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Q2 2019 DUE DILIGENCE QUESTIONNAIRE

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Page 1: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

Q2 2019

DUE DILIGENCE QUESTIONNAIRE

Page 2: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

DISCLAIMER

The information given herein is correct as of March 2019. This document was completed by Ben Raven.

TAVISTOCK WEALTH LTD

Important Note

This questionnaire is supplied on a confidential basis and may not be distributed to any other party without the express permission of Tavistock Wealth Ltd.

You may copy the questionnaire for your own internal purposes. You may not copy it for any other purposes without the express permission of Tavistock Wealth Ltd.

About Tavistock Wealth

Tavistock Wealth is a subsidiary of Tavistock Investments Plc, the UK wide financial services group. Currently Tavistock has over 200 financial advisers helping 50,000+ clients look after more than £3.5bn of investments.

Find out more at www.tavistockwealth.com or contact [email protected]

Page 3: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

TABLE OF CONTENTS

CONTENTS

PAGE 1 . - SECTION 1 & 2

COMPANY DETAILSCOMPANY STRUCTURE

PAGE 2. - SECTION 3

INVESTMENT PHILOSOPHY

PAGE 5. - SECTION 4

ABOUT US

PAGE 7. - SECTION 5

ASSETS UNDER MANAGEMENT

PAGE 8. - SECTION 6

WHY USE TAVISTOCK WEALTH?

PAGE 10. - SECTION 7

ACUMEN PORTFOLIOS

PAGE 19. - SECTION 8

TAVISTOCK PROFILES

PAGE 24. - SECTION 9

INVESTMENT PERFORMANCE

PAGE 25. - SECTION 10, 1 1 & 12

FEES AND CHARGESCOMMUNICATIONS & UPDATES

SYSTEMS

PAGE 26. - SECTION 13 & 14

SERVICE PROVIDERSCORPORATE GOVERNANCE

PAGE 27. - SECTION 15 & 16

REGULATION AND INSURANCEDISCRETIONARY CLIENT RELATIONSHIPS

3

Page 4: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

1.1 Company NameTavistock Wealth Ltd

1.2 Company Address1 Bracknell Beeches, Bracknell, RG12 7BW, United Kingdom

1.3 Company Websitewww.tavistockwealth.com

1.4 Adviser Website – Downloads/Factsheets/Bloghttp://advisers.tavistockwealth.com

1.5 Contact Number+44 1753 867000

1.6 Contact DetailsChristopher Peel – Chief Investment Officer: [email protected] Raven – Director: [email protected]

2.1 IndustryAsset ManagementDiscretionary Fund Management

2.2 Company BackgroundBlacksquare Capital LLP was founded in 2005 and launched its first funds in 2006. The company was acquired by Tavistock Investments Plc. in 2014 and renamed Tavistock Wealth Ltd. Tavistock Wealth manages over £1 billion of assets on behalf of all clients globally, the majority of which is managed through our flagship offering, the ACUMEN Portfolios. Our services are based on a combination of traditional values and revolutionary thinking, producing ethical and consistent net returns.We provide retail clients with access to institutional quality portfolio management at a retail price. We do this by partnering with the most successful risk manager in our industry. Our international business, Tavistock Wealth Global (TWL Global), provides discretionary investment services outside of the UK.

2.3 Legal/Ownership StructureTavistock Wealth is a subsidiary of Tavistock Investments Plc, the UK financial services group. The Tavistock Group currently has over 200 independent financial advisers and over £3.5 billion of funds under advice.

COMPANY INFORMATION

COMPANY DETAILS

COMPANY STRUCTURE

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1

2

Page 5: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

3.1 Our Investment Philosophy

We believe that an actively managed, globally allocated, multi-asset portfolio, comprised of low-cost Exchange Traded Funds (ETFs), with diversified holdings in equity, bond, commodity and property markets, is statistically more likely to outperform a traditional active manager.

Much research has demonstrated that only a small minority of traditional active fund managers beat their respective indices over any significant period. Two causes are higher management fees, and the considerable dealing costs required to actively trade hundreds, or sometimes thousands, of individual equity, bond, commodity or property positions.

However, the biggest challenge to overcome is the statistical phenomenon of “positive skewness”. This is the fact that over the last 90 years, the majority of the returns made by an index have been generated by only a small proportion of the stocks in that index. In other words, while a few stocks beat the wider index, the majority usually underperform, so most managers own mainly losing stocks.

3.2 Portfolio Construction

We believe the best risk adjusted returns can be derived from actively managing a basket of index or tracker holdings, including smart beta products that combine active optimisation techniques with systematic core strategies. Research, monitoring and analysis is carried out by our investment team on a daily, weekly and monthly basis, with the objective of continually improving the effectiveness of every ACUMEN Portfolio. The ACUMEN Portfolios form the building blocks for the model portfolios managed by Tavistock Wealth (Tavistock PROFILES).

Multiple layers of diversification within and between asset classes are designed to mitigate risk. Each regional asset class is optimised separately into a sub-portfolio, and then aggregated into a multi-asset portfolio that targets a level of risk consistent with the investment objectives of each ACUMEN Portfolio.

Each ACUMEN Portfolio is typically diversified across approximately 30+ ETFs, 8 primary asset classes, 98 countries and over 18,500 underlying positions. In another break with tradition, over 85% of the holdings within each ACUMEN Portfolio are hedged back to the investing currency, be that the pound sterling, the euro or the US dollar.

INVESTMENT SERVICES & PROCESSES

INVESTMENT PHILOSOPHY

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3

Page 6: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

INVESTMENT SERVICES & PROCESSES

INVESTMENT PHILOSOPHY3

Each ACUMEN Portfolio is optimised using Tavistock’s Backward Induction process at a regional asset class, asset class and portfolio level. On average, twenty-two separate optimisations are required to finalise each portfolio of holdings. The process analyses both historical and five-year rolling forecasted data for asset class returns and volatility. The output of this analysis is an ACUMEN Portfolio with the following structure:

3.5 Diversification

Every portfolio is constructed with these advanced, quantitative, fund management techniques and has exposure to the equity and debt securities of thousands of companies internationally. In our view, the resulting ACUMEN Portfolios are amongst the most diversified multi-asset portfolios in the world.

The final portfolio is a blend of the analyses run over the backward and forward looking time frames. The investment team use internal systems such as Thomson Reuters Eikon, Lipper for Fund Management, Datastream and AlternativeSoft. The same set of portfolio constraints and investment guidelines are also given to the quantitative analysis team at iShares (BlackRock) and they separately run a multi-step optimisation utilising their proprietary risk system, known as Aladdin. This vital element of our investment process independently validates the work done internally and helps distil any further improvement. Risk in the portfolios is monitored daily and the portfolios are typically rebalanced and recalibrated on a quarterly basis.

