Client Discretionary Management Agreement

Welcome to FINT.

FINT is a technology platform which provides you with the ability to invest in managed portfolios of exchange traded funds (ETFs) with specific tilts towards the environment, e-sports and disruptive technologies. The basic portfolio of Investments we use for each of our portfolios is a broad based but ethically vetted spread of funds for stability and diversification of your Investment, on top of which we invest 20% into your chosen fund type.

FINT has several portfolios designed to meet certain Investment characteristics – so, when you complete our onboarding process and answer the questions about investing and how that resonates with you, our system will recognise the portfolio type best suited to your wants, needs and current financial circumstances. As an example, in each of the categories (environment, e-sports and disruptive technologies) there are portfolios designed for people who are:

  • cautious and for whom risk of loss outweighs other major considerations;
  • willing to take moderate risks but recognises that with that there is a likelihood of moderate gains; and
  • wish to take higher risks to gain higher rewards but who also acknowledge that those risks mean there is a higher likelihood of losing money.

Your Investment on FINT is managed by Ironmarket. Ironmarket designs and manages the portfolios into which your Investment goes and manages settlement, custody and all queries arising from your Investment and your use of FINT. Ironmarket is Ironmarket Limited, which is an independent financial advisory firm which is authorised and regulated by the Financial Conduct Authority in the UK (FCA) (under firm reference number: 620330).  Ironmarket’s address is Unit 10 Brindley Court, Dalewood Road, Lymedale Business Park, Newcastle-under-Lyme, ST5 9AQ. Ironmarket’s telephone number is 01782 461563, and its email address is:

We have a dedicated customer support email for FINT which is

Your use of FINT is subject to this Agreement and our Fint APP terms, which are available at (FINT App). This Agreement are the terms upon which Ironmarket provides its investment management services to you and the FINT App terms are your Agreement with FINT as to your access to the FINT App and platform.

The FCA is the financial conduct regulator in the UK. Ironmarket is subject to the FCA’s detailed rules (FCA Rules) when it manages your Investments and is answerable to you and the FCA for its conduct. The FCA can be contacted at 12 Endeavour Square, London E20 1JN ( or telephone 08001116768).

You are a RETAIL CLIENT of Ironmarket under the FCA Rules.  This means you have the highest level of protection afforded by the FCA Rules to customers. You will also have the right to take any complaint which you cannot resolve with us to the Financial Ombudsman Service. The Financial Ombudsman Service can be contacted at Exchange Tower, London, E14 9SR, telephone 08000234567 or Further details of the Financial Services Comprehension Scheme are available from Taking a complaint to the Financial Ombudsman Service does not prevent you from taking your own legal proceedings. You may at any time ask us to re-categorise you as a potential client or an eligible counterpart, but it is not our policy normally to re-categorise a retail client and we can reject such a request at our discretion.

The terms which follow (@this Agreement’) govern your Investments on FINT and constitute a client Agreement between you and Ironmarket. References in this Agreement to “you” or to “the Customer” are to you and references to “us” or “our” or “we” are to Ironmarket. If you see a word beginning with a capital letter which is not a name (such as the name ‘Ironmarket’) it is a term with a specific meaning, which is known as a defined term. To make this Agreement easier to read we have placed the definitions in Schedule 1 to this Agreement. You should refer to those definitions where they are relevant, for clarity.

Summary at a glance

Set out below are important summary points of our Services.  These summary points are for your reference only and you should read all this document and our website terms and privacy notice before you proceed.

  • This document defines your use of our Services and your relationship with Ironmarket. It should be read in full and in conjunction with the Schedules. If you are unclear on any key aspect, please contact us as set out above under ‘Hello’. If you do not like any aspect, do not invest with us.
  • Our Services are primarily designing and managing your Portfolios (for more details see section below). We engage with a Custodian which is regulated by the FCA to hold your Investments for you and to manage any cash balances from time to time. Our current Custodian is WealthKernel Limited (WealthKernel). For more background on the Custodian, please see
  • We are not providing financial advice on or via FINT or to FINT Customers. This means that we do not recommend an Investment type or Investment style for you – you are responsible for making these decisions. This is because to form a detailed picture for an individual requires more information and more interaction than can be offered on an internet based platform. The beauty of a platform such as FINT is speed and ease of access, and low-cost operations which should enhance your returns on your investment. FINT is therefore likely, subject to our onboarding processes, to be suitable for most people. If you have complex personal or personal tax circumstances, you should seek independent financial advice before Investment with FINT.
  • Opening an Account on FINT is at  our discretion  and all  Customers  are subject  to  a  suitability assessment at the onboarding stage and may be subject to periodic reassessment thereafter.
  • We only provide access to FINT to adults (over 18) who are UK resident. If you do not fall into these categories, FINT is not for you.
  • All Customers will be subject to anti-money laundering identity checks at our onboarding stage and may be subject to periodic reassessment thereafter. These checks will include proof of identity and residential address via bank details provided to us and other electronic  means.
  • We will typically invest your funds within five (5) Business Days from when they are received by us. You may not see the Investment value on the FINT dashboard page until that time but the cash value will be reflected in the portfolio dashboard screen.
  • Withdrawals from the FINT platform will typically take up to ten (10) Business This is because your money is invested in funds which are listed on stock  markets and we may need to  sell some or all of your Investments first  before we can send you your money.


Risk Warning: Please remember that the value of your Investment can go down as well as up and you could get back less than you invested. The tax treatment of your Investments will depend on your individual circumstances and may change in the future. If you’re unsure whether investing or this Investment is right for you, please seek financial advice. Please see Schedule 3 which sets out the key risk factors affecting your Investment in more detail before you decide to invest.

A short guide to ETFs is available in Schedule 4.

Please download this Agreement and read them.  If you have any questions at all, please get in touch by phone, live chat (when available) or email to the contact details above.


