VIBHS Financial Ltd hereinafter known as "the Company", "the Firm" or "we", is fully committed to compliance with the requirements of the General Data Protection Regulation (Regulation (EU) 2016/679), which came into force on 25th May 2018.
The Firm is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and stored by the Firm. Please read the following carefully to understand our views and practices regarding your personal data and how the Company will treat it. By using our website, you are agreeing to be bound by this Policy, however, you are free to withdraw your consent anytime by notifying us.
For the General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR'), the data controller is VIBHS Financial Ltd
We know that you are concerned with how we deal with your personal information. This privacy statement sets out our current policies and demonstrates our commitment to your privacy. Our privacy policy may change at any time in the future for compliance purposes. You agree to revisit this page regularly and your continued access to or use of the Website will represent your consent to these changes.
We are required to maintain certain personal data about individuals for the purposes of satisfying our operational and legal obligations (to open an account, client due diligence, money laundering prevention, transact business effectively and to safeguard your assets and your privacy). We recognise the importance of correct and lawful treatment of personal data as it helps to maintain confidence in our organisation and to ensure efficient and successful outcomes when using this data.
We only use personal information as legally appropriate to provide you with a high quality of service and security. We may use the personal data collected from you to verify your identity and contact information. We may also use this information to establish and set up your trading account, issue an account number and a secure password, maintain your account activity, and contact you with account information. This information helps us improve our services, satisfy financial regulation and inform you about new products, services or promotions that may be of interest to you.
Personal data may consist of data kept on paper, computer or other electronic media; all of which is protected under the GDPR.
All data is :
We may collect and process the following data about you:
The types of personal data that we may process, for instance, include information about current, past and prospective clients and customers, website visitors, etc. with whom we have dealings. This information includes information required to communicate with you, including your name, mailing address, telephone number, email address, date of birth, ID and your location information.
We may also ask you for information when you report a problem with the Site. If you contact us, we may keep a record of that correspondence. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
You have choices about the data we collect. When you are asked to provide personal data, you may decline. You are also entitled to have the Firm erase your personal data, cease further dissemination of the data and potentially have third parties halt processing of the data. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal however, if you choose not to provide data that is necessary to provide a service or feature or to withdraw the data that is still relevant to original purposes of processing, you may not be able to use that service or feature.
The data we collect depends on the context of your interactions with the Company, the choices you make, including your privacy settings, and the service and features you use.
Cookies are small text files sent from the Web server to your computer. We use cookies to assist us in securing your trading activities and to enhance the performance of our Website. Cookies used by us do not contain any personal information, nor do they contain account or password information. They merely allow the site to recognise that a page request comes from someone who has already logged on.
We may share Website usage information about visitors to the Website with reputable advertising companies for targeting our Internet banner advertisements on this site and other sites. For this purpose, pixel tags (also called clear GIFs or web beacons), may be used to note the pages you've visited. The information collected by the advertising company using these pixel tags is not personally identifiable.
To administer and improve our Website, we may use a third party to track and analyse usage and statistical volume information including page requests, form requests, and click paths. The third party may use cookies to track behavior and may set cookies on behalf of us. These cookies do not contain any personally identifiable information.
We share your personal data with your consent or as necessary to complete any transaction or provide any service you have requested or authorised. We also share data with:
We may share information with affiliates if the information is required to provide the product or service you have requested, or to provide you with the opportunity to participate in the products or services our affiliates offer. We may also forge partnerships and alliances, which may include joint marketing agreements, with other companies who offer high-quality products and services that might be of value to our Customers.
To ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, we may share some information with partners, affiliates and alliances. This allows them to better understand the offers that are most relevant and useful to yourself. The use of your personal information is limited to the purposes identified in our relationship with the partner or affiliate.
We do not sell, license, lease or otherwise disclose your personal information to any third party for any reason, except as described below.
We reserve the right to disclose your personal information to third parties when required to do so by law to regulatory, law enforcement or other government authorities. We may also disclose your information as necessary to credit reporting or collection agencies. We may also disclose your information to non-affiliated third parties if it is necessary to protect the Company's rights or property.
To help us improve our services to you, we may engage another business to help us to carry out certain internal functions such as account processing, fulfillment, client service, client satisfaction surveys or other data collection activities relevant to our business. We may also provide a party with Customer information from our database to help us to analyse and identify Customer needs and notify Customers of product and service offerings.
Use of the shared information is strictly limited to the performance of the task we request and for no other purpose. All third parties with which we share personal information are required to protect personal information in a manner similar to the way we protect personal information. We use a variety of legal mechanisms, including contracts, to help insure your rights and protections.
Restriction of responsibility
If at any time you choose to purchase a product or service offered by another company, any personal information you share with that company will no longer be controlled under our Privacy Policy. We are not responsible for the privacy policies or the content of sites we link to and have no control of the use or protection of information provided by you or collected by those sites.
Whenever you elect to link to a co-branded Web site or to a linked Web site, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party, and you should familiarise yourself with the privacy policy provided by that third party.
All individuals who are the subject of personal data held by us are entitled to:
If you cannot access certain information and personal data collected by the Firm, you can always contact the Company at [email protected]. We will respond to requests to access or delete your personal data within 30 days.
In the case of a personal data breach, the Company shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority- Information Commissioner's Office, UK (ICO)unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification to ICO is not made within 72 hours, it shall be accompanied by reasons for the delay according to the Article 33 of GDPR.
Personal data collected by the Company may be stored and processed in your region or in any other country where the Company or its affiliates, subsidiaries or service providers maintain facilities. Typically, the primary storage location is in the client's region or in the UK, often with a backup to a datacentre in another region.
The storage location(s) are chosen to operate efficiently, to improve performance, and to create redundancies to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.
We transfer personal data from the European Economic Area to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data.
The Company retains personal data for as long as necessary to provide the services, or for other essential purposes such as complying with our legal obligations, including as an authorised financial services provider, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of various products, actual retention periods may vary significantly. The criteria used to determine the retention periods include, for example:
From time to time, we may update this Privacy Policy. In the event we materially change this Privacy Policy, the revised Privacy Policy will promptly be posted to the websites and we will post a notice on our websites informing you of such changes.
You agree to accept posting of a revised Privacy Policy electronically on the Website as actual notice to you. Any dispute over our Privacy Policy is subject to this notice and our Customer Agreement.
We encourage you to periodically check and review this policy so that you will always know what information we collect, how we use it, and to whom we disclose it. If you have any questions that this statement does not address, please contact us via [email protected]..
If you have a privacy concern, complaint or a question for the Data Protection Officer, please contact us via [email protected].. We will respond to questions or concerns within 30 days.
Unless otherwise stated, the Firm is a data controller for personal data we collect through the services subject to this statement. The Company is a private limited company under Companies House number 08279988 The registered office at Amlbenson The Long Lodge, 265-269 Kingston Road, Wimbledon, England, SW19 3NW The Firm's Compliance Officer is also the person responsible for data protection as the Data Protection Officer. The address for correspondence is 11-12 Token House Yard, London, EC2R 7AS. Telephone: 020 7709 2038.
In this Risk Disclosure Notice, "we", "our" or "us" shall mean VIBHS Financial Ltd, a company registered in England and Wales under company number 08279988, registered office at Amlbenson The Long Lodge, 265-269 Kingston Road, Wimbledon, England, SW19 3NW. We are authorised and regulated by the Financial Conduct Authority ("FCA") under Firm Reference Number 613381. In this Risk Disclosure Notice, "you" or "your" shall mean you as the client.