3.4 Quantitative Analysis

3.3 Backward Induction

Page | 3

1. Optimisation on a regional basis within an asset class.

2. Optimisation on an asset class basis.

3. Optimisation of final portfolio targeting a level of risk.

Final Portfolio

EquityGlobal

US

UK

Europe

Japan

Emerging Markets

Global

Emerging MarketsBond

Property

Commodity

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INVESTMENT SERVICES & PROCESSES

INVESTMENT PHILOSOPHY3

Page | 4

3.6 ACUMEN Portfolio Risk vs Return

3.7 Tavistock PROFILES Risk vs Return The ACUMEN Portfolios are blended together to create the Tavistock Profiles:

Targeted Annualised Volatility0.00% 3.00% 6.00% 9.00% 12.00% 15.00%

Ann

ualis

ed R

etur

n

ACUMEN Bond Portfolio

ACUMEN Conservative

Portfolio

ACUMEN Capital

Protection Portfolio

ACUMEN Income

Portfolio

ACUMEN Income

Protection Portfolio

ACUMEN Equity PortfolioACUMEN Strategic Portfolio

ACUMEN Progressive

Portfolio

ACUMEN Adventurous

Portfolio

TP3

TP4

TP5

TP6

TP7

TP8

Targeted Annualised Volatility

Ann

ualis

ed R

etur

n

0.00% 3.00% 6.00% 9.00% 12.00% 15.00%

TP2

Cash ABP ACP AIP APP AAP AEP ASP ACPP AIPP

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4.1 Our AimTavistock Wealth aim to provide retail clients with access to institutional quality portfolio management.

4.2 Our Investment OfferingWe run a core set of in-house funds called the ACUMEN Portfolios. The ACUMEN Portfolios cater for the varying risk appetite of different investors. This is done primarily by partnering up with the market leading provider of Exchange Traded Funds (ETFs):

We blend our ACUMEN Portfolios together to create the Tavistock PROFILES. These are model portfolios which target specific volatility parameters and are constantly monitored by our analysts, ensuring strict adherence to the criteria set by the Tavistock Wealth Investment Committee.

4.2 Investment CommitteeThe Tavistock Wealth Investment Committee meets monthly to discuss our investment offering. By meeting this frequently, Tavistock is able to effectively monitor and assess portfolio performance and volatility, enabling proactive improvements whenever necessary. The Tavistock Wealth Investment Committee has a mandate to ensure portfolios are managed in accordance with their stipulated investment objective. The Tavistock Wealth Investment Committee is chaired by Christopher Peel and other participants include Tavistock Wealth directors, senior management, the full investment management team and an external economist.

4.3 Key Personnel

Christopher Peel - Chief Investment OfficerChristopher Peel is the Chief Investment Officer of Tavistock Wealth and carries direct responsibility for all discretionary investments at the firm. Together with John Leiper, Head of Portfolio Management, and the portfolio management team, they co-manage the risk progressive range of ACUMEN Portfolios (UCITS funds) and the Tavistock PROFILES (model portfolios).

John Leiper CFA – Head of Portfolio Management

John is the Head of Portolio Management at Tavistock Wealth. Together with the research and investment team he manages the ACUMEN Portfolios and the Tavistock PROFILES. John has more than 10 years’ experience in financial markets having previously worked in a variety of roles at RBS, Morgan Stanley and Credit Suisse. John holds a BSc degree in Economics from Warwick University and an MSc degree in Economic History from the London School of Economics.

COMPANY INFORMATION

ABOUT US

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4

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4.4 Organisational Chart

COMPANY INFORMATION

ABOUT US

Page | 6

4

Andy FouracresCompliance

Director

Christopher PeelChief Investment

Officer

Sefi RothEconomist

India TurnbullInvestment

Analyst

James PeelInvestment

Analyst

Alex Livingstone

SeniorInvestment

Analyst

Sekar IndranJunior Portfolio

Manager

Ben RavenDirector

Jonah LevyInvestment

Analyst

Steven McGregor

Head of Advisor Support

Brian Raven Chief Executive

Julia FlemingBusiness

Development Associate

Matt CoombeBusiness

Development Associate

Connor StewartBusiness

Development Associate

Ashleigh Wallage

Office Manager

Kieran ScottSenior Business

Development Associate

Mo HussainSenior Business

Development Manager

John LeiperHead of Portfolio

Management

Gregor PrestonCompliance

Manager

Andrew PottieJunior Portfolio

Manager

Page 10: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

5.1 Total Assets Under Management (AUM)

5.2 Inflows Per Calendar Year

INVESTMENT SERVICES & PROCESSES

ASSETS UNDER MANAGEMENT

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AUM

£1 billion*

Effective Date

March 2019

Year

2014

Year

2015

Inflows

£100 million

Year

2016

Inflows

£450 million

Inflows

£80 million

5

*£850m discretionary and £150m non-discretionary

Year

2017

Inflows

£370 million

Page 11: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

6.1 Currency HedgingTavistock Wealth believes in hedging the overseas currency exposure within our ACUMEN Portfolios. This brings a number of advantages to both clients and advisers.

Currency hedging ensures that the asset allocation is the driver of portfolio returns, rather than currency moves. It also ensures the projected volatility of a portfolio is accurate at all times. Crucially for an adviser, this means the level of volatility the client is being exposed to is appropriate at all times.

Client portfolios benefit significantly from the insurance resulting from currency hedging, as they are unlikely to become misaligned with their risk appetite. The ACUMEN Portfolios hedge at least 85% of all non-UK exposure back to sterling.

An example of an UNHEDGED investment would work as follows. You hold an investment in an American stock market such as the S&P 500. The investment you make, as a UK investor, would be in GBP. However, the underlying investments to which you have exposure are held in USD. Over a 12 month period the S&P returns +5%. You have therefore made +5% in USD terms. However, the return you actually receive is not only based on what the S&P 500 has done. Crucially, it also depends on what the currency movement has been between GBP and USD over that same 12-month period. If the GBP has appreciated by +10% vs the USD over the period (and last year it appreciated by +8.5% between 10 April and 19 June), then even though the return of the S&P 500 was +5%, the overall return of the S&P 500 investment in your portfolio would be -4.55%.

Unhedged investments expose clients to significantly increased risk because their investments are affected by market moves that are not part of their intended strategy. As illustrated above, the investment is the American stock market – an equity investment. However, the investor is actually exposed to the equity market AND the currency market. The currency market is one of the most volatile of all financial markets and we believe care should be taken to minimise exposure to this risk wherever possible. A portfolio of hedged investments costs more than a portfolio of unhedged investments but the investor is much more protected in terms of both investment strategy and volatility (risk). The adviser is also protected in terms of the suitability of the investment recommendations they make.

INVESTMENT SERVICES & PROCESSES

WHY USE TAVISTOCK WEALTH?

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6

ARE YOU MAKING YOUR CLIENTS AWARE OF CURRENCY RISK?

HOW DOES YOUR FUND MANAGER TAKE CURRENCY RISK INTO ACCOUNT AND MANAGE IT WITHIN YOUR CLIENTS’

PORTFOLIOS?