    • This Agreement form a client Agreement made between you and Ironmarket which is subject to English law and to the FCA Rules.
    • This document sets out the terms under which we shall provide the Services to you, including details of the Services and a summary of our Charges and all other charges for those Services. Under this Agreement, we agree to provide the Services for the Portfolio(s) you select, and you agree to pay us for those Services.
    • By clicking accept, you agree to this Agreement which appoint lronmarket to manage Investments covered by this Agreement on a discretionary basis. A discretionary basis means we can affect transactions in your Portfolio for you without your prior approval. We need your Agreement to this because it is not administratively possible or cost-efficient for you, for us to have to seek your consent prior to every transaction.
    • You should only click accept – which means this Agreement are binding on you (and on us) when you are happy that you understand to your satisfaction the risks involved and you are happy that we have your complete discretion. If you are in any doubt about any term of this Agreement you should consult your solicitor, accountant or other professional adviser (Independent Professional Advisor).
    • If you do not agree to this Agreement, please do not apply to use the Services.
    • You should not treat any part of this document  or the  contents  of the  FINT  Website  or mobile  app as  constituting advice to you on taxation, legal, financial or any other matters and you should consult your own Independent Professional Advisor accordingly. The tax you must pay is personal to your circumstances and we are not advising you on that, or on tax rates, and the basis of tax charges is subject to change.
    • This Agreement, the Schedules and other documents referred to in this Agreement constitute a legal contract between you and us and set out both your and our rights and obligations under the Agreement  between you and us and you and FINT, together with important  information  regarding the  Services that we will provide to    For your own protection you should read them carefully before accepting them.  If you do not understand anything, contact us to ask for further  information on
    • If it is found that any section within this Agreement is invalid, that invalid section will have no effect on the validity of the remaining sections in this Agreement. The remaining Terms will continue to remain in place.
    • We have used plain English wherever possible but avoiding technical terms is not always possible. If you do not understand any part of the Terms you can should contact us to as for further information or should contact a Independent Professional Advisor.
    • Any terms and definitions used within this Agreement (which are capitalised) can be found in Schedule 1.
    • This Agreement, the Fint App terms and the FINT privacy policy(Related Documents) constitute the entire agreement between you  and us and supersede  and extinguish  all  previous Agreements  and arrangements  between  us, whether  written  or oral,  relating  to  their collective  subject    You acknowledge that you have not relied on any statement, promise, representation, assurance or warranty made or given by or on behalf of us which is not set out in this Agreement or the Related Documents.
    • This Agreement starts once our Account opening documents have been completed, the onboarding process is complete, you have clicked accept to accept this Agreement and the Related Documents, and we have sent to you via email a copy this Agreement as accepted by you and the Related Documents.
    • Once this Agreement has started, it will continue until you or we end it in accordance with Section 6 (Cancellation and Termination) below.
    • We may amend the Terms where we have a valid reason for doing so which will include to take account of changes to Applicable Laws or regulation or a decision of the Financial Ombudsman Service, changes to the way we are taxed or you and your portfolio we taxed or changes to the way Investment markets operate from time to time. If any amendments change how we manage the Services or handle your personal data, notification will be provided to you via email or live chat (when available) before they are due to take effect.
    • Changes will take effect ten (10) Business Days after the notice has been sent to you (unless a later date is provided for in the notice). Notifications will not be sent for any other amendments to this Agreement. Any amendment to this Agreement will not apply retrospectively.
    • Customers will not normally be required to sign a new Agreement or consent to any proposed amendments which will take effect as described above and you may choose, if you do not like any amendment, to end this Agreement without charge.
    • If, as a result of the amendments we make to this Agreement or any amendments the Custodian may make to its terms, you wish to close your Account with us, you may do so in accordance with this Agreement.
    • You acknowledge and accept that the information and data provided to you during the application process in respect of any potential Investment returns are for illustrative purposes only and do not guarantee the amount of returns which you may receive if you invest with us.
    • This Agreement, the Related Documents and any dispute or claim arising out of, or in connection with them or the Services (including non-contractual disputes or claims) will be governed by and construed in accordance with the laws of England.
    • You can bring legal proceedings in respect of This Agreement, the Related Documents and any dispute or claim arising out of, or in connection with them or the Services in the English courts. If you live in Scotland, you can bring legal proceedings in either the Scottish or the English courts. If you live in Northern Ireland, you can bring legal proceedings in respect of this Agreement in either the Northern Irish or the English courts.
    • Please note that neither FINT nor Ironmarket via FINT provides advice on Investments. If you have any questions regarding your Investments, including the risks associated with investing in a particular product or market, you should consider seeking independent advice from an Independent Professional Advisor. This might include, but may not be limited to, financial advice, Investment, legal and tax advice. We cannot give you any Investment, legal, taxation or other advice in connection with your Investments.
    • Our responsibilities to you in respect of your Investments will be limited to the management of your Portfolio as covered by this Agreement. We will not offer any broader financial planning and/or tax planning services, e.g. capital gains tax and inheritance tax considerations and accept no responsibility for your broader financial/tax planning arrangements or requirements.  It is recommended that you speak to an Independent Professional Advisor in relation to these areas.
    • The type of Portfolio you invest in will only be selected and become live after you have filled in the questionnaire sections of the FINT onboarding process, which will enable automatic assessment of your fundamental needs and financial objectives in investing via FINT and will incorporate to the extent it falls within the parameters of the Portfolio design the right Portfolio to take account of your attitude to any risks that may be involved.
    • We will manage your Portfolio at our discretion subject to the profile which arises from completion of the online questionnaire. The questionnaire tells us what your ability to absorb loss is and your attitude to risk. You will be unable to change your attitude to risk without recompleting the online questionnaire. Each Portfolio will then have your risk level displayed for you to see in the portfolio dashboard screen in FINT.
    • You should also refer to our Risk Explanation, at Schedule 3, which contains risk information relating to the Portfolios and the Investments in them.
    • We will review the Portfolio on an ongoing basis and if any changes are needed to ensure that your objectives are met then these changes will be made.
    • We will update you on the progress of your Investment on the portfolio dashboard screen, which shows the value in real time so far as possible of the Investments. There may be a time lag of up to 48 hours in this data so what you see as the value now will reflect the actual position at close of business on the previous Business Day.
    • We will use reasonable care and skill in performing our Services.
    • Where your Investments are held overseas, there may be different settlement, legal and regulatory requirements from those applying in the UK, together with different practices for the separate identification of clients and Investments. We will not borrow on your behalf, nor will we commit you to a contract that may need borrowing in order to achieve performance. We will not commit your monies to an obligation as an underwriter of any issue or offer for sale of securities.
    • The Custodian. We use the services of the Custodian to outsource settlement, custody and nominee arrangements for your Account. We will take responsibility for the selection of third-party custodians and will review their performance on an ongoing basis. Subject to the proper performance of these duties, we will not be held liable for any default by our selected Custodian.
    • We have entered into an agreement with WealthKernel, on behalf of ourselves and each of our Customers whereby WealthKernel has agreed to provide clearing and settlement, safe custody and associated services for our Customers. By opening an Account with us, you are also opening an account with WealthKernel. It is important for you to understand that this means you will be both our Customer and also a customer of WealthKernel.
    • In consideration of WealthKernel making their services available to you, you agree that:
      • we are authorised to enter into an agreement on your behalf with WealthKernel as your agent;
      • apart from this Agreement, you are bound by the WealthKernel custody terms and conditions which are available;
      • we are authorised to give instructions to WealthKernel on your behalf to provide information concerning you to WeathKernel and WealthKernel shall be entitled to rely on any such instructions or information without further enquiry; and
      • WealthKernel is authorised to hold cash and Investments on your behalf and is authorised to make a Cash Transfer or transfer Investments from your account to meet your settlement or other obligations to WealthKernel.
    • We reserve the right to change our Custodian, at which point we will give you reasonable advance notice, where practicable, of this change. You will be treated as accepting any such change unless you tell us that you do not agree to the change, in which case you have the right to terminate this Agreement by giving us notice at any time before the change comes into effect.
    • Other service provider. We use the services of Algochain Limited (Algochain) to obtain information, key Investment documents and to effect trades in units in relevant funds. Please see
    • Best execution. In placing or transmitting applications on your behalf to third parties, we will take reasonable steps to ensure that we obtain the best possible result for you. This is referred to as ‘best execution’. A summary of our best execution process is available in Appendix 1. We will combine your instructions with those of other clients. At times this may work to your advantage and others to your disadvantage. By accepting this Agreement, you are consenting to our best execution policy.
    • Valuations and benchmarks. Valuations of relevant units in the underlying funds in which your valuable cash is invested are obtained from Algochain. This is benchmarked periodically to comparable products.
    • Voting rights: As your appointed discretionary manager, we may at our sole discretion decide whether or not to exercise voting rights or Voluntary Corporate Actions relating to your Investments. This may mean that we act in accordance with or against the recommendations of boards or may not vote at all. We will exercise any voting rights attached to  shares registered  in the  name of the Custodian and held for you as the client. Consequently, you will not receive reports and accounts, circular or proxy soliciting material, unless specifically requested by you in writing in a  particular case. Where we exercise our discretion to vote we may do so on behalf of multiple clients. This may work to your advantage but sometimes to your disadvantage.  Should we identify a material conflict of interest between ourselves or clients in exercising our discretion to vote we will  not proceed without first obtaining your express prior consent. We will seek to act in accordance with the best interests of our clients when exercising (or not exercising) voting  rights or taking  up (or not taking  up) rights arising from Corporate Actions.
    • Anti-money laundering and identity checks. We are required by the anti-money laundering regulations to verify the  identity of our clients, to obtain information  as to the  purpose and nature  of the  business which we conduct on their behalf, and to ensure that the  information  we hold is up-to-date. For this purpose, we may use electronic identity verification systems and we may conduct these checks from time to time throughout our relationship, not just at the beginning.
    • Conflict of interests. We will endeavour always to act in the best interests of you, our client. However, circumstances can arise where we or one of our other clients may have some form of interest in business being transacted for you. If this happens or we become aware that our interests or those of one of our other clients conflict with your interests, we will write to you and obtain your consent before we carry out your instructions, and detail the steps we will take to ensure fair treatment. A summary of our conflicts of interest policy is available at Appendix 2.
    • Other benefits we may receive. From time to time we may attend training events funded and/or delivered by product providers, fund managers and platforms. These events are designed to enhance our knowledge and ultimately, therefore, enhance the quality of service we provide to our clients. Further details are available on request. We may also receive other non-monetary benefits from product providers, fund managers and platforms. In each case, we will ensure that the receipt of these benefits is allowable and does not conflict with the adviser charging rules.
    • Communicating with you. We may communicate with you by telephone, post, e-mail or in person. In certain circumstances, we may ask you to confirm any instructions in writing prior to implementation. All our communications with you will be in English. All your personal and financial information will be processed in accordance with our privacy policy
    • We reserve the right not to act on your instructions if:
      • to do so may involve us or you in a breach of legal and/or regulatory requirements; or
      • we believe on reasonable grounds that to do so would be impracticable or against your interests; or
      • to do so would run the risk of us suffering a financial loss.