This Risk Disclosure Notice is provided to you, as a Retail Client, in compliance with the rules of the FCA. Retail Clients are afforded the most protections under these rules.
This notice cannot disclose all the risks and other significant aspects of products such as futures, options, interests in investments and contracts for differences. You should not deal in these products unless you understand their nature and the extent of your exposure to risk. You should also be satisfied that the product is suitable for you in the light of your circumstances and financial position. Certain strategies, such as a 'spread' position or a 'straddle', may be as risky as a simple 'long' or 'short' position.
Although derivative instruments can be utilised for the management of investment risk, some of these products are unsuitable for many investors. Different instruments involve different levels of exposure to risk and in deciding whether to trade in such instruments you should be aware of the following points.
Transactions in futures involve the obligation to make, or to take, delivery of the underlying asset of the contract at a future date, or in some cases to settle the position with cash.
They carry a high degree of risk. The 'gearing' or 'leverage' often obtainable in futures trading means that a small deposit or down payment can lead to large losses as well as gains. It also means that a relatively small movement can lead to a proportionately much larger movement in the value of your investment, and this can work against you as well as for you.
Futures transactions have a contingent liability, and you should be aware of the implications of this, in particular the margining requirements, which are set out in paragraph 7 below.
There are many different types of options with different characteristics subject to the following conditions.
Buying options involves less risk than selling options because, if the price of the underlying asset moves against you, you can allow the option to lapse. The maximum loss is limited to the premium, plus any commission or other transaction charges however, if you buy a call option on a futures contract and you later exercise the option, you will acquire the future. This will expose you to the risks described in paragraphs 2 and 7.
If you write an option, the risk involved is considerably greater than buying options. You may be liable for margin to maintain your position and a loss may be sustained well in excess of the premium received. By writing an option, you accept a legal obligation to purchase or sell the underlying asset if the option is exercised against you, however far the market price has moved away from the exercise price. If you already own the underlying asset which you have contracted to sell (when the options will be known as 'covered call options') the risk is reduced. If you do not own the underlying asset ('uncovered call options') the risk can be unlimited. Only experienced persons should contemplate writing uncovered options, and then only after securing full details of the applicable conditions and potential risk exposure.
Certain London Stock Exchange member firms under special exchange rules write a particular type of option called a 'traditional option'. These may involve greater risk than other options. Two-way prices are not usually quoted and there is no exchange market on which to close out an open position or to affect an equal and opposite transaction to reverse an open position. It may be difficult to assess its value or for the seller of such an option to manage his exposure to risk.
Certain options markets operate on a margined basis, under which buyers do not pay the full premium on their option at the time they purchase it. In this situation you may subsequently be called upon to pay margin on the option up to the level of your premium. If you fail to do so as required, your position may be closed or liquidated in the same way as a futures position.
Futures and options contracts which are settled in cash can also be referred to as contracts for differences. These can be options and futures on the FTSE 100 index or any other index, as well as currency and interest rate swaps. However, unlike other commodity futures and options, these contracts can only be settled in cash.
Investing in a contract for differences carries the same risks as investing in a future or an option and you should be aware of these as set out in clauses 2 and 3 respectively.
Transactions in contracts for differences may also have a contingent liability and you should be aware of the implications of this as set out in clause 7.
It may not always be apparent whether or not a particular derivative is arranged on exchange or in an off-exchange derivative transaction. We should make it clear to you if you are entering into an off-exchange derivative transaction.
While some off-exchange markets are highly liquid, transactions in off-exchange or 'non-transferable' derivatives may involve greater risk than investing in on-exchange derivatives because there is no exchange market on which to close out an open position. It may be impossible to liquidate an existing position, to assess the value of the position arising from an off-exchange transaction or to assess the exposure to risk.
Bid prices and offer prices need not be quoted, and, even where they are, they will be established by dealers in these instruments and consequently it may be difficult to establish what a fair price is.
Foreign markets may involve different risks from UK markets. In some cases the risks will be greater. On request, we should provide an explanation of the relevant risks and protections (if any) which will operate in any foreign markets, including the extent to which we will accept liability for any default of a foreign firm through whom we deal.
The potential for profit or loss from transactions on foreign markets or in foreign denominated contracts will be affected by fluctuations in foreign exchange rates.
Contingent liability investment transactions, which are margined, require you to make a series of payments against the purchase price, instead of paying the whole purchase price immediately.
If you trade in futures contracts for differences or sell options, you may sustain a total loss of the margin you deposit with us to establish or maintain a position. If the market moves against you, you may be called upon to pay substantial additional margin at short notice to maintain the position. If you fail to do so within the time required, your position may be liquidated at a loss and you will be responsible for the resulting deficit.
Even if a transaction is not margined, it may still carry an obligation to make further payments in certain circumstances over and above any amount paid when you entered the contract.
Save as specifically provided by the FCA, we may only carry out margined or contingent liability transactions with or for you if they are traded on or under the rules of a recognized or designated investment exchange. Contingent liability investment transactions which are not so traded may expose you to substantially greater risks.
Before entering into a limited liability transaction, you should obtain from us a formal written statement confirming that the extent of your loss liability on each transaction will be limited to an amount agreed by you before you enter into the transaction.
The amount you can lose in limited liability transactions will be less than in other margined transactions, which have no predetermined loss limit nevertheless, even though the extent of loss will be subject to the agreed limit, you may sustain the loss in a relatively short time. Your loss may be limited, but the risk of sustaining a total loss to the amount agreed is substantial.
If you deposit collateral as security with us, the way in which it will be treated will vary according to the type of transaction, the type of client categorization you fall within, and where it is traded. There could be significant differences in the treatment of your collateral depending on whether you are trading on a recognized or designated investment exchange, with the rules of that exchange (and the associated clearing house) applying, or trading off-exchange, and whether you are a Retail Client or otherwise (please see clause 2.2 of the Client Agreement for further information). Deposited collateral may lose its identity as your property once dealings on your behalf are undertaken.
Even if your dealings should ultimately prove profitable, you may not get back the same assets which you deposited, and may have to accept payment in cash. You should ascertain from us how your collateral will be dealt with before depositing collateral with us.
Before you begin to trade, you should obtain details of all commissions and other charges for which you will be liable. If any charges are not expressed in money terms (but, for example, as a percentage of contract value), you should obtain a clear and written explanation, including appropriate examples, to establish what such charges are likely to mean in specific money terms. In the case of futures, when commission is charged as a percentage, it will normally be as a percentage of the total contract value, and not simply as a percentage of your initial payment.
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. Placing a stop-loss order will not necessarily limit your losses to the intended amounts, because market conditions may make it impossible to execute such an order at the stipulated price.
On many exchanges, the performance of a transaction by us (or third party with whom we are dealing on your behalf) is 'guaranteed' by the exchange or clearing house. However, this guarantee is unlikely in most circumstances to cover you, the client, and may not protect you if we or another party defaults on its obligations to you. On request, we should explain any protection provided to you under the clearing guarantee applicable to any on-exchange derivatives in which you are dealing. There is no clearing house for traditional options, nor normally for off-exchange instruments which are not traded under the rules of a recognized or designated investment exchange.
Our 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. On request, we should provide you with an explanation of the extent to which we will accept liability for any insolvency of, or default by, other firms involved with your transactions.
If after reading this document, you do not understand any of the risk warnings set out above, please contact us before continuing or seek advice from an independent financial services advisor.
VIBHS Financial Ltd (the "Firm" or "we") is a MiFID investment firm authorised and regulated by the Financial Conduct Authority (FCA). We are required to comply with the disclosure requirements under the Investment Firms Prudential Regime (IFPR), which is set out in the FCA Handbook MIFIDPRU 8. This supersedes the previous Pillar 3 disclosure.