Page 12: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

6.2 Transparency of chargesTavistock Wealth believe in operating a transparent pricing structure for the ACUMEN Portfolios. The industry practice is to quote an Ongoing Charges Figure (OCF) however, crucially, an OCF does not need to disclose any ‘variable’ costs such as the cost of trading a portfolio. Therefore, for a portfolio which is actively managed, clients may often see an OCF in the region of 1.00%, however in reality that same portfolio may incur further trading costs of approximately 1.50% a year. This means that fund may need to overcome a 2.50%1 cost hurdle each year before a client makes any money. For further information please visit our blog page - (http://blog.tavistockwealth.com/).Tavistock Wealth has identified the most cost and tax efficient method of building the ACUMEN Portfolios. This provides clients with efficient access to a robust asset allocation which will not expose them to significant ‘hidden’ costs. Further information on the ACUMEN Portfolios can be found in section 7.0.

6.3 ALADDINTavistock Wealth, through our strategic relationship with BlackRock, is granted access to BlackRock’s proprietary risk management system - Aladdin.Aladdin is responsible for managing over 33,000 portfolios globally, catering for $17 trillion of client portfolio assets every minute.Optimising the ACUMEN Portfolios through Aladdin enables Tavistock Wealth to offer our clients access to institutional quality portfolio management. It also enables Tavistock Wealth to leverage off the 1,000+ members of the BlackRock risk team.

6.4 White-Labelled DFM OfferingTavistock Wealth can offer IFA firms a white-labelled DFM offering on a number of different platforms. This option is available to IFAs who are looking to improve their investment offering and revolutionise their business.By entering into a working relationship with Tavistock Wealth, IFAs are able to alleviate themselves of the administrative burden of running advisory models whilst simultaneously mitigating the compliance risk and TCF implications of orchestrating portfolio re-balances on an advisory basis. Crucially this also enables the IFA to free up more time to write new business and subsequently increase their valuation.The underlying model portfolios would be run centrally by Tavistock Wealth with constant monitoring of all holdings and the ability to implement portfolio changes instantly. Additional benefits such as currency hedging, transparency of charges and access to the market-leading ALADDIN risk management system would also be available to the IFA.Marketing literature as well as monthly factsheets and ad-hoc research can all be produced in the IFAs own branding, as the IFA transforms their practice from an advisory business into a modern-day wealth manager.

INVESTMENT SERVICES & PROCESSES

WHY USE TAVISTOCK WEALTH?

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6

1 Shedding light on 'invisible' costs: trading costs and mutual fund performance. Roger Edelen, Richard Evans, Gregory Kadlec.

Page 13: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

7.1 ACUMEN OverviewTavistock Wealth is the sub-investment manager of the ACUMEN Open Ended Investment Company (OEIC). The 7 sub-funds of the OEIC are:

ACUMEN Bond Portfolio ACUMEN Conservative Portfolio ACUMEN Income Portfolio ACUMEN Progressive Portfolio ACUMEN Adventurous Portfolio ACUMEN Equity Portfolio ACUMEN Strategic Portfolio

Tavistock Wealth is the sub-investment manager of the FundLogic Alternatives PLC OEIC. The 2 sub-funds of the OEIC are:

ACUMEN Capital Protection Portfolio ACUMEN Income Protection Portfolio

Portfolio ConstructionThe ACUMEN Portfolios are highly sophisticated baskets of ETFs containing several thousand underlying securities. Multiple layers of diversification within and between asset classes are key to the portfolio construction process and are designed to mitigate risk. Each regional asset class is optimised separately into a sub-portfolio, and then aggregated into a multi-asset portfolio that targets a level of risk that is consistent with the investment objectives of the ACUMEN Portfolios.ACUMEN FeaturesThe ACUMEN Portfolios are highly diversified, sophisticated, multi-asset global portfolios comprised of ETFs. Each portfolio is optimised utilising the Backward Induction optimisation process at a regional asset class level, asset class level and fund level. On average, there are twenty-two separate optimisations that are run to reach a final portfolio of holdings. The process looks at both historical and five-year rolling forecasted data for asset class returns and volatility. The final portfolio is blend of the analysis run over the backward and forward looking time frames. All the work is conducted by the investment team utilising internal systems such as Thomson Reuters Eikon, Lipper for Investment Management, Datastream and AlternativeSoft. The same set of portfolio constraints and investment guidelines are also given to the quantitative analysis team at iShares (BlackRock) and they separately run a multi-step optimisation utilising their proprietary risk system known as Aladdin. This is a very important part of our investment process as it seeks to independently validate the work done internally by the investment team.ACUMEN ProtectionWith the ACUMEN Protection Portfolios, you can protect a significant amount of your initial investment, as well as protect a substantial amount of any potential future profits. This is achieved through PROTECTED INVESTING - a mechanism that tracks the growth of the portfolio and locks in a percentage of any growth each time the portfolio reaches a new high.

INVESTMENT SERVICES & PROCESSES

ACUMEN PORTFOLIOS

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Mitigation of foreign exchange risk

Institutional quality risk management

Wide diversification across equities, bonds, commodities and property

Wide diversification across the UK, Europe, US, Asia and Emerging Markets

Strategy that remains 100% invested

Run to specific volatility bands

High levels of liquidity

No barriers to entry

Cost & Tax efficient fund structure

Please refer to section 6.1

Access to the ALADDIN risk management system (please refer to section 6.3). BlackRock has in excess of 1,000 employees in their research team spread across 70 offices in 30 different countries.

Market-leading range of ETFs enables Tavistock Wealth to implement our unique asset allocation. Our asset allocation is the result of extensive analysis focusing on both backward looking data and forward looking forecasts.It is not possible to implement our asset allocation with any other ETF provider owing to the lack of choice at the ETF level.

Provides clients with the opportunity to outperform active managers who must try and ‘time the market’ consistently and incur potentially prohibitive trading costs in attempting to do so. There is overwhelming research to suggest that as the time frame increases, less active managers are able to outperform.

ACUMEN Portfolios aim to provide clients (of a given risk profile) access to an asset allocation which can diversify away losses and remain fully invested so that there is no need to try and predict the future of financial markets. ACUMEN Portfolios are therefore able to benefit from a lower cost base (significantly lower trading costs) and by removing the need to ‘time the markets’.

Tavistock Wealth work with BlackRock to ensure the ACUMEN Portfolios perform within strict volatility bands at all times.