We endeavour to advise you promptly if such circumstances arise, subject to our obligations under Applicable Law and regulation.

  • If you die. We will suspend taking instructions in relation to your estate. This means that we will continue to manage your Account in accordance with any instructions you have given us so far. We also reserve the right to exercise our absolute discretion to make payments to HMRC to help you deal with inheritance tax. Otherwise, we will only accept further instructions once we have been presented with a valid grant of probate or representation.
    • The Charges applicable to your FINT Investment are set out in Schedule 2.
    • Our Charges will be paid by the platform provider (this is where your Investments are held), who will deduct our fees from your Portfolio Assets. We will review the amount in the cash account in your Portfolio on an ongoing basis. If there is insufficient available Cash to pay our Charges, they will realise Investments to settle our Charges. Assets within your Portfolio will be disinvested proportionally and transferred to your platform cash account to cover the outstanding Charges.
    • If a third party imposes any additional charge or cost as a result of your default in complying with your obligations under this Agreement or with any reasonable request by us pursuant to this Agreement, then any such charge or costs shall be borne by you and deducted from your Portfolio. Note that other related costs including taxes may arise that are not paid via FINT nor imposed by it.
    • Cancellation or cooling off rights do not apply to the discretionary management service. This means that once you have entered into this Agreement, you will not have any time frame in which to change your mind. You are of course able to cancel this Agreement in line with the termination clause below at any time.
    • Termination of this Agreement by us. We may terminate this Agreement by giving you at least 20 Business Days written notice.
    • Termination of this Agreement by you. You may terminate this Agreement at any time, without penalty. Notice of this termination must be given in writing (may be by email or by clicking on the settings screen and close account button in FINT) and will take effect from the date of receipt. Termination is without prejudice to any transactions already initiated which will be completed according to this Agreement, unless, otherwise we agree in writing.
    • Responsibilities on termination. You will be liable to pay for any services provided prior to termination and any Charges outstanding, if applicable. Termination will not affect accrued rights, existing commitments or any contractual provision intended to survive termination of the Agreement. You agree on termination to pay:
      • Our Charges pro rata to the date of termination; and
      • Any additional expenses necessarily incurred by us in cancelling the Agreement and any losses necessarily realised in settling or concluding outstanding obligations and transferring your assets to a new Custodian.
    • On termination, we may retain and/or realise any of your assets as may be required to settle the transactions already initiated, and to pay any outstanding liabilities of yours.
    • If you will no longer be a UK  resident, you must inform us promptly prior to your move away, as  there  may be certain  restrictions  placed  on your Account and our ability to  continue with the  Where required  by any Applicable  Law, we may restrict any further Investment and/or we may also  sell your holding  in the  Portfolios and close your Investments.
    • We are currently unable to offer Services to  US passport holders or nationals of any country listed  in the  United  States Department of Treasury’s Office of Foreign  Assets  Control website at

Our Financial Services Register number is 620330. Our permitted business includes advising on and managing Investments. You can check this on the Financial Services Register by visiting the FCA’s website or by contacting the FCA on 0800 111 6768. We will be treating you as a retail client. This means that you are afforded the highest level of protection under the regulatory system and you should have the right to take any complaint to the Financial Ombudsman Service.