For the purpose of prudential regulations, we are classified as a "non-SNI (small and non-interconnected) firm and are subject to the basic and standard requirements. We are required to provide a level of detail in our disclosures that is appropriate to our size and internal organisation, and to the nature, scope, and complexity of our activities.
The firm is owned by PiyushKumar Vinodbhai Parekh, and it operates its own website and the platforms, proprietary software, staff, and support services that enable the firm to provide their respective regulated services to the United Kingdom.
The firm is not part of a consolidation group.
The firm’s Board of Directors (the "Board") is responsible for the oversight of the implementation of the strategic objectives, risk strategy, and internal governance arrangements of the Firm.
As of 31.03.2024, the number of directorships held by each member of the Board is as follows:
Name | Number of Directorship Positions Held | ||
---|---|---|---|
Executive | Non-Executive | Total | |
Piyushkumar Vinodbhai Parekh (SMF 3) Guy Ian Oliver Riches (SMF3) |
2 | 0 | 2 |
Kirit Balubhai Mistry | 1 | 0 | 1 |
The Board meets every quarterly months and receives reports on investment, operations, financial, risk, legal, and compliance matters.
The Firm’s board has one committee:
The Risk and Compliance Committee (RCC), oversees the firm's risk management framework and compliance framework.
All staff resources for the firm’s activities are managed by in-house staff members and certain secondary functions are outsourced to third-party service providers. The outsourced service providers are as follows.
In accordance with MIFIDPRU 4.3.2, VIBHS must at all times maintain own funds that are at least equal to its own fund’s requirement.
As a Non-SNI firm, the Firm is required to maintain an amount of own funds that is the higher of the:
The below table shows the Own Funds requirement in further detail.
Overall financial adequacy rule (OFAR) | |
---|---|
Permanent minimum requirement (PMR) | £330K (Transitioning to £750K by Jan 2027) |
Fixed overhead requirement (FOR) | £121K |
K- Factor requirement | £1K |
MIFIDPRU TP 2 Own funds requirements: transitional provision 2.18
The K-Factor requirements consider the Risk of Harm to Clients (RtC), Markets (RtM) and the Firm (RtF) and these are broken down as follows:
K-Factor requirement | Amount (£000) |
---|---|
The sum of the K-AUM, K-CMH and K-ASA requirements | 1 |
The sum of the K-COH and K-DTF requirements | N/A |
The sum of the K-NPR, K-CMG, K-TCD, and K-CON requirements | N/A |
Total | 1 |
Assets Under Management (“K-AUM”), Client Orders Handled (“K-COH”), Cleared Margin Given (“K-CMG”), and Concentration Risk (“K-CON”) Assets Safeguarded and Administered (“K-ASA”), Daily Trading Flow (“K-DTF”), Trading Counterparty Default (“K-TCD”) and Net Position Risk (“K-NPR”) are not applicable for VIBHS.
The K-Factor requirements applicable for the Firm is:
• Client Money Held (“K-CMH”)
The Firm must, at all times, hold its own funds and liquid assets which are adequate, both to their amount and their quality, to ensure that the Firm is able to remain financially viable throughout the economic cycle and be able to address any material potential harm that may result from its ongoing activities; and to ensure that the firm's business can be wound down in an orderly manner, minimising harm to consumers or to other market participants.
As a result of the introduction of the IFPR, the Firm has conducted and documented its Internal Capital Adequacy and Risk Assessment process (ICARA) to identify whether the Firm complies with the above mentioned overall financial adequacy rule. The Firm may hold additional own funds or additional liquid assets above the Firm's own funds requirement or basic liquid assets requirement to manage the potential harms identified.
The Firm's ICARA is reviewed and approved by the Board at least annually, or more often as deemed appropriate.
The firm is required to comply with the MIFIDPRU Remuneration Code under IFPR, which aims to ensure that we have risk-focused remuneration policies that are consistent with and promote sound and effective risk management in the long-term interests of the Firm and our customers.
We have formulated our approach to the remuneration policy and practices with reference to the guidance set out by the FCA.
The firm's remuneration policy has been created and is reviewed annually by the Compliance officer it aims to promote sound and effective risk management, encourage responsible business conduct, limit risk-taking and avoid conflicts of interest, align employee's interests with the firm's long-term strategy and objectives, and to be gender neutral, in line with the Equality Act 2010.
AII staff receive fixed remuneration in the form of base salary.
Base Salary
We review the base salary of our staff members on an annual basis by considering factors such as market information and individual performance.
Material risk takers are those staff members and members of Senior Management who have a material impact on the Firm's risk profile.
The firm does not have any material risk-takers.
For the financial year ended 31.03.2024, the amount of remuneration awarded by VIBHS is as follows:
Total remuneration | £ |
---|---|
Fixed remuneration | 347,851 |
For the financial year ended 31.03.2024, the amount of remuneration awarded is as follows:
Total | Senior Management | Other material risk takers | Other staff | |
---|---|---|---|---|
Total remuneration | £347,851 | £222,000 | £0 | £125,851 |
Fixed remuneration | £347,851 | £222,000 | £0 | £125,851 |
The own funds amount for the firm derives from common equity tier 1 capital (“CET1”), comprising from share capital and retained earnings. Further detail of this can be seen in the below tables.
Item | Amount (£'000) | Source based on reference numbers/letters of the balance sheet as at 31 August 2024 |
---|---|---|
OWN FUNDS | 335 | |
TIER 1 CAPITAL | ||
COMMON EQUITY TIER 1 CAPITAL | 335 | |
Fully paid-up capital instruments | 2970 | I |
Share premium | ||
Retained earnings | (2597) | II |
Accumulated other comprehensive Income | ||
Other reserves | 80 | III |
Adjustments to CET1 due to prudential Filters | ||
Current year losses | (118) | IV |
(-) TOTAL DEDUCTIONS FROM COMMON EQUITY TIER 1 | ||
CET1: Other capital elements, deductions and adjustments | ||
ADDITIONAL TIER 1 CAPITAL | 000 | |
Fully paid up, directly issued capital Instruments | ||
Share premium | ||
(-) TOTAL DEDUCTIONS FROM ADDITIONAL TIER 1 | ||
Additional Tier 1: Other capital elements, deductions, and adjustments | ||
TIER 2 CAPITAL | 000 | |
Fully paid-up, directly issued capital Instruments | ||
Share premium | ||
(-) TOTAL DEDUCTIONS FROM TIER 2 | ||
Tier 2: Other capital elements, deductions and adjustments |
Item | Balance sheet as at 31 August 2024 Amount as at period end (£'000) |
Cross-reference to 5 Annexure 1 |
---|---|---|
ASSETS | ||
Non-Current Asset | ||
1 Tangible Assets | 8 | |
2 Licenses | 80 | |
Current Assets | ||
1 Trade and other receivables (Debtors) | 137 | |
2 Cash at bank | 209 | |
TOTAL ASSETS | 434 | |
LIABILITIES | ||
Current Liabilities | ||
1 Trade creditors | 50 | |
2 Social Security and other taxes | 11 | |
3 Other payables | 24 | |
4 Accrued expenses | 14 | |
TOTAL LIABILITIES | 99 | |
SHAREHOLDERS' EQUITY | ||
1 Share capital | 2970 | I |
2 Retained earnings | (2597) | II |
3 Other Reserves | 80 | III |
4 Current year losses | (118) | IV |
Total Shareholders' equity | 335 | |
TOTAL EQUITY AND LIABILITIES | 434 |
VIBHS Financial Ltd (the "Firm" or "we") is a MiFID investment firm authorised and regulated by the Financial Conduct Authority (FCA). For the purpose of prudential regulations, we are classified as a "non-SNI (small and non-interconnected) firm] and are subject to the basic and standard requirements. We are required to provide a level of detail in our disclosures that is appropriate to our size and internal organisation, and to the nature, scope, and complexity of our activities.
