. How should organisations implement a robust policy management system? Creation of PoliciesExperienced professionals within a company can play a key role in drafting and creating policy, although it is worth bearing in mind this can be a time-consuming process. Pro-forma policies are available on the internet but these tend to be expensive, difficult to tailor and the onus is on organisations to keep them up-to-date. Another option is to engage a third party professional, such as a lawyer or consultant, to assist with policy drafting (or review

what has already been produced in house). While this can be the costliest option, it does free up senior management time and shifts the onus of keeping policies up-dated to a third party.

Deploying and auditing policyOrganisations are adopting a wide-range of expensive, time-consuming and ineffective strategies to deploy policies, such as: Pinning policies on notice boards and/or publishing them on the intranet, a method that leads to them often being ignored by staff. Issuing new employees with a staff handbook and including a clause in their contract obliging them to read the information. In reality, few employees actually take time to read a policy handbook, which is rarely updated to reflect new policies. Circulating paper copies of a policy with the requirement that they are signed and returned to the issuing manager, a method that means an organisation has no way of knowing if it has been fully understood.

Distributing policy via email may have the advantage of leaving an audit trail, but it is too easy for employees to delete or ignore incoming messages.

ConclusionWealth Management organisations are increasingly looking to technology to manage the demands of adhering to compliance requirements. One of the industry’s biggest challenges is managing the significant and growing number of Policies and Procedures that they are required to communicate to staff. One way to demonstrate Best Practice is to implement a bespoke technology based Policy Management solution that supports the key principles of the UKBA/FCPA and BSI 10500, ensuring a clear compliance audit trail for the benefit of the Board, Senior Management, Auditors and Regulators. Jeremy Crame, CEO of Hitec says: “The only way companies can demonstrate Best Practice and distance themselves from the actions of a rogue individual is to implement a bespoke technology based Policy Management solution that ensures a clear compliance audit trail for the benefit of the Board, Senior Management, Auditors and Regulators and reduce risk.”

21Issue 4 Autumn 2015

Below, Hitec sets out five basic stages that should form the backbone of any successful policy management programmes:

Stage One – Establishing policy requirements• Audit employee understanding of the regulatory environment.• Retain data to feed into subsequent stages of the policy life cycle.

Stage Two – Drafting policies• Cut and paste or import policies from existing documents. • Collaboratively draft and edit.• Use Version Control to ensure the latest version of policy and procedure is always being

worked on.

Stage Three – Policy deployment• Deliver a clear and consistent presentation of the right policies to the right people across the

organisation.• Set automatic reminders to those employees who haven’t signed up to policy documents.• Specify different policies for different user groups.• Provide individual policy libraries with access to up-to-date policies in each.• Automatically present policies in local languages to staff whatever their location.

Stage Four – Testing understanding and affirming acceptance• Ensure secure confirmation by staff that they agree to terms of the policy.• Test employee understanding through random, multiple-choice questions for most important

policies, such as anti-bribery and anti-money laundering.• Set automatic reaffirmation – periodically re-present policies to refresh / reinforce

understanding.• Respond to low scores or non-agreement e.g. re-presents policies and questionnaires, alert

policy owner.

Stage Five – Auditing and reporting• Capture and display detailed data on effectiveness of policy deployment.• Demonstrate acceptance and understanding of policies (by policy, groups, individuals, over

configurable timescales etc).• Provide audit trails e.g. who received/agreed to which version of which policy on what date.• Highlight ambiguous or poorly worded questions.

To learn more about Hitec and how it can help implement a policy management pro-gramme, visit www.hiteclabs.com/policyhub

Five Critical Stages Of Policy Management

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WMA members

ACPI Investments LtdArcrate*ADM Investor ServicesA J Bell Securities LtdAlbert E SharpAndrews Gwynne LLPArbuthnot Latham & Co LtdArnold Stansby & Co LtdAshcourt Rowan AssetManagementBarclays Bank PlcBarratt & CookeBlankstone Sington LtdBordier & CieBrewin Dolphin LtdBRI Wealth Management PlcBrooks Macdonald Asset MgmtBrown Shipley & CoCambridge Investments LtdCanaccord Genuity Wealth(International) LtdCanaccord Genuity WealthManagementCave & Sons LtdCazenove Capital MgmtCharles Schwab UK LtdCharles Stanley & Co LtdC Hoare & CoCity Asset Management PlcClose Brothers AssetManagementCornelian Asset Managers Ltd

