As indicated before, we have identified advice and intermediary risk as our single biggest risk under FAIS. We define advice risk as the risk that advisors is exposed to when offering advice to clients as defined in the FAIS Act. We define intermediary risk as the risk a provider is exposed to when acting as an intermediary as defined in the same law. Our investment planning process consists of eight steps, which we refer to as “moments of trust”, namely:

1. A professional introduction.

2. Gathering of client information.

3. Defining and establishing a professional relationship between advisor and client.

4. Preparing the client proposal.

5. Presenting the client proposal.

6. Agreeing on the relevant material elements pertaining to the financial proposal.

7. Implementation of the proposed financial product.

8. Ongoing reporting and financial services offered to clients.

Each stage is subject to a compliance due diligence before a written agreement with strategic partners is entered into. Our audits include a critical analysis of the content and quality of compliance procedures and records.