This remuneration policy outlines the principles and practices for determining the remuneration of employees at VIBHS Financial Ltd. The policy is designed to ensure that our approach to compensation is consistent with sound risk management and complies with the requirements of the FCA’s MIFIDPRU Remuneration Code (MIFIDPRU 7) while being proportionate to the size, nature, and complexity of the firm.
This policy applies to all employees of VIBHS Financial Ltd.
Remuneration at VIBHS Financial Ltd consists of only Fixed Pay (Salary): All staff receive a fixed salary, which reflects the role, responsibilities, and experience of the individual.
The Board of VIBHS Financial Ltd is responsible for overseeing the remuneration of all employees. The firm does not have a formal remuneration committee, as it is not required given our size and the absence of material risk-takers. The Board ensures that remuneration decisions are consistent with the firm’s risk management and long-term objectives.
Given the size and nature of VIBHS Financial Ltd, we apply the FCA’s remuneration principles in a proportionate manner.
The following elements are not applicable due to the absence of material risk-takers:
As required by the MiFIDPRU 8 rules, VIBHS Financial Ltd will disclose key information about its remuneration policy, including the link between pay and performance and the overall governance of the remuneration process.
This policy will be reviewed annually by the Board to ensure it remains appropriate for the firm’s size, activities, and regulatory obligations.
Approved by the Board of VIBHS Financial Ltd
This template is a straightforward policy that reflects the firm’s small size and the FCA’s proportionate approach under the MIFIDPRU framework.
Welcome to VIBHS Financial Ltd, we would like to introduce you to our Best Execution Policy. This policy is designed to ensure that we're consistently striving to give you the best possible outcome when it comes to your financial transactions. This policy operates in conjunction with our Compliance Manual and The Firm’s other policies.
Our Compliance Officer is primarily responsible for overseeing the policy. In their absence, a designated deputy - this could be our Managing Director, another Director, or the Compliance Assistant - steps in to ensure seamless continuity.
The language used in our policy aligns with definitions provided in the FCA Handbook’s Glossary. If you need any further clarification, don't hesitate to reach out to our Compliance Department.
This policy is approved by The Firm's Executive Management and periodically reviewed by the Compliance Officer.
We've established a robust system for monitoring adherence to the policy, using a -tiered defence mechanism. The first line of defence involves systematic testing and monitoring by the brokerage department's line management. Our Compliance Officer provides the second line of defence, providing an additional layer of scrutiny. The third line of defence includes health checks and internal audits to evaluate potential weaknesses and maintain overall health checks as The Firm evolves and grows.
VIBHS Financial Ltd is authorised and regulated by the FCA under Firm Reference Number 613381 as a Matched Principal Broker. We're registered in England and Wales under Company number 08279988. By agreeing to the terms of this Policy, you're acknowledging your agreement with the terms and conditions of the company.
In line with the Markets in Financial Instruments Directive (MiFID II) and Section 11.2A of the FCA’s Conduct of Business Sourcebook (COBS), we strive to achieve the best execution for our clients. However, we cannot guarantee that our execution price will always be the best available.
The Firm senior management and Compliance department are dedicated to ensuring robust business practices in all client trading activities and aim to provide the best execution consistently. We select electronic trading platforms that can provide you with the best execution, considering various factors including the nature of your orders, market prices, and the nature of the market in question. We aim to provide all market participants with access to tradable prices on a non-discriminatory basis, taking into account the diversity in markets and instruments, and the type of orders you may place.
To understand COBS 11.2A, it's important to understand its roots. The FCA's best execution requirements encapsulated in these rules came into being as part of the UK's incorporation of MiFID II. Here are some notable milestones in its development:
COBS 11.2A rules apply primarily to firms conducting investment business in the UK. The focus is on those that execute orders on behalf of clients, transmit client orders to other entities, or manage client portfolios.
The principal duty of a firm is to take all appropriate steps to ensure the best possible outcome for its clients when executing orders. However, if a client gives a specific instruction about an order, The Firm may be exempted from this obligation.
Several factors come into play during order execution, including price, costs, speed, likelihood of execution, and Size & Nature. For retail clients, the most significant elements are usually price and costs.
For retail clients, the best possible outcome shall be determined in terms of the total consideration, representing the price of the financial instrument and the costs related to execution, which shall include all expenses incurred by a client which are directly related to the execution of the order, including clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.
When executing an order for a retail client, the best possible result must be determined in terms of the total cost - the price of the financial instrument and all costs related to execution.
The FCA advises that positive price changes between order submission and execution should be passed on to the client and that positive slippage should be passed on to the client which is a positive difference between order submission price and execution price.
Using only a single venue for executing orders is permissible if it can be demonstrated that this approach consistently provides the best outcome for clients.
In case a client provides specific instructions, The Firm must follow these instructions while executing the order.
The Firm must establish effective arrangements and implement an execution policy to ensure the best possible result for its clients.
The Firm keep records of its transactions to demonstrate to clients and the FCA that it has executed orders in line with its execution policy.
The company's obligation to provide “Best Execution” does not apply if a client is classified as an Eligible Counterparty or provides specific instructions regarding the execution of their order.
The company deals with Retail Clients, Professional Clients, and Eligible Counterparties as defined by MiFID and FCA handbook rules.
The Company decides which financial instruments to offer and sets their prices. Through the Trading Platform, we provide you with live prices from our third-party liquidity providers via our Prime Brokers. As a "Matched Principal Broker", we're the other party to every trade. This means if you open a position with us, you can only close it with us.
Our Prime Broker gets its Spot FX prices from various liquidity providers in the wholesale market. Even though we send your orders to our Prime Broker for execution, we're the sole counterparty to your trades. Thus, we're the only Execution Venue for your orders. When choosing our Prime Brokers, we made sure they could give the best outcome for our clients. Some of the factors we considered are:
We do due diligence when starting a relationship with a Prime Broker, throughout the relationship, and on an annual basis. We work with Prime Brokers and liquidity providers who are known for their strong compliance and legal records, financial stability, and extensive industry experience.
We quote two prices for each financial instrument: the higher "Ask" price at which you can buy and the lower "Bid" price at which you can sell. The difference between the Bid and Ask prices is the "Spread". Certain orders are executed at the Ask price, and others at the Bid price. We always try to ensure that the price offered to the client are reasonable in comparison to the market rates. We do this by comparing market data and historical prices for the same product or comparing the product against similar products.
it is also possible that factors such as market data latency, the speed of a client’s internet connection or high market volatility can lead to price slippage. This could result in favour or to the detriment of the client, and it is outside of The Firm’s control.
All orders are transmitted to our Prime Brokers for execution. The system automatically gets a quote from a selection of liquidity providers. The technology provider will then aggregate all available liquidity at the best possible prices. We continuously check our Prime Brokers to ensure they're consistently obtaining best execution from their liquidity providers. You can request a copy of the Prime Broker’s Best Execution Policy at any time. The costs related to executing Client orders are outlined in the Client Agreement. We'll disclose all costs related to the execution of the Client Order.
We make all costs transparent and fully disclose them to you. You might need to pay commission charges for opening and closing trades, but we'll always tell you about these costs in advance. We'll agree on a fee structure with you once your trading account has been approved.