Coutts & CoCunningham CoatesDavyDeutsche Bank Private Wealth MgmtDuncan Lawrie Asset Management LtdEdwards Securities LtdEFG Harris AlldayEquiniti Financial ServicesFidelity Worldwide InvestmentFiske PlcGHC Capital Markets LtdHalifax Share Dealing LtdHargreave Hale LtdHavelock Hunter Stockbrokers LtdHawksmoor Investment Management LtdHeartwood Wealth Management LtdHedley & Company Stockbrokers LtdHSBC Global Asset Management UK LtdHSBC Investment ServicesHubwise Securities LtdICON Personal Share DealingIG GroupIM Asset Management LtdIngenious Asset Management Ltd

Interactive Investor PlcInvestec Wealth & Investment LtdJames Brearley & SonsJames Hambro & Partners LLPJames Sharp & CoJefferies International LtdJM Finn & Co LtdJulius Baer International LtdKillik & Co LLPM D Barnard & Co LtdMultrees Investor ServicesMurray Asset Management LtdMosaic Money Management*Nutmeg Savings & Investment LtdN W Brown Group LtdOdey Wealth ManagementPershingPilling & CoProspect Wealth Management*Premier Asset ManagementQuilter CheviotRamsey Crookall & CoRathbone Brothers PlcRaymond James InvestmentMgmt PlcR C Brown Investment Mgmt PlcRedmayne-Bentley LLPReyker Securities PlcRossie House InvestmentManagement

RothschildRuffer LLPS&T Asset Management LLPSanlam Private WealthSantander SharedealingSarasin & Partners LLPThe Share CentreSmith & Williamson InvestmentManagement LtdSpeirs & Jeffrey LtdStandard Life Wealth LtdSt James’s Place WealthManagementStockdale Asset Management*StocktradeTD Direct InvestingThesis Asset Management PlcTilly Bailey & Irvine LLPTilman Asset ManagementTilney BestinvestTroy Asset Management LtdTurcan Connell Asset Mgmt LtdVartan Ravenscroft - a tradingname of A Vartan LimitedVeritas Asset Management (UK) LtdVestra Wealth LLPWalker Crips StockbrokersWaverton Investment ManagementW H Ireland LtdWhitefoord LLP

Full Members107 of our members are wealth management and broking firms that deal directly for the private investor. Over £650 billion of the country’s wealth is under the management of these members. Our current list of full members is as below

ActuareAllFunds BankAlpha Financial Markets ConsultingAltus LtdBITA RiskBNP Paribas Securities ServicesBovill LtdBRP Bizzozero & Partners UK LtdCalastone LtdCampion CapitalCharles Russell Speechlys LLPChartered Institute for Securities &Investments (CISI)Clearstream Banking SAClyde & Co LLPCoFunds LtdComarch UK Ltd

CommonTime LtdComPeer LtdDeloitte LLPDion Global Solutions (London) LtdEquiniti XaniteEuroclear UK & Ireland LtdFinancial Services Training PartnersFNZ UK LtdFundsNetworkGoal Group LtdGoldman Sachs InternationalHerbert Smith FreehillsHITECHowden Risk PartnersHuntswoodInteractive DataInvestec Capital MarketsInvestment & Wealth MgmtConsultants LtdJersey Finance

JHC Systems LtdKinetic Partners LLPKing & Wood Mallesons SJ BerwinKnadel LtdKPMG LLPLark (Group) LtdLloyd’sLloyds Banking GroupLombard RiskLondon Stock ExchangeMaclay Murray & Spens LLPMorningstar UK LtdNorton Rose Fulbright LLPObjectway Financial SoftwareOriel Asset Management LLPOriel Securities LtdPeel HuntPlatform SecuritiesProfile SoftwareProquote LtdPulse Software Systems Ltd

Resources Compliance (UK) LtdRoyal Bank of Scotland –Financial Institutions GroupRPCSales KineticsSEIShore Capital StockbrokersSimCorp CoricSocial Stock ExchangeTravers Smith LLPVanguard Asset ManagementWealth DynamixWealth-XWillis GroupWinterflood Securities LtdWisdomTree Europe Ltd

Associate Members76 firms are associate members who do not deal directly for the private investor but share the aims of the WMA community. Our current list of associate members is as below:

Correct as of 18.08.15

23Issue 4 Autumn 2015

No responsibility for loss to any person acting or refraining from acting as a result of any material contained in this publication can be accepted by the WMA, the author, publisher or printer. The views expressed by individual contributors are not necessarily those of the Association.

Company limited by guarantee. Registered in England and Wales.No 2991400. VAT registration 675 1363 26. Published for the WMAby WordWide London. Copyright WMA 2014.

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24 WMA Journal@WMA_UK