Daily liquidity, daily dealing, settlement T+4

Minimum Investment £100No initial fees/exit feesNo performance feesNo bid/offer spreadsNISA compliant

No CGT event on trades within the ACUMEN PortfoliosNo stamp duty on holdings within the ACUMEN Portfolios

7.2 ACUMEN Features & Benefits

INVESTMENT SERVICES & PROCESSES

ACUMEN PORTFOLIOS

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ACUMEN Feature Benefit

7

Page 15: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

7.3 ACUMEN - Dynamic Planner Risk Rating

INVESTMENT SERVICES & PROCESSES

ACUMEN PORTFOLIOS

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ACUMEN Portfolio Risk Rating

7

ACUMEN Bond Portfolio

ACUMEN Conservative Portfolio

ACUMEN Income Portfolio

ACUMEN Progressive Portfolio

ACUMEN Adventurous Portfolio

ACUMEN Equity Portfolio

ACUMEN Strategic Portfolio

ACUMEN Capital Protection Portfolio

ACUMEN Income-Protection Portfolio

Page 16: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

INVESTMENT SERVICES & PROCESSES

ACUMEN PORTFOLIOS7

ACUMEN Bond Portfolio

The portfolio aims to have a minimum fixed income exposure of 80%. The portfolio may also have exposure to a range of global asset classes including equities, commodities, property, cash, near cash, deposits, transferable securities and money market instruments. The portfolio primarily gains exposure to the above asset classes by investing in a range of low cost, index tracking funds or exchange traded funds. The portfolio may also gain exposure to the above asset classes through investment in collective investment schemes, investment trusts, investment companies and where permissible by holding the asset classes directly.

ACUMEN Conservative Portfolio

The portfolio aims to have a minimum fixed income and/or cash exposure of 30% and equity exposure ranging between 20-60%. This portfolio aims to gain exposure through investment in a diversified portfolio of regulated UCITS-compliant collective investment schemes, regulated or authorised collective investment schemes, investment trusts, investment companies, cash and near cash and deposits. The portfolio primarily invests in a range of low cost, index tracking funds or exchange traded funds but may also invest in other transferable securities and money market instruments in accordance with the rules in COLL.

ACUMEN Income Portfolio

The portfolio will maintain at least 30% exposure to fixed income and cash and between 20-60% exposure to shares. The portfolio aims to gain exposure through investment in a wide range of global asset classes including equities, bonds, commodities, property, cash, near cash and deposits. The portfolio may also be exposed to other transferable securities and money market instruments. The portfolio primarily gains exposure to the above asset classes by investing in a range of low cost, index tracking funds or exchange traded funds. The portfolio may also gain exposure to the above asset classes through investment in collective investment schemes, investment trusts, investment companies and where permissible by holding the asset classes directly.

ACUMEN Progressive Portfolio

The portfolio has no minimum exposure to fixed income and/or cash and the portfolio aims to have an equity exposure ranging between 40-85%. The portfolio primarily invests in a range of low cost, index tracking funds or exchange traded funds but may also invest in other transferable securities and money market instruments in accordance with the rules in COLL. This portfolio aims to to gain exposure through investment in a diversified portfolio of regulated UCITS-compliant collective investment schemes, regulated or authorised collective investment schemes, investment trusts, investment companies, cash and near cash and deposits.

7.4 ACUMEN Investment Policies

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INVESTMENT SERVICES & PROCESSES

ACUMEN PORTFOLIOS7

ACUMEN Adventurous Portfolio

The portfolio has no minimum exposure to fixed income and/or cash and the maximum permitted equity exposure is 100%. The portfolio primarily invests in a range of low cost, index tracking funds or exchange traded funds but may also invest in other transferable securities and money market instruments in accordance with the rules in COLL. This portfolio aims to gain exposure through investment in a diversified portfolio of regulated UCITS-compliant collective investment schemes, regulated or authorised collective investment schemes, investment trusts, investment companies, cash and near cash and deposits.

ACUMEN Equity Portfolio

The portfolio aims to have a minimum equity exposure of 80%. The portfolio may also have exposure to a range of global asset classes including bonds, commodities, property, cash, near cash, deposits, transferable securities and money market instruments. The portfolio primarily gains exposure to the above asset classes by investing in a range of low cost, index tracking funds or exchange traded funds. The portfolio may also gain exposure to the above asset classes through investment in collective investment schemes, investment trusts, investment companies and where permissible by holding the asset classes directly.

ACUMEN Strategic Portfolio

The portfolio aims to gain exposure through investment in a range of global asset classes including equities, bonds, commodities, property, cash, near cash, deposits, transferable securities and money market instruments. There is no minimum or maximum expose to any asset class listed above or to any financial market. The portfolio primarily gains exposure to the above asset classes by investing in a range of low cost, index tracking funds or exchange traded funds. The portfolio may also gain exposure to the above asset classes through investment in collective investment schemes, investment trusts, investment companies and where permissible by holding the asset classes directly.

ACUMEN Capital Protection Portfolio

The aim of the ACUMEN Capital Protection Portfolio is to deliver long-term capital growth by investing in a range of global financial markets. The portfolio is typically comprised of lower and medium risk investments such as cash, bonds and property as well as a few higher risk investments such as equities and commodities. The portfolio targets long-term volatility in the range of 5% to 7% and through the protection mechanism seeks to ensure you always get back at least 90% of the highest value ever achieved by the portfolio.

ACUMEN Income Protection Portfolio

The aim of the ACUMEN Income-Protection Portfolio is to deliver long-term growth by investing in a range of global financial markets. The investment holdings target both capital growth and an annual yield which is accumulated into the portfolio. The portfolio is typically comprised of lower and medium risk investments such as cash, bonds and property as well as a few higher risk investments such as equities and commodities. The portfolio targets long-term volatility in the range of 7% to 9% and through the protection mechanism seeks to ensure you always get back at least 85% of the highest value ever achieved by the portfolio.

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7.5 ACUMEN Risk Profiles

INVESTMENT SERVICES & PROCESSES

ACUMEN PORTFOLIOS

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7

ACUMEN Portfolio Risk Profile

The ACUMEN Bond Portfolio targets a risk profile of 2.0 on a scale from 1-10, and can be characterised as “cautious risk”. The portfolio is typically comprised of lower risk investments such as bonds. The portfolio aims to produce annualised volatility in the range of 1.5% to 3.0%.

The ACUMEN Conservative Portfolio targets a risk profile of 3.5 on a scale from 1-10, and can be characterised as “cautious to moderate risk”. The portfolio is typically comprised of lower and medium risk investments such as cash, bonds, and property as well as a few higher risk investments such as equities and commodities. The portfolio aims to produce annualised volatility in the range of 5.1% to 7.0%.

The ACUMEN Income Portfolio targets a risk profile of 5.5 on a scale from 1-10, which can be characterised as “low end of moderate risk”. The portfolio is actively managed and is typically comprised of lower and medium risk investments such as cash, bonds and property as well as a few higher risk investments such as equities and commodities. The portfolio aims to produce annualised volatility in the range of 7.1% to 9.0%.

The ACUMEN Progressive Portfolio targets a risk profile of 7.5 on a scale from 1-10, which can be characterised as “moderate to adventurous risk”. The portfolio is typically comprised of higher risk investments such as equities and commodities but will also contain a few medium risk investments such as bonds and property. The portfolio aims to produce annualised volatility in the range of 9.1% to 11.0%.