    • You will be legally bound by this Agreement so it is important now and on a continuing basis that you agree that you have and will maintain full legal capacity and all necessary authority, permissions and powers, and have taken all necessary action to enable you:
      • to enter into this Agreement lawfully;
      • to give us orders and instructions;
      • to enter into any transactions; and
      • to grant any security interests, rights and powers referred to in this Agreement.
    • You shall:
      • co-operate with us in good faith and promptly in all matters relating to the Services;
      • provide us with such information and materials  as we may reasonably require in order to  supply the Services and ensure that such information and materials are true and accurate;
      • regularly log on to your Account  to review your Investments  as  well as  any communication or documentation that may be added to your Document Library from time to time; and
      • notify us promptly of any changes to your circumstances or information you provided e.g. your residency, financial circumstances, Investment objectives, or attitude to risk.
    • In accepting this Agreement, you confirm there is no action, suit or proceeding, or pending or threatened action, suit or proceeding, before any court, tribunal, governmental body, agency or official, or any arbitrator that purports to affect or is likely to affect, the legality, validity or enforceability against you of this Agreement or ability to perform your obligations under this Agreement.
    • You acknowledge that any transaction dealt with by us on your instructions will be assessed by statutory and other requirements relating to money laundering and combating terrorist financing.
    • We are legally obliged to keep your affairs    However, we may be required by Applicable  Law  to  make a disclosure to the National Crime Agency where we know or suspect that a  transaction may involve money laundering or terrorist financing.  If we make a disclosure in relation to this  matter, we may not  be able to tell you that a  disclosure has been made. We may have to stop providing  Services  to you for a  period of time  and may not  be able  to tell you why. We shall not be liable in any way whatsoever for any loss or damage (including any costs, expenses or liabilities) of any kind incurred by you as a result of having to make such a disclosure or having to stop  providing Services to  you for such  period of time.
    • You are wholly responsible for the accuracy of any information that you provide to us and we shall not be liable in any way whatsoever should incorrect data received from you result in financial loss or damage (including any costs, expenses or liabilities) of any kind. You will notify us immediately if you discover that any information we hold for you is obsolete, incorrect, misleading, inconsistent and/or  irrelevant  in any way.
    • If our performance  of any of our obligations  under this Agreement  is prevented  or delayed  by any act or omission by your failure to perform any relevant obligation  under this Agreement (“Customer Default”), we can shall without limiting  our  other  rights  or remedies  have the  right to suspend  performance of the  Services  until you  remedy the  Customer  Default, and to rely  on the  Customer  Default to  relieve us from the  performance of any of our  obligations  to the  extent the  Customer  Default  prevents  or delays our  performance  of any of our obligations.
    • In the event of a Customer Default, we shall not be liable for any costs or losses sustained or incurred by you arising directly or indirectly from our failure or delay to perform any of our obligations under this Agreement.
    • You will indemnify us in respect of (that is, you will be responsible for) any liability, cost, expense, loss  or any damage incurred by  us (including  but  not limited  to  professional advisors’ fees)  arising  from  your  breach of this Agreement,  your negligence, your wilful default or any fraud  or fraudulent  misrepresentation made by you or on your behalf.
    • If you no longer wish to use our Services, you will no longer be able to access the arrangements we have in place for safekeeping and custody and administration. Therefore, you would need to close your Account. The only exceptions to this are in the event of the Account holder’s death where funds will be held pending probate and withdrawal by the executor or your personal representatives.
    • Please note that by agreeing to this Agreement:
      • you acknowledge receipt of this Agreement and that this Agreement apply to Investments you make with us;
      • you acknowledge that you have read this Agreement carefully; and
    • you authorise the transfer of information, on a confidential basis, as required under this Agreement between third parties. Further details of how we use and process your data are set out in our privacy policy
    • As a Customer you will be given access to view your Account online. This can be accessed with your email address and your password. For security reasons these are sent to you by email to the email address provided by you. It is your responsibility to keep all your Account details including your password safe and secure and ensure they cannot be accessed by others.
    • We will take all reasonable steps to ensure your Account can be viewed via the FINT App at any time. There will however be times when we need to interrupt our online service to perform maintenance.
    • Your Account will allow you to view details of your Portfolios, where your money is invested and the value of your Investments. It also has an online Document Library that allows you to view Account literature.
    • The value of Investments that appear on your Account are not real time. There is typically one (1) Business Day delay due to mutual funds updating their prices. Whilst we try to ensure the complete accuracy of the values, there may at times be circumstances outside our control that means the number is not accurate.
    • Any Instructions to change personal details or contact details on your Account may be made by you. It is important that you maintain the email address we have for you to ensure that any important communications or alerts are received. You should also make sure that your email settings are set up to receive emails from us.
    • If you open multiple Portfolios, you will automatically be able to view all the details and documents for the new Portfolios under the same Account.
    • You must tell us immediately if you do not recognise any transaction within your Account. Please use the contact screen in FINT or email
    • In addition to your termination rights as set out in Section 6, we or the Custodian shall be entitled to close your Account for the following reasons:
      • if you have not given us any documents, we need to meet our regulatory or legal responsibilities;
      • if you have failed to provide us with satisfactory evidence or documentation for us to complete our anti money laundering verification process;
      • if we believe, acting reasonably that any information or declaration you have given to us when opening an Account or subsequently, is untrue, misleading, or incomplete in any material way, or if you fail to inform us of any information you later become aware of which makes any previous information untrue, misleading or incomplete;
      • under the terms of a court order;
      • if you have lent, deposited as collateral or used as security one or more Assets in your Accounts or have tried to do so without our consent; or
      • if you have done or failed to do something which  means we are unable  to  comply  with our legal and/or regulatory obligations under Applicable Law.
    • We will let you know in writing the date on which we will be closing  your Portfolios  or Account.
    • We will not be legally responsible for any remuneration,  costs,  charges,  fees,  expenses,  taxes  or other  amounts  which become payable  by closing  your Portfolios or Account.
    • We make decisions to deal on your behalf in relation to your Investments, and we assess the suitability of the transactions based on the information you have provided us about your knowledge and experience of investing, your financial situation and objectives which you have given us by completing the questionnaire screens in FINT. As part of the process for setting  up your Account with  us, we will ask you a  number of questions. The answers you provide to those questions will allow us to  assess whether we are able to  offer you a suitable Portfolio and if so, which Portfolio is suitable for you.
    • Suitability to invest is based on your financial situation and ability to  bear any losses, your objectives  and attitude to  risk and whether you have  the  knowledge  and experience to  understand  the  risks  involved  with the  management of your Portfolio.
    • The decision whether to allow you to open an Account  is  entirely  ours  and we may decide for any reason,  or no reason, not to authorise you. We may, at our discretion, permit you to answer the questions again at a future date, but we are under no obligation to  do so.
    • If we are unable to offer you a suitable Portfolio  based on your responses to the  assessment noted  in clause 11.1, we may not offer you one.
    • We will not be liable to  you for any losses,  damages or costs  arising from  our decision not to  open an Account  or not to permit you to  answer the  questions again.
    • You should notify us promptly of any material change in your Investment objectives, attitude to risk, any individual financial or personal  circumstances  or knowledge and experience in financial services.  Such changes  are important  and may affect the Services we provide to you. Failure to provide up to date  information  may impact on our ability to  provide the  Services to  correspond with  your needs. We will ask you to update this  information  from time to time and it is your responsibility to do so.
    • The impact of events and circumstances outside our control,  including but  not  limited  to the  ongoing movements in the  markets and fluctuations  in the value  of Investments, will not automatically  be or be deemed to  be a  breach of any Investment  objectives  or your risk profile.  Our Portfolios are managed on a fully discretionary  basis to  match  defined  risk profiles. This service enables us to make Investment decisions on your behalf without needing to obtain your approval for those transactions. You will see on your Account page in FINT the changes that are
    • We offer discretionary  Investment  management  and  our  Investments  may cover  all  world  markets  without geographical spread or type  of Investment  being restricted.
    • You are required to  accept the  risk profile  and characteristics  of the Portfolio selection. Where additional Investment  is  made into  a Portfolio it will be invested  and managed in accordance with the  risk profile
    • We will not accept specific instructions relating  to  individual Investments within the
    • When funds have arrived, they will typically be invested within five (5) Business Days. There may be occasions when it will take longer than this.
    • If you are dissatisfied with any aspect of our Services you are entitled to make a complaint. We have a complaints procedure that is available on request (and can be found If you wish to register a complaint, please contact us:
      • In writing: Alaric Gordon, lronmarket Ltd, Unit 10 Brindley Court, Dalewood Road, Lymedale Business, Park, Newcastle-under-Lyme, ST5 9QA
      • By phone: 01782 461563
      • By e-mail:
    • Please be assured we treat complaints seriously. For your further protection, if you cannot settle your complaint with us, you may be entitled to refer it to the Financial  Ombudsman Service.  Full details can be found on its website at
    • Financial Services Compensation Scheme: We are also covered by the Financial Services Compensation Scheme . You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim. Further information about compensation scheme arrangements is available at
    • Client money:
      • We are not permitted to handle client money and we cannot accept a cheque made out to us (unless it is in respect of a service for which we have sent you an invoice) or handle cash. We will only handle your money via the FINT platform.
      • We will not be liable for any loss or damage of any kind that is attributable to:
        • our failure to take any action which, in our opinion, might breach an applicable FCA Rule or any other Applicable Law, or any action taken in order to comply with Applicable Law or the requirements of any market;
        • any fall in the value of Investments (including, without  limitation, those which may occur due to delays  during the process of verifying your identity in compliance with money laundering regulations);
        • any reasonable refusal or failure to accept and/ or execute any Investment on your behalf; or
        • our reasonable reliance on any information, instructions, notices or communications that we believe to be from you and/or a person authorised by you to give the same, including any person authorised to give instructions in respect of your Portfolio.
      • We will take reasonable care in the assessment and appointment of Custodians, bankers, counterparties, agents and other third Subject to the performance of that duty we will not be liable for any losses, damages or costs suffered or incurred by you that is attributable to the performance of any third party involved in the provision of the Services including but not limited to services provided by the Custodian.
      • We will not be responsible for any liabilities arising because of any circumstance outside of our reasonable control.
      • FORCE MAJEURE. We shall not be in breach of this Agreement if there is, and shall not be liable or have responsibility of any kind for any loss or damage incurred by you as a result of, any total or partial failure, interruption or delay in performance of our duties and obligations occasioned by any act of God, fire, act of government, state, governmental or supranational body or regulatory authority or war, civil commotion, terrorism, failure of any computer dealing system, interruptions of power supplies, labour disputes of whatever nature or any other reason (whether or not similar in kind to any of the above) beyond our reasonable control.
      • THIRD PARTIES. A person who is not a party to this Agreement will not have any benefits under the Contracts  (Rights  of Third Parties) Act1999 and will not  have any rights to  enforce its terms.
        • We will send all notices, information and other correspondence to you via the email address you have provided us with when you set up your account. You agree as an ongoing obligation to provide us with an up to date  email address and to  inform  us as soon  as  reasonably  practicable  if this  should  We are entitled to rely on the  last  email address you have provided, and an email sent to  that  email address  by us  shall  be good service under this Agreement.
        • We cannot guarantee that general emails will be successfully delivered, or that they will be secure and virus free. We will not be liable for any loss, damage, expense, harm or inconvenience caused as a  result of an email being  lost, delayed, intercepted, corrupted  or otherwise  altered, or for failing  to  be delivered for any reason beyond our reasonable
        • If we choose to correspond by post,  communications  will be sent  to  the  address you provided when  you set  up your Account. Alternatively, we may communicate with you when appropriate by telephone.
        • You can give us Instructions and notifications in relation to Investments we hold on your behalf via
        • We will not be obliged to act on any Instruction  and, in particular, we will not act on any Instruction  where it  is  illegal or against any relevant rule or regulation to  do so. Where we do act on your Instructions we will do so as soon as reasonably practicable once we have received them.
        • Where Instructions given orally or by electronic communication are directed at a specific person and that person is not present to  receive them, there  may be a delay  in acting  on such Instructions  until actual receipt  by such person.
        • We may act on any Instruction or other  notification  which we believe  in good faith  is from you without  carrying out any further checks  or investigations. We will not be liable for following  an Instruction  or notification  which  is  not in fact genuine, or for not following, or for investigating  further any instruction  or notification  we believe  may not  be genuine.
        • We will not be liable for any error of transmission or misunderstanding, or for the  fraud of any other  party (except  in the case of our negligence, wilful default or fraud).
        • We are not obliged to acknowledge receipt of your Instructions.
      • SECURITY
        • Your access to the online portal and messages will be protected via the username and password you created as part of the  onboarding  Your username and password are personal to you and you must not  share your username or password with  anyone else.
        • We shall not be liable to you for any losses, damages or costs suffered as a result of you sharing your username or password with a third party. You must notify us immediately if you learn or suspect  that  the  security  of your username or password may have been breached.  If we receive such a notification from you or determine ourselves that the security of your username or password may have been breached, you will not be able to access messages or the online portal until measures have been taken to verify your identity.