We don’t receive 'Payment for Order Flow', meaning we don’t get paid to send orders to particular execution venues. We earn our money from the commissions and charges for spread you pay when you trade.
We might change our fees, but we'll let you know in advance. We'll also always let you know about any third-party charges or fees.
A Market Order is an order to buy or sell at the best available price. It's typically filled promptly during operating hours. However, during periods of high market volatility or low liquidity, there might be delays or a difference in the price quoted and the price at which the order is filled (slippage). We cannot therefore guarantee the specific execution price of a Market Order.
A Limit Order is an order to buy or sell a financial instrument at a specific price or better. It might not be filled if the market doesn’t reach the specified price. A Limit Order to buy is placed below the current market price. A Limit Order to sell is placed above the current market price. This type of order is used when you believe the price will change direction at a certain level.
A Stop Order is an order to buy or sell once the price of a financial instrument reaches a specified price, known as the stop price. When the stop price is reached, a Stop Order becomes a Market Order. This type of order is used when you want to limit your losses or protect your profits on a position.
If you give us a specific instruction about an order, we'll execute it accordingly. However, please note that by doing so, we may not be able to achieve the best possible result for your order in relation to the elements of our best execution policy that are affected by those instructions.
All orders are handled and executed in accordance with our Order Execution Policy. The order handling process depends on the type of order you place and the market conditions at the time. It's your responsibility to understand how your orders will be executed.
The Firm’s back office team monitor our execution quality and the fairness of the price proposed to the client . We also review our execution policies and arrangements regularly . You have a right to ask for information about how your orders are handled and executed. Any instance where trade has failed to be booked or has been booked incorrectly is recorded in the Trading Error Register.
We’ll provide you with a comprehensive trade report on a daily basis. This report shows your trade activity, the prices you received, and any fees you paid.
We'll review this policy at least once a year. We might make changes if we identify a need for improvement, or if there are changes in the relevant laws or market conditions. Any changes we make will be posted on our website, and we'll notify you by email.
The variety of orders that our clients may place include:
Each type of order is executed in accordance with our Best Execution Policy. It's important to highlight that, under abnormal market conditions, the executed price of a trade may significantly deviate from the originally requested price. Such circumstances might arise during market opening, news releases, volatile markets, rapid price movements, or if there is insufficient liquidity for the execution of a specific volume at the declared price.
The Firm will proceed directly to a prompt settlement of transactions on the execution of each transaction.
The minimum lot size for Foreign Exchange transactions is 1,000 units of base currency. While there's no upper limit for order size, we retain the right to decline any order as specified in the client agreement. We strive to fill the client's order irrespective of the volume, at the best available price based on the market liquidity at the time of execution.
The size and nature of a client's order may have an impact on the market, a factor over which we have no control. .
In line with MiFID II regulations, we are required to establish and implement a Best Execution Policy to ensure the best possible result for client orders. Our policy must be clearly disclosed to our clients, and we are required to obtain their prior consent. We provide all the relevant information regarding our Best Execution policy, the selection of execution venues, and potential inducements. Clients are notified of any material changes to our execution arrangements or best execution policy. Our operation time is continuous from 22:00 GMT Sunday through to 22:00 GMT Friday. Non-operating periods are 22:01 GMT Friday through to 21:59 GMT Sunday. Bank Holidays will be announced via email.
Lastly, we want to remind our clients that transactions entered in financial instruments with us are not undertaken on a recognized exchange and they may be exposed to greater risks than regulated exchange transactions. The Company may not execute an order, or it may change the opening or closing price of an order in certain cases, including but not limited to, instances of a technical failure of the trading platform.
We need your consent to carry out our execution policies. This means when we execute orders, we have to get your agreement first.
If we decide to execute orders outside a trading venue, we need your explicit consent before going ahead. You can give us this consent either as a general agreement or for individual transactions. When we execute your orders, we'll tell you where it was done.
Keep in mind that some of our products may not be available for sale in all jurisdictions or countries. Our Best Execution Policy isn't meant for any place where its publication, availability, or distribution goes against local laws, including the USA.
The Best Execution Policy doesn't mean we're asking or inviting you to buy or sell CFDs or other derivative instruments. This policy shouldn't be the only thing you use to decide whether or not to trade in CFDs or other derivatives.
We only provide you with access to our Trading Platform; we're not acting as your agent or fiduciary. While we're committed to giving you the best execution, we don't owe you any extra fiduciary duties besides specific regulatory obligations or any contracts between us. You're responsible for your investment decisions, and we're not liable for any trading losses you might suffer from those decisions.
If you instruct us to execute an order in a certain way, it might prevent us from getting the best possible outcome for you. It could also prevent us from following our Best Execution Policy, which aims to get the best overall outcome for consistently executing orders.
If a trade fails (like a system failure) or there's a dealing error (the trade was executed incorrectly), and it's our fault, we'll make sure you're not disadvantaged. We keep a record of failed trades and dealing errors, managed by the Compliance Officer.
We don't keep records of trades that settle late but ultimately settle as per the original instructions, as these don't cause any loss. But if there is a loss or if the trade fails, we'll follow the procedure mentioned above.
The Firm’s Best Execution policy aligns with the FCA's New Consumer Duty, prioritising the customer's best interest and outcome at every stage of our operations.
Our policy guarantees the best possible outcome when executing client orders, considering aspects such as price, cost, speed, likelihood of execution and settlement, size, nature, and other relevant factors.
We commit to clear communication and transparency in our execution practices, disclosing key information about costs and risks to ensure fair treatment of consumers.
Consistent with the Consumer Duty's focus on consumer outcomes, we conduct rigorous, ongoing reviews of our Best Execution policy, constantly adapting to meet the evolving needs of our consumers and maintain the highest service standard.
Our policy, designed in line with the 'Acting in the Best Interests of Consumers' principle of the Consumer Duty, prioritises delivering optimal results and high customer satisfaction.
In summary, our Best Execution policy and broader operations not only adhere to FCA regulations but strive to exceed them, underscoring our commitment to serving our customers' best interests.
Usage of this Complaints policy must be in conjunction with VIBHS Financial Limited's ("VIBHS") Compliance Regulations Manual and other company policies and procedures currently in effect and those yet to be introduced.
Reference to the Compliance Officer throughout this policy includes in his absence, his appointed deputy. For the benefit of clarity an appointed deputy will be defined as any one person from:
(i) The Managing Director (“MD”), being a Financial Conduct Authority (“FCA”) Approved Person;
(ii) In the absence of (i) above, another Director of VIBHS, also being an FCA Approved Person and in association with (iii) below;
(iii) The Compliance Assistant (if required).
References to the masculine include the feminine. Items in italics have their essence defined in the FCA's Glossary. Refer to the Compliance department if you require further information. This Complaints policy must not be reproduced or provided to third parties without prior reference to the Compliance Officer and their subsequent approval.
This policy is sponsored by VIBHS' Executive Management and will be maintained by the company's Compliance Officer, therefore any queries and /or suggestions for change should be addressed to the firm's Compliance Officer.
VIBHS is currently authorised and regulated by the FCA under Firm Reference Number ("FRN") 613381.
A complaint for the purpose of this policy is defined as any oral or written expression of dissatisfaction whether justified or not, from or on behalf of a person about the provision of, or failure to provide, a financial service or a redress determination which:
(i) Alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and
(ii) Relates to an activity of that respondent or of any other respondent with whom that respondent has some connection in marketing or providing financial services or products which comes under the jurisdiction of the Financial Ombudsman Service ("FOS").