The ACUMEN Adventurous Portfolio targets a risk profile of 8.5 on a scale from 1-10, which can be characterised as “adventurous risk”. The portfolio is typically comprised of higher risk investments such as equities and commodities. The portfolio aims to produce annualised volatility in the range of 11.1% to 13.0%.

The ACUMEN Equity Portfolio targets a risk profile of 8.5 on a scale from 1-10, which can be characterised as “adventurous risk”. The portfolio is typically comprised of higher risk investments such as equities. The portfolio aims to produce annualised volatility in the range of 11.6 % to 13.5%.

The ACUMEN Strategic Portfolio targets a risk profile of 9.0 on a scale from 1-10, which can be characterised as “adventurous risk”. The portfolio is typically comprised of higher risk investments such as equities and commodities. The portfolio aims to produce annualised volatility in the range of 12.1% to 14.0%.

The ACUMEN Capital Protection Portfolio targets a risk profile of 3.5 on a scale from 1-10, and can be characterised as “cautious to moderate risk”. The portfolio is typically comprised of lower and medium risk investments such as cash, bonds, and property as well as a few higher risk investments such as equities and commodities. The portfolio aims to produce annualised volatility in the range of 5.0% to 7.0%.

The ACUMEN Income Protection Portfolio targets a risk profile of 5.5 on a scale from 1-10, which can be characterised as “low end of moderate risk”. The portfolio is actively managed and is typically comprised of lower and medium risk investments such as cash, bonds and property as well as a few higher risk investments such as equities and commodities. The portfolio aims to produce annualised volatility in the range of 7.0% to 9.0%.

Page 19: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

INVESTMENT SERVICES & PROCESSES

ACUMEN PORTFOLIOS77.6 ACUMEN Benchmark

ACUMEN Portfolio Benchmark

Page | 16

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index

Average (5%) and the Bloomberg Barclays Global Aggregate Bond Index (95%). The

peer group benchmark is the Investment Association’s Flexible Investment sector.

Benchmark performance is evaluated over a rolling twelve-month investment cycle.

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index

Average (5%), Bloomberg Barclays Global Aggregate Bond Index (57%) and the

iShares MSCI World ETF (38%). The peer group benchmark is the Investment

Association’s Flexible Investment sector. Benchmark performance is evaluated over

a rolling twelve-month investment cycle.

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index

Average (5%), Bloomberg Barclays Global Aggregate Bond Index (43%) and the

iShares MSCI World ETF (52%). The peer group benchmark is the Investment

Association’s Flexible Investment sector. Benchmark performance is evaluated over

a rolling twelve-month investment cycle.

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index

Average (5%), Bloomberg Barclays Global Aggregate Bond Index (28.5%) and the

iShares MSCI World ETF (66.5%). The peer group benchmark is the Investment

Association’s Flexible Investment sector. Benchmark performance is evaluated over

a rolling twelve-month investment cycle.

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index

Average (5%), Bloomberg Barclays Global Aggregate Bond Index (9.5%) and the

iShares MSCI World ETF (85.5%). The peer group benchmark is the Investment

Association’s Flexible Investment sector. Benchmark performance is evaluated over

a rolling twelve-month investment cycle.

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index

Average (5%) and the iShares MSCI World ETF (95%). The peer group benchmark is

the Investment Association’s Flexible Investment sector. Benchmark performance is

evaluated over a rolling twelve-month investment cycle.

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index

Average (5%) and the iShares MSCI World ETF (95%). The peer group benchmark is

the Investment Association’s Flexible Investment sector. Benchmark performance is

evaluated over a rolling twelve-month investment cycle.

The market composite benchmark (GBP Hedged) is the Bloomberg Barclays Global

Aggregate Bond Index (60%) and the iShares MSCI World ETF (40%). The peer

group benchmark is the Investment Association’s Mixed Investment 20-60% Shares

sector. Benchmark performance is evaluated over a rolling twelve-month

investment cycle.

The market composite benchmark (GBP Hedged) is the Bloomberg Barclays Global

Aggregate Bond Index (45%) and the iShares MSCI World ETF (55%). The peer group

benchmark is the Investment Association’s Mixed Investment 20-60% Shares

sector. Benchmark performance is evaluated over a rolling twelve-month

investment cycle.

Page 20: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

7.7 ACUMEN Share Classes

INVESTMENT SERVICES & PROCESSES

ACUMEN PORTFOLIOS

Page | 17

ACUMEN Portfolio

7

ACUMEN Portfolio Share Class

Class X SharesAnnual Management Charge - 0.75%Ongoing Charges Figure - 1.04%Sedol Code - GBP: (BZ3T3D2) EUR: (BZ3T3F4) USD: (BZ3T3G5)ISIN Code - GBP: (GB00BZ3T3D26) EUR: (GB00BZ3T3F40) USD: (GB00BZ3T3G56)

Class X SharesAnnual Management Charge - 0.75%Ongoing Charges Figure - 1.06% Sedol Code - GBP: (B84LZT8) EUR: (BZ3SYL4) USD: (BZ3SZ55)ISIN Code - GBP: (GB00B84LZT89) EUR: (GB00BZ3SYL48) USD: (GB00BZ3SZ550)

Class X SharesAnnual Management Charge - 0.75%Ongoing Charges Figure - 1.18%Sedol Codes - GBP Acc: (BYW8MW5) GBP Inc: (BYW8MX6) EUR: (BZ3T0Q4) USD: (BZ3T2H9)ISIN Codes - GBP Acc: (GB00BYW8MW59) GBP Inc: (GB00BYW8MX66) EUR: (GB00BZ3T0Q40) USD: (GB00BZ3T2H98)

Class X SharesAnnual Management Charge - 0.75%Ongoing Charges Figure - 1.08% Sedol Code - GBP: (B87LP73) EUR: (BZ3T2L3) USD: (BZ3T2N5)ISIN Code - GBP: (GB00B87LP737) EUR: (GB00BZ3T2L35) USD: (GB00BZ3T2N58)

Class X SharesAnnual Management Charge - 0.75%Ongoing Charges Figure - 1.12%Sedol Code - GBP: (B7NJ0M4) EUR: (BZ3T3B0) USD: (BZ3T3C1)ISIN Code - GBP: (GB00B7NJ0M49) EUR: (GB00BZ3T3B02) USD: (GB00BZ3T3C19)

Class X SharesAnnual Management Charge - 0.75%Ongoing Charges Figure - 1.15%Sedol Code - GBP: (BZ3T3H6) EUR: (BZ3T3J8) USD: (BZ3T3K9)ISIN Code - GBP (GB00BZ3T3H63) EUR: (GB00BZ3T3J87) USD: (GB00BZ3T3K92)

Class X SharesAnnual Management Charge - 0.75%Ongoing Charges Figure - 1.25%Sedol Code - GBP: (BZ3T3L0) EUR: (BZ3T3M1) USD: (BZ3T3N2)ISIN Code - GBP: (GB00BZ3T3L00) EUR: (GB00BZ3T3M17) USD: (GB00BZ3T3N24)