It is important that we have your clear instructions regarding signatories to the Account. We shall honour and act on any Instruction, confirmation, or authorisation in writing signed, authenticated or sent or purported  to be signed, authenticated or sent by you believed by us to be genuine and so that we shall not be liable for acting in good faith  upon any such instruction, confirmation  or authority notwithstanding that it shall subsequently  be shown that the same was not given or signed, authenticated or sent by you.

    • We will obtain, process, store and use your personal data  in accordance with  and subject to  Data  Protection
    • Our Privacy Notice available at explains how we collect, use, disclose, transfer and store your data.
    • You agree that, at any time and in order to comply with Applicable Law, we may send your information to credit reference and or fraud prevention or similar  agencies that  help  us  and others  make credit  decisions,  and which  carry out  identity, fraud prevention or credit control checks to  help  reduce the  incidence of fraud or financial crime.  We will be supplied with credit information (although we do not offer  lines of credit) as well as information from the  electoral register. The agency will record the details of the  search, irrespective  of whether we accept your application.
    • We may use automated credit scoring methods to assess your application  and verify your identity.


  • Terms and Definitions
Account means your FINT account made up of your personal data, your Portfolios and any web messages and emails.
Agreement means the contract between Ironmarket and the Customer in accordance with this Agreement.
Applicable Law means, as applicable to the  provision  of the  Services described in this Agreement, all laws, rules  (including the  FCA Rules and any default  rules  of any market or central counterparty or any default arrangements of any system, including any order routing system, or any trading rules or conventions in the relevant markets),  regulations,  directives,  customs,  practices,  decisions  and usages  of any  relevant  exchange,  market,  multi-lateral trading  facility,  central  securities  depository and/or  clearing  house or  system  and/or  central  counterparty,  if any,  and  all  applicable  procedures, guidance, codes of conduct of any market or governmental or regulatory authority or any self-regulatory organisation,  including   without   limitation,  any   accounting   rules,  fiscal   regulations,  anti-money laundering, terrorist financing  and sanctions  laws, rules, procedures, guidance an regulations, all as may be amended, supplemented  or replaced from time to time.
Assets means the assets in a Portfolio, ETFs and cash.
Available Cash means any Cash that is  not  currently  invested  in Assets  or identified  as  Committed  Cash, and may be used to invest  in Assets, pay Charges or fund  withdrawals. Available Cash is sourced  from contributions made, the sale of Assets,  Investment income or interest received.
Business Days means   a day (other than a  Saturday, Sunday or  public  holiday) when  banks  in  London  are open for business.
Cash means both Available Cash and Committed Cash.
Cash Transfer means the process of moving money to or from an Account as a Cash value and not a movement of Assets.
Charges means the charges fees and charges noted in Schedule 2.
Charges Information Documentation means the document which can be found in your Document Library, and which details the Charges applied to your Account agreed between you and us, as may be amended from time to time.
Committed Cash means any Cash that a)  has  been ring-fenced  to  complete  a  Trade Instruction  that  has not  reached the contractual settlement date, b) is required to complete a Voluntary Corporate Action, c) is from a payment source that  has not cleared, for example a  cheque or d) is cash  held within  a  Model Portfolio.  It cannot be used to invest  in Assets, pay Charges  or fund withdrawals.
Corporate Action means any event that affects the share capital, or unit  capital,  or holding  structure  of  Investments  and will be either a Voluntary Corporate Action  or a  Mandatory Corporate Action  as determined  by us.
Custodian means   a custodial financial institution regulated  by the  FCA  or comparable  regulatory authority that holds Customer Assets  and Cash for safekeeping  to  minimise the  risk of their loss to  you. This can be in either electronic or physical form.
Data Protection Legislation means all applicable data protection and privacy legislation in force from time to time in the UK including the General Data Protection Regulation ((EU)  2016/679); the Data Protection Act 2018; the Privacy and Electronic Communications  Directive 2002/58/EC (as updated  by Directive  2009/136/EC) and the  Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as may be amended, supplemented or replaced  from time  to  time  and all other  legislation  and regulatory  requirements  in force from time  to time which apply to a  party relating to the use of personal data  (including, without limitation, the privacy of electronic communications).
Document Library means a secure area in your online   Account   where   you   can  access   certain   documents and communications, we may send to you.
ETFs means shares or bonds in a company, government  bonds,  Investment trusts  and exchange Traded funds which are bought and sold  on a  regulated market.
FCA means the Financial Conduct Authority.
FCA Rules means the conduct rules contained within the FCA Handbook as may be amended, supplemented or replaced from time to time.
Financial Services Compensation Scheme means  the  Financial Services  Compensation  Scheme  is  an independent  body, established  under the Financial Services  and Markets Act  2000 as  the  UK’s  statutory compensation  fund  of last resort, for customers  of financial services  firms authorised  by the  FCA.
Instructions means all instructions received from you, relating to an Account that are not Trade Instructions.
Investment means an Asset or Cash held or to be held in your Account (Invested shall be construed accordingly).
Mandatory Corporate Action means  an event which is not a Voluntary Corporate Action which is initiated  in respect of a  company or manager of a  fund that affects all shareholders or unitholders and requires an action  by those shareholders or unitholders to be taken.