It should also be noted that under the FCA's Dispute Resolution ("DISP") Sourcebook Rule DISP 1.1.10R In relation to VIBHS' obligations under this chapter, references to a complaint also include an expression of dissatisfaction which is capable of becoming a relevant new complaint being a complaint referred to FOS after commencement which relates to an act or omission occurring before commencement if:
(i) The act or omission is that of a person who was immediately before commencement, subject to a former scheme;
(ii) The act or omission occurred in the carrying on by that person of an activity to which that former scheme applied; and
(iii) The complainant is eligible and wishes to have the complaint dealt with under the new scheme. (Where the complainant is not eligible in accordance with DISP 2 (Jurisdiction of the Financial Ombudsman Service), an Ombudsman may if they consider it appropriate, treat the complainant as eligible if they would have been entitled to refer an equivalent complaint to the former scheme in question immediately before commencement.
Under DISP 1.2.1R to aid consumer awareness of the protections offered by the provisions in this chapter VIBHS must:
(i) Publish appropriate information regarding their internal procedures for the reasonable and prompt handling of complaints;
(ii) Refer eligible complainants to the availability of this information;
(iii) Provide such information in writing and free of charge to eligible complainants:
On request; and
When acknowledging a complaint
These summary details should cover at least how VIBHS fulfills its obligation to handle and seek to resolve relevant complaints and that if the complaint is not resolved, the complainant may be entitled to refer it to FOS.
A complaint may only be dealt with under FOS if it is brought by or on behalf of an eligible complainant. A complaint may also be brought on behalf of an eligible complainant (or a deceased person who would have been an eligible complainant) by a person authorised by the eligible complainant or authorised by law. It is immaterial whether the person authorised to act on behalf of an eligible complainant is themselves an eligible complainant.
Under DISP 2.7.3R an eligible complainant must be a person that is:
(i) A consumer;
(ii) A micro-enterprise;
(iii) A charity which has an annual income of less than £1 million at the time the complainant refers the complaint to VIBHS; or
(iv) A trustee of a trust which has a net asset value of less than £1 million at the time the complainant refers the complaint to the firm.
In determining whether an enterprise meets the tests for being a micro-enterprise, account should be taken of the enterprise's 'partner enterprises' or 'linked enterprises' e.g., where a parent company holds a majority shareholding in a complainant if the parent company does not meet the tests for being a micro-enterprise then neither will the complainant.
If VIBHS is in doubt about the eligibility of a business, charity, or trust, it should treat the complainant as if it were eligible. If the complaint is referred to FOS, the Ombudsman will determine eligibility by reference to appropriate evidence, such as audited accounts or VAT returns.
To be an eligible complainant a person must also have a complaint that arises from matters relevant to one or more of the following relationships with VIBHS:
(i) The complainant is (or was) a customer of VIBHS; or
(ii) The complainant is (or was) a potential customer of VIBHS
Under DISP 2.7.9R the following are not eligible complainants:
(i) A firm whose complaint relates in any way to an activity which the firm itself has permission to carry on;
(ii) A complainant who is/was:
A professional client; or
An eligible counterparty; in relation to the firm and activity in question at the time of the act or omission which is the subject of the complaint; and
(iii) In the Consumer Credit Jurisdiction:
A body corporate;
A partnership consisting of more than three persons;
A partnership all of whose members are bodies corporate; or
An unincorporated body which consists entirely of bodies corporate.
The regulation, therefore, allows that for an individual, business, charity, or trustee who was a professional customer of VIBHS at the time of the act or omission and in respect of the activity which is the subject of the complaint, VIBHS need not classify them as an Eligible Complainant.
Nonetheless, VIBHS must adopt a 'best practice' philosophy of investigating any complaint that whilst not resulting in the firm making any form of redress, may indicate an underlying operational weakness that may require remedial action, particularly if the situation is repeated.
All staff must immediately forward all incoming documentation whether hand-written or by email relating to a complaint or an expression of dissatisfaction as defined in section 2.1 to the Compliance Officer. The Compliance Officer will record the complaint in the "Complaints Log" and issue the complaint with a unique "Complaint reference number". The Compliance Officer will acknowledge the receipt of the complaint to the complainant in writing confirming amongst other detail required by DISP:
(i) The complaint's unique reference number;
(ii) The name and/or job title of the individual handling the complaint for VIBHS; and
(iii) Details of VIBHS' internal complaint handling procedures.
To comply with DISP 1.4.1R, once a complaint has been received by VIBHS, it must:
(i) Investigate the complaint competently, diligently, and impartially, obtaining additional information as required;
(ii) Assess fairly, consistently and promptly:
The subject matter of the complaint;
Whether the complaint should be upheld;
What remedial action and/or redress may be appropriate;
If appropriate, whether it has reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in the complaint; taking into account all relevant factors;
(iii) Offer redress or remedial action when it decides this is appropriate;
(iv) Explain to the complainant promptly and in a way that is fair, clear and not misleading, its assessment of the complaint, its decision on it and any offer of remedial action or redress; and
(v) Comply promptly with any offer of remedial action or redress accepted by the complainant.
Factors that may be relevant in the assessment of a complaint under DISP 1.4.1R may include the following:
(i) All the evidence available and the particular circumstances of the complaint;
(ii) Similarities with other complaints received by VIBHS;
(iii) Relevant guidance published by the FCA, other relevant regulators, FOS or former schemes; and
(iv) Appropriate analysis of decisions by FOS concerning similar complaints received by VIBHS.
VIBHS must aim to resolve complaints at the earliest opportunity thus minimising the number of unresolved complaints which may need to be referred to FOS. Accordingly, where a complaint against VIBHS is referred to FOS, the firm must cooperate fully with FOS and comply promptly with any settlements or awards made by it under DISP 1.4.4R.
DISP 1.5.1R provides that the following rules do not apply to a complaint that is resolved by VIBHS by close of business on the business day following its receipt:
(i) The Complaints Time Limit rules;
(ii) The Complaints Forwarding rules;
(iii) The Complaints Reporting rules;
(iv) The Complaints Record rule; and
(v) The Complaints Data Publication rules.
It should be noted that complaints falling within this section are still subject to the Complaint Resolution rules and for the purposes of this section:
(i) A complaint received on any day other than a business day or after the close of business on a business day, may be treated as received on the next business day; and
(ii) A complaint is resolved where the complainant has indicated acceptance of a response from VIBHS with neither the response nor acceptance having to be in writing.
On receipt of a complaint VIBHS must:
(i) Send the complainant a prompt written acknowledgement providing early reassurance that it has received the complaint and is dealing with it; and
(ii) Ensure the complainant is kept informed thereafter of the progress of the measures being taken for the complaint's resolution.
To comply with DISP 1.6.2R VIBHS must, by the end of eight weeks after its receipt of the complaint, send the complainant:
(i) A 'final response', being a written response from the firm which:
Accepts the complaint and where appropriate offers redress or remedial action; or
Offers redress or remedial action without accepting the complaint; or
Rejects the complaint and gives reasons for doing so and which (a) encloses a copy of FOS' standard explanatory leaflet and (b) informs the complainant that if they remain dissatisfied with VIBHS' response, they may refer their complaint to FOS and must do so within six months; or
(iii) A written response which:
Explains why it is not in a position to make a final response and indicates when it expects to be able to provide one;
Informs the complainant that they may refer the complaint to FOS; and
Encloses a copy of FOS' standard explanatory leaflet.
DISP 1.6.2R does not apply if the complainant has already indicated in writing acceptance of a response by VIBHS provided that the response:
(i) Informed the complainant how to pursue their complaint with VIBHS if they remains dissatisfied; and
(ii) Referred to the ultimate availability of FOS if they remains dissatisfied with VIBHS' response.