Class A SharesAnnual Management Charge - 1.00%Ongoing Charges Figure - 1.33%Sedol Code - GBP: (BD71CN3) EUR: (BD71CP5) USD: (BD71CQ6)ISIN Code - GBP: (IE00BD71CN33) EUR: (IE00BD71CP56) USD: (IE00BD71CQ63)

Class A SharesAnnual Management Charge - 1.00%Ongoing Charges Figure - 1.32%Sedol Code - GBP: (BG032B5) EUR: (BG032C6) USD: (BG032D7)ISIN Code - GBP: (IE00BG032B54) EUR: (IE00BG032C61) USD: (IE00BG032D78)

Page 21: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

9.1 Tavistock PROFILES

ACUMEN Portfolios

ACUMEN Protection Portfolios

ACUMEN Portfolio Platforms

INVESTMENT SERVICES & PROCESSES

ACUMEN PORTFOLIOS77.8 ACUMEN Platform Availability

Page | 18

Page 22: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

8.1 OverviewThe Tavistock PROFILES cater for clients wishing to invest in risk profiles 2-8, Tavistock Wealth operate with a key focus on risk management ensuring our Tavistock PROFILES (model portfolios) operate within defined volatility parameters.

The Tavistock PROFILES allocate across nine primary asset classes – Government Bonds, Corporate Bonds, Inflation-Linked Bonds, Emerging Market Bonds, Developed Market Equities, Emerging Market Equities, Commodity Equities, Property Equities and Cash.

All Tavistock PROFILES are re-balanced centrally by the Tavistock Wealth investment team. Rebalances typically take place twice per year.

INVESTMENT SERVICES & PROCESSES

TAVISTOCK PROFILES

Page | 19

Tavistock PROFILES - (2-8 + Income Portfolio)

Risk Levels 2 - 8

Allocation to ACUMEN Portfolios:100%

Inception Date:28th February, 2008 (Income Portfolio - 2nd March, 2009, PROFILE - 2 17th May, 2018)

DFM Fee:0%

9.1 Tavistock PROFILES

8

Page 23: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

8.2 Volatility TargetsThe volatility targets of the Tavistock risk profiles are as follows:

8.3 Investment Objectives

INVESTMENT SERVICES & PROCESSES

TAVISTOCK PROFILES

Page | 20

CAUTIOUS RISK

LOW END OF CAUTIOUS TO MODERATE RISK

CAUTIOUS TO MODERATE RISK

LOW END OF MODERATE RISK

MODERATE RISK

LOW END OF MODERATE TO ADVENTUROUS RISK

MODERATE TO ADVENTUROUS RISK

1.5% -3.0%

3.1% - 4.5%

4.6% - 6.0%

6.1% - 7.5%

7.6% - 9.0%

9.1% - 10.5%

10.6% - 12.0%

Tavistock PROFILE Risk Profile Volatility Target

The investment objective of PROFILE 2 is to seek to deliver long term capital growth by investing in a range of global financial markets. The portfolio is actively managed and comprised of multi-asset investments including equities, bonds, commodities, and property.

The investment objective of PROFILE 3 is to seek to deliver long term capital growth by investing in a range of global financial markets. The portfolio is actively managed and comprised of multi-asset investments including equities, bonds, commodities, and property.

The investment objective of PROFILE 4 is to seek to deliver long term capital growth by investing in a range of global financial markets. The portfolio is actively managed and comprised of multi-asset investments including equities, bonds, commodities, and property.

The investment objective of PROFILE 5 is to seek to deliver long term capital growth by investing in a range of global financial markets. The portfolio is actively managed and comprised of multi-asset investments including equities, bonds, commodities, and property.

The investment objective of PROFILE 6 is to seek to deliver long term capital growth by investing in a range of global financial markets. The portfolio is actively managed and comprised of multi-asset investments including equities, bonds, commodities, and property.

The investment objective of PROFILE 7 is to seek to deliver long term capital growth by investing in a range of global financial markets. The portfolio is actively managed and comprised of multi-asset investments including equities, bonds, commodities, and property.

The investment objective of PROFILE 8 is to seek to deliver long term capital growth by investing in a range of global financial markets. The portfolio is actively managed and comprised of multi-asset investments including equities, bonds, commodities, and property.

Tavistock PROFILE Investment Objective

8

2

2

Page 24: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

8.4 Investment Policies

INVESTMENT SERVICES & PROCESSES

TAVISTOCK PROFILES

Page | 21

The investment policy of PROFILE 2 is to gain exposure through investment in a diversified portfolio comprised of regulated collective investment schemes, transferable securities, and cash. The minimum exposure to investment grade bonds and/or cash is 25% and the maximum equity exposure is 45%.

The investment policy of PROFILE 3 is to gain exposure through investment in a diversified portfolio comprised of regulated collective investment schemes, transferable securities, and cash. The minimum exposure to investment grade bonds and/or cash is 45% and the maximum equity exposure is 35%.

The investment policy of PROFILE 4 is to gain exposure through investment in a diversified portfolio comprised of regulated collective investment schemes, transferable securities, and cash. The minimum bond and/or cash exposure is 30% and equity exposure ranges between 20-60%.

The investment policy of PROFILE 5 is to gain exposure through investment in a diversified portfolio comprised of regulated collective investment schemes, transferable securities, and cash. The minimum bond and/or cash exposure is 30% and the equity exposure ranges between 20-60%.

The investment policy of PROFILE 6 is to gain exposure through investment in a diversified portfolio comprised of regulated collective investment schemes, transferable securities, and cash. There is no minimum exposure to bonds and/or cash and the equity exposure ranges between 40-85%.

The investment policy of PROFILE 7 is to gain exposure through investment in a diversified portfolio comprised of regulated collective investment schemes, transferable securities, and cash. There is no minimum exposure to bonds and/or cash and the maximum equity exposure is 100%.

The investment policy of PROFILE 8 is to gain exposure through investment in a diversified portfolio comprised of regulated collective investment schemes, transferable securities, and cash. There is no minimum exposure to bonds and/or cash and the maximum equity exposure is 100%.

Tavistock PROFILE Investment Policy

8

The ACUMEN Bond Portfolio targets a risk profile of 2.0 on a scale from 1-10, and can be characterised as “cautious risk”. The portfolio is typically comprised of lower risk investments such as bonds. The portfolio aims to produce annualised volatility in the range of 1.5% to 3.0%.

The ACUMEN Conservative Portfolio targets a risk profile of 3.5 on a scale from 1-10, and can be characterised as “cautious to moderate risk”. The portfolio is typically comprised of lower and medium risk investments such as cash, bonds, and property as well as a few higher risk investments such as equities and commodities. The portfolio aims to produce annualised volatility in the range of 5.1% to 7.0%.