Model Portfolio means a selected group of Investments that are managed by us to achieve a specific financial goal or objective.
Portfolio means your portfolio of Investments.
Services means the investment management services supplied by us to you pursuant to this Agreement and as more particularly set out in Section 4 of this Agreement.
Schedules means the schedules that form part of this Agreement and have effect as if set out in full in its body.


Terms mean this Agreement and conditions as amended from time to time in accordance with Section 3 of this Agreement.
Trade Instruction means an instruction received from you to buy or sell  Investments  relating  to your Account.
Trusted Third Party means   a third  party with whom  a  Custodian  has entered  into an Agreement (which,  if applicable, complies  with  FCA outsourcing  rules)  for the  provision of services  or information  from that third  party to us or us to that third  party or to  clients,  either together or individually.
Voluntary Corporate Action means  an event initiated  by the board of directors of a  company or manager of a  fund that affects all shareholders or unitholders and requires an action  by those shareholders or unitholders to be taken, and where we have decided to notify you of such an event.
Web Message means an email on FINT’s internal messaging system.


  • Fees and Charges

We’ve provided details of the Charges for managing your Portfolio and Product or Services on a discretionary basis as well as all the other charges likely to be applied.

Management fees     1% of Portfolio value annually   – calculated daily, paid monthly.


CHAPs charges £25.00


  • Ironmarket charges an annual management fee which includes the costs of running FINT (Fee). Our Fee is a percentage of the money you have Invested with us. It includes all costs associated with the daily maintenance and management of your Portfolio(s) and includes value added tax where applicable.
  • Investment costs will also apply, which include fund charges, taken directly  from the  fund  provider,  and market  spread, which  is the  difference  between the  price we buy and sell
  • Whilst we quote the Fee as ‘annual’ it is taken monthly in arrears.
  • We will deduct the Fee directly from the sums held in your Portfolio(s), so you do not have to set up a monthly payment to us. Fees will be debited on or before the 28″ day of each month and will be clearly marked on your statements.
  • You will only be charged Fees on the money value of your Portfolio, so if (for example) you added funds  halfway through  the  month, you would only  be charged for the time  it was Invested  with  us during that month. If, which we do not expect, our Portfolios do face losses in a given month, our Fee would reduce accordingly.
  • The value of your  Portfolios is the  combined value  of all the Portfolios you hold on FINT (but not any other Investment you may hold with Ironmarket, if you are also separately a client of Ironmarket in any capacity), and is calculated by reference to the value of the Portfolio(s) on the day before payment is taken.
  • Risks and Investments

This section gives an overview of the main risks associated with your Investment. To help you, it goes first into some detail about how you may approach risk. It then goes into more specific detail as to the specific risks relating to Investments more generally, all of which apply to the ETFs making up your Portfolios, and then to an explanation and some more specific risk explanations in relation to ETFs.

This section cannot disclose all the risks associated with the Portfolios. You should not invest in or deal in any financial product unless you understand its nature and the extent of your exposure to risk. You should also be satisfied that it is suitable for you in the light of your circumstances and financial position.


All Investments involve a degree of risk of some kind. This section describes some of the risks which are relevant to the Services we provide to you. We may provide further risk information during the course of our Services to you, as appropriate.

The Portfolios invest in ETFs, whose prices are dependent on fluctuations in the financial markets which are outside our control. Investments and the income from them may go down as well as up and you may get back less than the amount you Invested. Past performance is not a guide to future performance.

Risk: What It Means

Risk in financial terms is the chance or probability that an outcome and/or investment’s actual gains will differ from an expected outcome or return. Risk includes the possibility of losing some or all of an original investment. Quantifiably, risk is usually assessed by considering historical behaviours and outcomes but, of course, the past cannot change or albeit predict the future.

Overall, it is possible and prudent to manage investment risk by understanding the basics of risk and how it is measured. Learning the risks that can apply to different scenarios and some of the ways to manage them will help all types of investors to avoid losses.

Everyone is exposed to some type of risk every day—whether from driving, walking down the road, investing, capital planning, or something else. An investor’s personality, lifestyle and age are some of the key factors to consider for individual investment management and risk purposes. Each investor has a unique risk profile that determines their willingness and ability to withstand risk. In general, as investment risks rise, investors should rationally expect higher returns to compensate for taking those risks.

A fundamental idea in finance is the relationship between risk and return. The greater the amount of risk an investor is willing to take, the greater the potential return should be. Risks can come in various ways and investors need to be compensated for taking on additional risk. For example, a Government bond is considered one of the safest investments and when compared to a corporate bond, provides a lower rate of return. A company is much more likely to go bankrupt than the Government, and because the default risk of investing in a corporate bond is higher, investors are offered a higher rate of return by corporate bonds.

Time horizon and the liquidity of investments is often a key factor influencing risk assessment and risk management. If an investor needs funds to be immediately accessible, they are less likely to invest in high risk investments or investments that cannot be immediately liquidated and more likely to place their money in riskless securities, which are almost certain to have lower yields.

Time horizons will also be an important factor for individual investment portfolios. Younger investors with longer time horizons to retirement may be willing to invest in higher risk investments with higher potential returns. Older investors would have a different risk tolerance since they will need funds to be more readily available.

Types of Financial Risk

Every saving and investment action involves different risks and returns. In general, financial theory classifies investment risks affecting asset values into two categories: systematic risk and unsystematic risk. Broadly speaking, investors are exposed to both systematic and unsystematic risks.

Systematic risks, also known as market risks, are risks that can affect an entire economic market overall or a large percentage of the total market. Market risk is the risk of losing investments due to factors, such as political risk and macroeconomic risk, that affect the performance of the overall market. Market risk cannot be easily mitigated through portfolio diversification. Other common types of systematic risk can include interest rate risk, inflation risk, currency risk, liquidity risk, country risk, and sociopolitical risk.

Unsystematic risk, also known as specific risk or idiosyncratic risk, is a category of risk that only affects an industry or a particular company. Unsystematic risk is the risk of losing an investment due to company or industry-specific hazards. Examples include a change in management, a product recall, a regulatory change that could drive down company sales, or a new competitor in the marketplace with the potential to take away market share from a company. Investors often use diversification (that is, investing in lots of different things) to manage unsystematic risk by investing in a variety of assets not all of which would be impacted by any given change.

In addition to the broad systematic and unsystematic risks, there are several specific types of risk, including:

  1. Business Risk

Business risk refers to the basic viability of a business—the question of whether a company which is invested in will be able to make sufficient sales and generate sufficient revenues to cover its operational expenses and turn a profit to repay its investors. While financial risk is concerned with the costs of financing, business risk is concerned with all the other expenses a business must cover to remain operational and functioning. These expenses include salaries, production costs, facility rent, office, and administrative expenses. The level of a company’s business risk is influenced by factors such as the cost of goods, profit margins, competition, and the overall level of demand for the products or services that it sells.

Operational risk is a type of business risk that arises from the day-to-day operation of a business and can include risks associated with system failures, human errors, fraud, or other internal processes that might negatively impact a business’s financial performance. Operational risks can be managed through effective internal controls, processes, and systems.

Businesses and investments can also be exposed to legal risks stemming from changes in laws, regulations, or legal disputes. Legal and regulatory risks can be managed through compliance programs, monitoring changes in regulations, and seeking legal advice as needed.