It is expected that within eight weeks of their receipt, almost all complaints to VIBHS will be addressed by it through a final response or response as described in DISP 1.6.4R. VIBHS should note that when assessing its response to a complaint, the FCA may have regard to a number of factors including the quality of response weighted against the Complaints Resolution rules, as well as the speed with which it was made.
If under DISP 1.7.1R VIBHS has reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in a complaint, it may forward the complaint or the relevant part of it, in writing to that other respondent provided it:
(i) Does so promptly;
(ii) Informs the complainant promptly in a final response of why the complaint has been forwarded by it to the other respondent and of the other respondent's contact details; and
(iii) Where jointly responsible for the fault alleged in the complaint, it complies with its own obligations under this chapter in respect of that part of the complaint it has not forwarded.
DISP 1.7.2R determines that when a respondent receives a complaint that has been forwarded to it under DISP 1.7.1R, the complaint is treated for the purposes of DISP as if made directly to that respondent, and as if received by it when the forwarded complaint was received. On receiving a forwarded complaint, the standard time limits will apply from the date on which the respondent receives the forwarded complaint.
All "hard copy" documentation generated by the complaint must be retained in a "Complaints" file and held in accordance with the FCA's record-keeping requirements regarding complaints - Refer to Section 4
All electronic documentation or communications generated by the complaint e.g., email, must be maintained in a secure, dedicated "Complaints" directory with separate sub-folders for each complainant and held in accordance with the FCA's record-keeping requirements regarding complaints - Refer to Section 4.
Once all the information in respect of a complaint has been recorded, the Compliance Officer will inform the CEO of the complaint details and any initial findings. The Compliance Officer will subsequently provide the CEO with regular updates until the complaint is resolved to the mutual satisfaction of all parties.
Definitions of "Complaint" and "Eligible Complainant" remain as per sections 2.1 and 2.2.2.
All staff must immediately forward all incoming verbal complaints or expressions of dissatisfaction defined in Section 2.1 to the Compliance Officer. The Compliance Officer will write down all the key aspects of the complaint and verbally inform the complainant;
(i) That the telephone conversation is being recorded;
(ii) Of the complaint's unique reference number;
(iii) Of the complainant's right of access to FOS along with their full contact details; and
(iv) That they will acknowledge receipt of the complaint in writing.
After the call, the Compliance Officer will record the complaint in the "Complaints Log" and then acknowledge the receipt of the verbal complaint in writing to the complainant reiterating:
(i) The complaint's unique reference number;
(ii) The complainant's right of access to FOS along with their full contact details;
(iii) The name and/or job title of the individual handling the complaint for VIBHS;
(iv) Details of VIBHS' internal complaint handling procedures.
With the exception of 3.1 above, the complaint is to be handled in precisely the same manner as detailed in section 2.3 above.
In compliance with DISP 1.9.1R, VIBHS must make and retain records of complaints relating to MiFID business for a minimum period of five years and for all other business for a minimum of three years from the date of its receipt of the complaint. These records are required for the purposes of monitoring by the FCA and also to ensure that the firm is able to co-operate with FOS. They should include:
(i) The name of the complainant;
(ii) The substance of the complaint; and
(iii) Any correspondence between VIBHS and the complainant including details of any redress offered by VIBHS.
Under DISP 1.10, VIBHS must provide to the FCA twice a year by electronic submission via the FCA's 'RegData' system, with a report which contains for the relevant reporting period, information about:
(i) The total number of complaints received by VIBHS; and
(ii) The total number of complaints closed by the firm:
Within four weeks or less of receipt;
Within four to eight weeks of receipt;
More than eight weeks after receipt; and
(iii) The total number of complaints:
Upheld by the firm in the reporting period;
Outstanding at the beginning of the reporting period; and
(iv) The total amount of redress paid in respect of complaints during the reporting period.
Where a complaint could fall into more than one category the complaint should be recorded in the category that VIBHS considers to form the main part of the complaint.
The relevant reporting periods are six-monthly from 1 April to 30 September and 1 October to 31 March each year and reports must be submitted to the FCA within one month of the end of the relevant reporting period.
In accordance with DISP 1.10.7R a closed complaint is a complaint:
(i) Where VIBHS has sent a final response; or
(ii) Where the complainant has indicated in writing acceptance of VIBHS' earlier response under DISP 1.6.4R.
Electronic submission via their 'RegData' system to which VIBHS' Compliance Officer will have access is the FCA's preferred method of Complaints reporting. In the absence of the functionality to submit reports electronically to the FCA a report under this section must be delivered in the way set out in the FCA's Supervision Sourcebook ("SUP") sections 16.3.6R to 16.3.16G - "General provisions on reporting".
If VIBHS is unable to submit a report in electronic format because of a systems failure of any kind the firm must:
(i) Submit its report through one of the alternative methods of submission detailed in SUP 16.3.9R; and
(ii) Notify the FCA in writing and without delay of that systems failure.
For the purpose of inclusion in the public record maintained by the FCA, VIBHS must:
(i) Provide the FCA at the time of its authorisation, with details of a single contact point within VIBHS for complainants; and
(ii) Notify the FCA of any subsequent change in those details when convenient and at the latest, in VIBHS' next report.
The contact point can be by name or job title and may include, for example, a helpline telephone number. However, it is recommended to remain consistent with this policy, that the Compliance Officer is the nominated contact point at VIBHS for complainants.
VIBHS must cooperate fully with FOS in the same manner as it would with the FCA i.e., in an open and honest manner pertaining to the handling of complaints against it. Cooperation with FOS includes but is not limited to, producing requested documents, adhering to any specified time limits, attending hearings when requested to do so, and complying promptly with any settlements or awards.
VIBHS Financial Ltd hereinafter known as "the Company", "the Firm" or "we", is fully committed to compliance with the requirements of the General Data Protection Regulation (Regulation (EU) 2016/679), which came into force on 25th May 2018.
The Firm is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and stored by the Firm. Please read the following carefully to understand our views and practices regarding your personal data and how the Company will treat it. By using our website, you are agreeing to be bound by this Policy, however, you are free to withdraw your consent anytime by notifying us.
For the General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR'), the data controller is VIBHS Financial Ltd
We know that you are concerned with how we deal with your personal information. This privacy statement sets out our current policies and demonstrates our commitment to your privacy. Our privacy policy may change at any time in the future for compliance purposes. You agree to revisit this page regularly and your continued access to or use of the Website will represent your consent to these changes.
We are required to maintain certain personal data about individuals for the purposes of satisfying our operational and legal obligations (to open an account, client due diligence, money laundering prevention, transact business effectively and to safeguard your assets and your privacy). We recognise the importance of correct and lawful treatment of personal data as it helps to maintain confidence in our organisation and to ensure efficient and successful outcomes when using this data.
We only use personal information as legally appropriate to provide you with a high quality of service and security. We may use the personal data collected from you to verify your identity and contact information. We may also use this information to establish and set up your trading account, issue an account number and a secure password, maintain your account activity, and contact you with account information. This information helps us improve our services, satisfy financial regulation and inform you about new products, services or promotions that may be of interest to you.
Personal data may consist of data kept on paper, computer or other electronic media; all of which is protected under the GDPR.
All data is :
We may collect and process the following data about you:
The types of personal data that we may process, for instance, include information about current, past and prospective clients and customers, website visitors, etc. with whom we have dealings. This information includes information required to communicate with you, including your name, mailing address, telephone number, email address, date of birth, ID and your location information.