The ACUMEN Income Portfolio targets a risk profile of 5.5 on a scale from 1-10, which can be characterised as “low end of moderate risk”. The portfolio is actively managed and is typically comprised of lower and medium risk investments such as cash, bonds and property as well as a few higher risk investments such as equities and commodities. The portfolio aims to produce annualised volatility in the range of 7.1% to 9.0%.

The ACUMEN Progressive Portfolio targets a risk profile of 7.5 on a scale from 1-10, which can be characterised as “moderate to adventurous risk”. The portfolio is typically comprised of higher risk investments such as equities and commodities but will also contain a few medium risk investments such as bonds and property. The portfolio aims to produce annualised volatility in the range of 9.1% to 11.0%.

The ACUMEN Adventurous Portfolio targets a risk profile of 8.5 on a scale from 1-10, which can be characterised as “adventurous risk”. The portfolio is typically comprised of higher risk investments such as equities and commodities. The portfolio aims to produce annualised volatility in the range of 11.1% to 13.0%.

The ACUMEN Equity Portfolio targets a risk profile of 8.5 on a scale from 1-10, which can be characterised as “adventurous risk”. The portfolio is typically comprised of higher risk investments such as equities. The portfolio aims to produce annualised volatility in the range of 11.6 % to 13.5%.

The ACUMEN Strategic Portfolio targets a risk profile of 9.0 on a scale from 1-10, which can be characterised as “adventurous risk”. The portfolio is typically comprised of higher risk investments such as equities and commodities. The portfolio aims to produce annualised volatility in the range of 12.1% to 14.0%.

The ACUMEN Capital Protection Portfolio targets a risk profile of 3.5 on a scale from 1-10, and can be characterised as “cautious to moderate risk”. The portfolio is typically comprised of lower and medium risk investments such as cash, bonds, and property as well as a few higher risk investments such as equities and commodities. The portfolio aims to produce annualised volatility in the range of 5.0% to 7.0%.

The ACUMEN Income Protection Portfolio targets a risk profile of 5.5 on a scale from 1-10, which can be characterised as “low end of moderate risk”. The portfolio is actively managed and is typically comprised of lower and medium risk investments such as cash, bonds and property as well as a few higher risk investments such as equities and commodities. The portfolio aims to produce annualised volatility in the range of 7.0% to 9.0%.

2

Page 25: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

8.5 Risk Profiles

INVESTMENT SERVICES & PROCESSES

TAVISTOCK PROFILES

Page | 22

PROFILE 2 targets a risk profile of 2 on a scale from 1-10, which can be characterised as “Cautious risk”. It is typically comprised of lower and medium risk investments such as cash, bonds, and property as well as a few higher risk investments such as equities and commodities. The portfolio targets annualised volatility in the range of 1.5% to 3.0%.

PROFILE 3 targets a risk profile of 3 on a scale from 1-10, which can be characterised as “low end of cautious to moderate risk”. It is typically comprised of lower and medium risk investments such as cash, bonds, and property as well as a few higher risk investments such as equities and commodities. The portfolio targets annualised volatility in the range of 3.1% to 4.5%.

PROFILE 4 targets a risk profile of 4 on a scale from 1-10, which can be characterised as “cautious to moderate risk”. The portfolio is typically comprised of lower and medium risk investments such as cash, bonds, and property as well as a few higher risk investments such as equities and commodities. The portfolio targets annualised volatility in the range of 4.6% to 6.0%.

PROFILE 5 targets a risk profile of 5 on a scale from 1-10, which can be characterised as “low end of moderate risk”. The portfolio is typically comprised of lower and medium risk investments such as cash, bonds, and property as well as higher risk investments such as equities and commodities. The portfolio targets annualised volatility in the range of 6.1% to 7.5%.

PROFILE 6 targets a risk profile of 6 on a scale from 1-10, which can be characterised as “moderate risk”. The portfolio is typically comprised of higher risk investments such as equities and commodities but will also contain a few lower and medium risk investments such as cash, bonds, and property. The portfolio targets annualised volatility in the range of 7.6% to 9.0%.

PROFILE 7 targets a risk profile of 7 on a scale from 1-10, which can be characterised as “low end of moderate to adventurous risk”. The portfolio is typically comprised of higher risk investments such as equities and commodities but will also contain a few lower and medium risk investments such as cash, bonds, and property. The portfolio targets annualised volatility in the range of 9.1% to 10.5%.

PROFILE 8 targets a risk profile of 8 on a scale from 1-10, which can be characterised as “moderate to adventurous risk”. The portfolio is typically comprised of higher risk investments such as equities and commodities but will also contain a few medium risk investments such as bonds and property. The portfolio targets annualised volatility in the range of 10.6% to 12.0%.

Tavistock PROFILE Risk Profile

8

2

Page 26: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

8.6 Benchmarks

INVESTMENT SERVICES & PROCESSES

Page | 23

Tavistock PROFILE Benchmark

TAVISTOCK PROFILES

Tavistock PROFILES (2-8 + Income)

*Profile 2 currently only available on Novia and

Praemium

Tavistock PROFILE Platforms

8.7 Platform Availability

8

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index Average (5%),

Bloomberg Barclays Global Aggregate Bond Index (76%) and the iShares MSCI World ETF (19%).

The peer group benchmark is the Investment Association’s Flexible Investment sector.

Benchmark performance is evaluated over a rolling twelve-month investment cycle.

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index Average (5%),

Bloomberg Barclays Global Aggregate Bond Index (66.5%) and the iShares MSCI World ETF

(28.5%). The peer group benchmark is the Investment Association’s Flexible Investment sector.

Benchmark performance is evaluated over a rolling twelve-month investment cycle.

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index Average (5%),

Bloomberg Barclays Global Aggregate Bond Index (57%) and the iShares MSCI World ETF (38%).

The peer group benchmark is the Investment Association’s Flexible Investment sector.

Benchmark performance is evaluated over a rolling twelve-month investment cycle.

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index Average (5%),

Bloomberg Barclays Global Aggregate Bond Index (47.5%) and the iShares MSCI World ETF

(47.5%). The peer group benchmark is the Investment Association’s Flexible Investment sector.

Benchmark performance is evaluated over a rolling twelve-month investment cycle.

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index Average (5%),

Bloomberg Barclays Global Aggregate Bond Index (38%) and the iShares MSCI World ETF (57%).

The peer group benchmark is the Investment Association’s Flexible Investment sector.

Benchmark performance is evaluated over a rolling twelve-month investment cycle.

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index Average (5%),

Bloomberg Barclays Global Aggregate Bond Index (28.5%) and the iShares MSCI World ETF

(66.5%). The peer group benchmark is the Investment Association’s Flexible Investment sector.

Benchmark performance is evaluated over a rolling twelve-month investment cycle.

The Market Composite Benchmark (GBP Hedged) is the Sterling Overnight Index Average (5%),

Bloomberg Barclays Global Aggregate Bond Index (19%) and the iShares MSCI World ETF (76%).

The peer group benchmark is the Investment Association’s Flexible Investment sector.