  1. Credit or Default Risk

Credit or default risk is the risk that a borrower will be unable to pay the contractual interest or principal on its debt obligations. This type of risk is particularly concerning to investors who hold bonds in their portfolios. Government bonds usually have the least amount of default risk and, as such, the lowest returns. Corporate bonds, on the other hand, tend to have a higher amount of default risk, but also higher interest rates.

Bonds with a lower chance of default may be considered ‘’investment’ grade, while bonds with higher chances of default may be considered high yield or even ‘junk’ bonds. Investors can use  bond rating agencies—such as Standard and Poor’s, Fitch and Moody’s—to determine which bonds are investment-grade and which are not.

  1. Country Risk

Country risk refers to the risk that a country won’t be able to honour its financial commitments. When a country defaults on its obligations, it can harm the performance of all other financial instruments in that country—as well as other countries it has relations with. Country risk applies to stocks, bonds, mutual funds, options, and futures that are issued within a particular country. This type of risk is most often seen in emerging markets or countries that have a severe deficit.

  1. Foreign-Exchange Risk

When investing in foreign countries, it’s important to consider the fact that currency exchange rates can change the price of the asset as well. Foreign exchange risk (or exchange rate risk) applies to all financial instruments that are in a currency other than your domestic currency.

As an example, if you live in the UK and invest in a US stock in US dollars, even if the share value appreciates, you may lose money if the US dollar depreciates in relation to the sterling pound.

  1. Interest Rate Risk

Investment rate risk is the risk that an investment’s value will change due to a change in the absolute level of interest rates, the spread between two rates or in any other interest rate relationship. This type of risk affects the value of bonds more directly than stocks and is a significant risk to all bondholders and, by extension, funds that invest in bonds. As interest rates rise, bond prices in the secondary market fall because the bonds pay interest which is worth less, as rates rise, relative to less costly investments or holding cash in a savings account — and vice versa.

Reinvestment risk is related to interest rate risk. It is the possibility that an investor may not be able to reinvest the cash flows received from an investment (such as interest or dividends) at the same rate of return as the original Investment. Reinvestment risk is particularly relevant for fixed income Investments like bonds, where interest rates may change over time. Investors can manage reinvestment risk by diversifying their portfolio, or considering investments with different maturity dates.

  1. Political Risk

Political risk is the risk an investment’s returns could suffer because of political instability or changes in a country. This type of risk can stem from a change in government, legislative bodies, other foreign policy makers, or military control. Also known as geopolitical risk, the risk becomes more of a factor as an investment’s time horizon gets longer.

  1. Counterparty Risk

Counterparty risk is the likelihood or probability that one of those involved in a transaction might default on its contractual obligation to pay for an asset bought by it. Counterparty risk can exist in credit, investment, and trading transactions, especially for those occurring in over-the-counter markets. Financial Investment products such as stocks, options, bonds, and derivatives carry counterparty risk.

  1. Liquidity Risk

Liquidity risk is associated with an investor’s ability to sell their investment for cash. Typically, investors will require some premium for illiquid assets (those which cannot easily be sold) which compensates them for holding those assets that cannot be easily liquidated.


  1. Model Risk

This type of risk arises from the use of financial models to make Investment decisions, evaluate risks, or price financial instruments. Modelling risk can occur if the model is based on incorrect assumptions, data, or methodologies, leading to inaccurate predictions and potentially adverse financial consequences. Modelling risk can be managed by validating and periodically reviewing financial models, as well as using multiple models to cross-check predictions and outcomes.

Risk vs. Reward

The risk-return tradeoff is a balance between the desire for the lowest possible risk and the highest possible returns. In general, low levels of risk are associated with low potential returns and high levels of risk are associated with high potential returns. Each investor must decide how much risk they’re willing and able to accept for a desired return. This will be based on factors such as age, income, investment goals, liquidity needs, time horizon, and personality.

Risk and Diversification

The most basic and effective strategy for minimizing risk is diversification. Diversification is based heavily on the concepts of correlation and risk. A well-diversified portfolio will consist of different types of investments from diverse industries or asset classes that have varying degrees of risk and correlation with each other’s returns.


ETFs are investment funds, traded like shares, which hold assets such as shares, commodities or bonds. They often closely track the performance of a financial index, and as such, their value can go down as well as up and you may get back less than you originally invested.

Currency risk

Investments denominated in a currency other than sterling or ones that undertake transactions on foreign markets, which include the financial markets of developing countries (Emerging Markets), may expose you to greater risks caused by fluctuations in foreign exchange rates. This can adversely affect the value of your return and the value of your investment. Investments in Emerging Markets are exposed to additional risks, including accelerated inflation, exchange rate fluctuations, adverse repatriation laws and fiscal measures, and macroeconomic and political factors.

Investment manager risks

This is the risk of loss from the poor performance of the fund managers managing the ETFs in your portfolio as well as by us in the management of your Portfolio.

Suspensions of trading

Under certain trading conditions it may be difficult or impossible to liquidate a position. This may occur, for example, at times of rapid price movement if the price rises or falls in one trading session to such an extent that under the rules of the relevant exchange trading is suspended or restricted.

Exchange or clearing house protections

On many exchanges, the settlement of a transaction is ‘guaranteed’ by the exchange or clearing house. However, this guarantee may not protect you if your investment manager or another party defaults on its obligations to the exchange.


Your investment manager’s insolvency or default, or that of any other brokers involved with your transaction, may lead to positions being liquidated or closed out without your consent. In certain circumstances, you may not get back the actual assets which you lodged as collateral and you may have to accept any available payments in cash.

  • What is an Exchange-Traded Fund?

What is an ETF?

An ETF is called an exchange-traded fund because it is traded on an exchange, just like stocks and shares are. ETF is actually a form of pooled investment security that operates much like a mutual fund, pooling investors’ money to invest in underlying assets. Typically, ETFs will track a particular index, sector, commodity, or other assets, but unlike mutual funds, ETFs can be purchased or sold on a stock exchange the same way that a regular stock can. An ETF can be structured to track anything from the price of an individual commodity to a large and diverse collection of securities. ETFs can even be structured to track specific Investment strategies. ETFs do this by either requiring a basket of units in stocks which represent and thus track the desired index, sector, commodity or other assets, or entering into contacts which achieve the same result. As an example, the first ETF was the SPDR S&P 500 ETF (NYSE: SPY), which tracks the S&P 500 Index, and which remains an actively traded ETF today.

ETF share prices fluctuate all day as the ETF is bought and sold.

ETFs can contain all types of Investments, including stocks, commodities, or bonds; some offer U.S.-only holdings, while others are international.

ETFs offer low expense ratios and fewer broker commissions than buying the stocks individually and are thus a low-cost way to develop a diversified strategy for Investment.

Understanding ETFs

An ETF usually holds multiple underlying assets, rather than only one (like a stock does). Because there are multiple assets within an ETF, they can be a popular choice for diversification. ETFs can thus contain many types of investments, including stocks, commodities, bonds, or a mixture of investment types.

Various types of ETFs are available to investors that can be used for income generation, speculation, and price increases, and to hedge or partly offset risk in an investor’s portfolio. Here is a brief description of some of the ETFs available on the market today.

ETFs are generally characterized as either passive or actively managed. Passive ETFs aim to replicate the performance of a broader index—either a diversified index such as the FTSE 100 or a more specific targeted sector or trend.

Actively managed ETFs typically do not target an index of securities, but rather have portfolio managers making decisions about which securities to include in the portfolio. These funds have benefits over passive ETFs but tend to be more expensive to investors. The FINT offering will generally invest into passive ETFs.