We may also ask you for information when you report a problem with the Site. If you contact us, we may keep a record of that correspondence. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
You have choices about the data we collect. When you are asked to provide personal data, you may decline. You are also entitled to have the Firm erase your personal data, cease further dissemination of the data and potentially have third parties halt processing of the data. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal however, if you choose not to provide data that is necessary to provide a service or feature or to withdraw the data that is still relevant to original purposes of processing, you may not be able to use that service or feature.
The data we collect depends on the context of your interactions with the Company, the choices you make, including your privacy settings, and the service and features you use.
Cookies are small text files sent from the Web server to your computer. We use cookies to assist us in securing your trading activities and to enhance the performance of our Website. Cookies used by us do not contain any personal information, nor do they contain account or password information. They merely allow the site to recognise that a page request comes from someone who has already logged on.
We may share Website usage information about visitors to the Website with reputable advertising companies for targeting our Internet banner advertisements on this site and other sites. For this purpose, pixel tags (also called clear GIFs or web beacons), may be used to note the pages you've visited. The information collected by the advertising company using these pixel tags is not personally identifiable.
To administer and improve our Website, we may use a third party to track and analyse usage and statistical volume information including page requests, form requests, and click paths. The third party may use cookies to track behavior and may set cookies on behalf of us. These cookies do not contain any personally identifiable information.
We share your personal data with your consent or as necessary to complete any transaction or provide any service you have requested or authorised. We also share data with:
We may share information with affiliates if the information is required to provide the product or service you have requested, or to provide you with the opportunity to participate in the products or services our affiliates offer. We may also forge partnerships and alliances, which may include joint marketing agreements, with other companies who offer high-quality products and services that might be of value to our Customers.
To ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, we may share some information with partners, affiliates and alliances. This allows them to better understand the offers that are most relevant and useful to yourself. The use of your personal information is limited to the purposes identified in our relationship with the partner or affiliate.
We do not sell, license, lease or otherwise disclose your personal information to any third party for any reason, except as described below.
We reserve the right to disclose your personal information to third parties when required to do so by law to regulatory, law enforcement or other government authorities. We may also disclose your information as necessary to credit reporting or collection agencies. We may also disclose your information to non-affiliated third parties if it is necessary to protect the Company's rights or property.
To help us improve our services to you, we may engage another business to help us to carry out certain internal functions such as account processing, fulfillment, client service, client satisfaction surveys or other data collection activities relevant to our business. We may also provide a party with Customer information from our database to help us to analyse and identify Customer needs and notify Customers of product and service offerings.
Use of the shared information is strictly limited to the performance of the task we request and for no other purpose. All third parties with which we share personal information are required to protect personal information in a manner similar to the way we protect personal information. We use a variety of legal mechanisms, including contracts, to help insure your rights and protections.
Restriction of responsibility
If at any time you choose to purchase a product or service offered by another company, any personal information you share with that company will no longer be controlled under our Privacy Policy. We are not responsible for the privacy policies or the content of sites we link to and have no control of the use or protection of information provided by you or collected by those sites.
Whenever you elect to link to a co-branded Web site or to a linked Web site, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party, and you should familiarise yourself with the privacy policy provided by that third party.
All individuals who are the subject of personal data held by us are entitled to:
If you cannot access certain information and personal data collected by the Firm, you can always contact the Company at [email protected]. We will respond to requests to access or delete your personal data within 30 days.
We maintain strict security standards and procedures with a view to preventing unauthorised access to your data by anyone, including our staff. We use leading technologies such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your data. The hardware protection includes Cisco security products. The software protection tools include strict control mechanisms as follows: SSL 3, TLS 1.2 with keys equal or larger than 2048-bit. The Firm's staff and other third parties, whenever contracted to provide support services, are required to observe our privacy standards and to allow us to audit them for compliance.
In the case of a personal data breach, the Company shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority- Information Commissioner's Office, UK (ICO)unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification to ICO is not made within 72 hours, it shall be accompanied by reasons for the delay according to the Article 33 of GDPR.
Personal data collected by the Company may be stored and processed in your region or in any other country where the Company or its affiliates, subsidiaries or service providers maintain facilities. Typically, the primary storage location is in the client's region or in the UK, often with a backup to a datacentre in another region.
The storage location(s) are chosen to operate efficiently, to improve performance, and to create redundancies to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.
We transfer personal data from the European Economic Area to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data.
The Company retains personal data for as long as necessary to provide the services, or for other essential purposes such as complying with our legal obligations, including as an authorised financial services provider, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of various products, actual retention periods may vary significantly. The criteria used to determine the retention periods include, for example:
From time to time, we may update this Privacy Policy. In the event we materially change this Privacy Policy, the revised Privacy Policy will promptly be posted to the websites and we will post a notice on our websites informing you of such changes.
You agree to accept posting of a revised Privacy Policy electronically on the Website as actual notice to you. Any dispute over our Privacy Policy is subject to this notice and our Customer Agreement.
We encourage you to periodically check and review this policy so that you will always know what information we collect, how we use it, and to whom we disclose it. If you have any questions that this statement does not address, please contact us via [email protected].
If you have a privacy concern, complaint or a question for the Data Protection Officer, please contact us via [email protected]. We will respond to questions or concerns within 30 days.
Unless otherwise stated, the Firm is a data controller for personal data we collect through the services subject to this statement. The Company is a private limited company under Companies House number 08279988 registered office at Amlbenson The Long Lodge, 265-269 Kingston Road, Wimbledon, England, SW19 3NW The Firm's Compliance Officer is also the person responsible for data protection as the Data Protection Officer. The address for correspondence is 11-12 Token House Yard, London, EC2R 7AS. Telephone: 020 7709 2038.
My Sea and Vision Sea Global (vseaglobal.com/index.htm)
only one international (o2onlyone.com)
TP EAGLE(s) (tpeaglebvi.com). (www.mas.gov.sg/IAL.aspx?sc_p=T).
YINFOREX (yinforex.com/)
Term Brokers (www.szlibkr.com)
INZI Global (www.inzikg.com)
Lion Financial/ 18lion (www.18lion.com)
Caomeng (www.caomeng.com)
Trade Korea (www.tradekorea.com)
EdwardFX: http://www.edwardfx.net and http://cn.edwardfx.net are cloned websites of Edward Technology Capital Ltd (Edward Technology Capital Ltd website is www.edwardtech.co.uk)
These firms claim to be subsidiaries of VIBHS Financial without the permission and consent of the company. These brokers may be using VIBHS Financial brand and logo to fraudulently deceive and mislead our valuable customers.
Therefore, this serves as an official statement to reiterate, our official company named VIBHS Financial Ltd as usual will continue to serve our valuable clients through our only registered domains:
http://www.vibhsfinancial.co.uk/
These brokers have been warned that action will be taken should they not remove their claims of partnership and this has been reported to the relevant governing bodies.
We urge our valuable customers to be cautious and take extra care when dealing with any other parties.
We continue to report issues of this severity and reserve the right to take legal action. Please contact our Customer Service at [email protected] for any further information.
VIBHS Financial Ltd does not provide service to any jurisdiction where the licensee is restricted/prohibited to provide its services.
VIBHS Financial Ltd is registered in England and Wales under company number 08279988, registered office at Amlbenson The Long Lodge, 265-269 Kingston Road, Wimbledon, England, SW19 3NW, and authorised and regulated by the Financial Conduct Authority in the United Kingdom under FCA Firm Reference Number 613381.
CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. 55.97 % of retail investor accounts lose money when trading CFDs with this provider. You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money.
The information on this website is targeted at residents of the United Kingdom. It is not intended for distribution to residents in any jurisdiction where distribution would be unlawful of contravene regulatory requirements.