Benchmark performance is evaluated over a rolling twelve-month investment cycle.

2

Page 27: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

The Tavistock PROFILES have been independently risk profiled by Dynamic Planner. Projections are based on the asset allocation of the underlying investments. The above ratings have been issued by the Dynamic Planner. The value of investments held in the Tavistock PROFILES may fall as well as rise. Past performance should not be seen as an indication of future performance. The Tavistock PROFILES are a white-labelled offering based on the DFM Portfolio Management Service provided by PB Financial Planning. PB Financial Planning is a trading style of Tavistock Private Client Limited, which is authorised and regulated by the FCA. All performance data up until 31/12/16 has been provided by PB Financial Planning. As of 01/01/17, all Tavistock PROFILES invest in a blend of the ACUMEN Portfolio range. All performance data thereafter is provided by Tavistock Wealth Limited. Source of data: PB Financial Planning, Tavistock Wealth Limited, FE Analytics, Thomson Reuters, and Lipper for Investment Management unless otherwise stated. Date of data: 31st March 2019 unless otherwise stated.

INVESTMENT SERVICES & PROCESSES

Page | 24

N/A

3.56%

4.69%

5.86%

6.75%

7.92%

8.78%

5.52%

0.51%

1.09%

1.21%

1.35%

1.36%

1.46%

1.53%

0.82%

N/A

0.09%

0.51%

1.72%

2.27%

2.78%

2.90%

2.23%

N/A

7.42%

12.03%

16.63%

21.54%

29.08%

32.42%

15.89%

N/A

15.66%

20.11%

24.92%

30.07%

39.03%

42.28%

27.05%

PROFILE MAR 19 YTD 1 yr

INVESTMENT PERFORMANCE

Tavistock PROFILE 2

Tavistock PROFILE 3

Tavistock PROFILE 4

Tavistock PROFILE 5

Tavistock PROFILE 6

Tavistock PROFILE 7

Tavistock PROFILE 8

Tavistock Income

9

3 yr 5 yr

Tavistock PROFILE 3 Tavistock PROFILE 4 Tavistock PROFILE 5 Tavistock PROFILE 6

Tavistock PROFILE 7 Tavistock PROFILE 8 Tavistock Income

Page 28: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

10.1 ACUMEN Portfolio Charges

10.2 Discretionary Fund Management (DFM) Charges

11.1 CommunicationsTavistock Wealth issue the following communications to advisers:

Monthly performance reportMonthly factsheetsTavistock Wealth blogTavistock Wealth PR articles/video

12.1 Investment Management SystemsThe systems used by the Tavistock Wealth investment management team are:

Lipper for Investment ManagementThomson Reuters EikonAlternativeSoft

INVESTMENT SERVICES & PROCESSES

FEES AND CHARGES

COMMUNICATIONS & UPDATES

Page | 25

ACUMEN Portfolio

ACUMEN Bond Portfolio

ACUMEN Conservative Portfolio

ACUMEN Income Portfolio

ACUMEN Progressive Portfolio

ACUMEN Adventurous Portfolio

ACUMEN Equity Portfolio

ACUMEN Strategic Portfolio

AMC / OCF / Total Transaction Costs

0.75% / 1.04% / 0.10%

0.75% / 1.06% / 0.08%

0.75% / 1.18% / 0.14%

0.75% / 1.08% / 0.10%

0.75% / 1.12% / 0.06%

0.75% / 1.15% / 0.08%

0.75% / 1.25% / 0.08%

Investment Portfolio

Tavistock PROFILES

DFM Management Fee (p.a.)

0.00% (100% allocation to in-house ACUMEN Portfolios)

SYSTEMS

10

11

12

DatastreamFE Analytics

Ad-hoc research publications – e.g. Brexit/ Bond market bubble

ACUMEN Protection Portfolios

ACUMEN Capital Protection

ACUMEN Income Protection

AMC / OCF / Total Transaction Costs

1.00% / 1.33% / 0.125%

1.00% / 1.32% / 0.125%

*OCF is inclusive of AMC

*OCF is inclusive of AMC

Page 29: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

12.2 Trade Execution ProcessA copy of the Tavistock Wealth trade execution policy is available upon request.

12.3 Is there an in-house dealing function?No

12.4 Affiliated BrokersAll trades are placed and executed via Tradeweb (https://www.tradeweb.com/)

INVESTMENT SERVICES & PROCESSES

SYSTEMS

Page | 26

SERVICE PROVIDERS

CORPORATE GOVERNANCE

13.1 Service ProvidersThe service providers used by Tavistock Wealth for the ACUMEN Portfolios are:

Director(s) - Investment Fund Services Limited and FundLogicDepositaries - National Westminster Bank plc and Northern Trust Fiduciary Services (Ireland) LimitedCustodians - BNP Paribas Securities Services and Morgan Stanley & Co. International PlcAdministrators and Registrars - Investment Fund Services Limited and FundLogicAuditor - Ernst & Young LLP

13.2 Other Key Outsourced Service ProvidersTavistock Wealth outsource IT to Commercial IT Services, based in Cheltenham.

14.1 Corporate GovernanceFurther details regarding Corporate Governance are available upon request.

14.2 Environmental and Social ImpactTavistock Wealth is committed to sustainable waste disposal, with polices in place to ensure the appropriate re-use and recycling of equipment/waste wherever possible.Tavistock Wealth engages with the community by working with charities local to our Head Office in Bracknell.

14.3 DirectorsBrian Raven | Christopher Peel | Oliver Cooke | Ben Raven | Andy Fouracres

14.4 Frequency of Board of Directors MeetingsMonthly

12

13

14

Page 30: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

15.1 Regulated JurisdictionsUnited Kingdom

15.2 Regulatory Body ReviewN/A

15.3 Disciplinary Action by RegulatorsN/A

15.4 Client ComplaintsWithin the last 3 years: 0

15.5 Retail Distribution ReviewTavistock Wealth does not provide advice to clients.

INVESTMENT SERVICES & PROCESSES

REGULATION AND INSURANCE

Page | 27

DISCRETIONARY CLIENT RELATIONSHIPS

16.1 Primary Point of ContactTavistock Wealth does not maintain relationships with clients. A client’s primary point of contact is their financial adviser, who is responsible for managing the client relationship and the suitability of their investment strategy.

16.2 Discretionary Clients Relationships>8,000

16.3 Average Discretionary Client Size£50,000 - £100,000

16.4 What is the smallest discretionary client size considered?ACUMEN Portfolio minimum investment: £100Tavistock PROFILE: No minimum investment

16.5 What percentage of AUM is accounted for by the 5 largest clients?<1.00%

CHARIT Y RELATIONSHIPS

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Page 31: DUE DILIGENCE QUESTIONNAIRE - TAVISTOCK WEALTH...DISCLAIMER The information given herein is correct as of March 2019. This document was completed by Ben Raven. TAVISTOCK WEALTH LTD

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