Bond ETFs

Bond ETFs are used to provide regular income to investors. Their income distribution depends on the performance of underlying bonds. They might include government bonds, corporate bonds, and state and local bonds—called municipal bonds. Unlike their underlying instruments, bond ETFs do not have a maturity date. They generally trade at a premium or discount from the actual bond price.

Stock ETFs

Stock (equity) ETFs comprise a basket of stocks to track a single industry or sector. For example, a stock ETF might track automotive or foreign stocks. The aim is to provide diversified exposure to a single industry, one that includes high performers and new entrants with potential for growth. Unlike stock mutual funds, stock ETFs have lower fees and do not involve actual ownership of securities.

Industry/Sector ETFs

Industry or sector ETFs are funds that focus on a specific sector or industry. For example, an energy sector ETF will include companies operating in that sector. The idea behind industry ETFs is to gain exposure to the upside of that industry by tracking the performance of companies operating in that sector.

One example is the technology sector, which has witnessed an influx of funds in recent years. At the same time, the downside of volatile stock performance is also curtailed in an ETF because they do not involve direct ownership of securities. Industry ETFs are also used to rotate in and out of sectors during economic cycles.

Commodity ETFs

As their name indicates, commodity ETFs invest in commodities, including crude oil or gold. Commodity ETFs provide several benefits. First, they diversify a portfolio, making it easier to hedge downturns.

For example, commodity ETFs can provide a cushion during a slump in the stock market. Second, holding shares in a commodity ETF is cheaper than physical possession of the commodity. This is because the former does not involve insurance and storage costs.

Currency ETFs

Currency ETFs are pooled Investment vehicles that track the performance of currency pairs, consisting of domestic and foreign currencies. Currency ETFs serve multiple purposes. They can be used to speculate on the prices of currencies based on political and economic developments for a country. They are also used to diversify a portfolio or as a hedge against volatility in forex markets by importers and exporters. Some of them are also used to hedge against the threat of inflation. There’s even an ETF option for bitcoin.

Leveraged ETFs

A leveraged ETF seeks to return some multiples (e.g., 2× or 3×) on the return of the underlying Investments. For instance, if the FTSE 100 rises 1%, a 2× leveraged FTSE 100 ETF will return 2% (and if the index falls by 1%, the ETF would lose 2%). These products use derivatives such as options or futures contracts to leverage their returns. There are also leveraged inverse ETFs, which seek an inverse multiplied return. FINT does not use leveraged ETFs.

Appendix 1 – Best Execution Policy Summary

  • Overview
    • It is in the interests of our clients and us that we obtain the best possible result when placing orders with other firms e.g. third-party brokers and fund managers for the execution of client orders or when transmitting orders on behalf of clients. We are required to take all reasonable steps to provide the best execution when carrying out such transactions and, on your request, to provide you with a copy of the policy that we have adopted to achieve that objective.
    • This best execution policy applies to orders in financial instruments such as funds and other securities and includes our use of ETFs.
  • Execution factors
    • When placing orders with other firms for the execution of orders or when transmitting orders, we will make every effort to ensure the best possible result for our clients taking into account the following factors:
      • price;
      • cost;
      • speed;
      • likelihood of execution and settlement;
      • size;
      • nature of the order; and
      • any other relevant consideration.
    • For retail clients, the price and cost of execution of the order will normally be the most important aspect in obtaining the best possible result. We will, therefore, assume this is the most important outcome for your transaction unless you tell us otherwise.
  • Executing your order
    • In arranging for the execution  of your order:
      • we may use a third-party broker or platform to execute your order; and
      • we may trade as an agent {where our scope of regulatory permissions allows us to do so).
    • Execution venues
      • All orders placed by us on FINT are executed through the Custodian.
      • We will regularly assess the venues/third parties available to us to identify those that will enable us, on a consistent basis, to obtain the best possible result when arranging the execution of your orders. The list will then be updated, where necessary, following such an assessment.
      • The third parties have responsibilities in relation to best execution and client order handling themselves. We will also undertake periodic monitoring to ensure that they are meeting the relevant requirements.
    • Client-specific Instructions
      • If you have given Instructions that price is not the most important factor in executing your Instructions, we will make every effort to comply with your Instructions but cannot guarantee this. This may be due to either the nature of the order or the type of financial instrument you wish to trade in.
      • We will normally make all decisions as to where the orders are placed in relation to the execution venue.
      • We may, in some circumstances, accept any client specific instructions you should be aware that this may prevent us from following the processes set out in this policy which have been designed to obtain the best possible results for the execution of those orders in respect of the elements covered by those specific Instructions.
    • Charges

It is our policy that commission and charging structures will not influence either the selection of execution venues or the order flow that follows as a result of the execution process. We will therefore not discriminate between the execution venues we use to arrange execution of your orders.

  • Monitoring and review of our execution policy
    • We will regularly monitor the effectiveness of our best execution policy to identify and, where appropriate, correct any deficiencies. In particular, this will cover the execution quality of any third parties referred to in the policy.
    • This review should be carried out regularly (on at least an annual basis) or whenever a material change occurs that affects your ability to continue to obtain the best possible result for your clients. We will also •review this best execution policy at least annually and whenever there is a significant change that affects our ability to continue to obtain the best possible results for our clients.
  • Staff understanding

All relevant staff are made aware of this policy to highlight and emphasise the importance of best execution.

Appendix 2 – Conflicts of Interest Policy Summary

  • The purpose of our conflicts of interest policy is to:
    • Identify the circumstances which constitute or may give rise to a conflict of interest entailing a risk of damage to our clients; and
    • Specify the procedures to be followed and measures to be adopted in order to manage such conflicts.
  • In preparing the policy we have taken into account a number of factors including:
    • Whether circumstances might arise where we make a financial gain or avoid a financial loss at the expense of you as a client;
    • Whether we have an interest in the outcome of a service provided to you distinct from your interests; and
    • Whether we have a financial or other incentives to favour the interest of another client or group of clients over your interests.
  • Examples of the potential conflicts of interest we have identified include:
    • Where we have confidential information regarding an existing or former client which would be of value to another part of our firm or to other clients of our firm;
    • If a transaction carried out on your behalf relates to an Investment in respect of which we or an associate may benefit from a commission, fee, mark up or mark down payable otherwise than by you as a client, and we or an associate may also receive fees from the counterparty to such a transaction;
    • If we act as agent for you as a client in relation to transactions in which we are also acting as agent for other clients and associates; and
    • Where we have an interest in other financial services companies. Where this applies, details will be disclosed in Section 5-Our Obligations of this Discretionary Management Agreement.
  • Against this background our conflicts policy can be summarised as follows:
    • Where a conflict arises, your interests as a client will always be put before our interests and those of our employees;
    • Where our firm has a material interest in a transaction to be entered into for you, all reasonable steps will be taken to ensure fair treatment for you;
    • We have established procedures to ensure fair treatment between clients. For example, when executing an aggregated order for a client which is not filled, securities which are obtained are allocated fairly between clients. We will  not enter into  dealing arrangements that could compromise  our ability to comply with  our best execution  obligations;
    • We have a policy designed to minimise the  risk of conflicts arising in situations where staff receive or provide gifts/inducements from  clients or third  parties;
    • We have a personal account dealing procedure to reduce potential conflicts in situations where staff deal for their own account;
    • We have internal organisational arrangements which act as information barriers controlling the disclosure of information within the firm and preventing the unauthorised release of restricted information to  other areas of the firm; and
    • We have an independence policy that requires staff to act disregarding any material  interest or conflict of interest when advising a  client or dealing for a  client in the  exercise of discretion.