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EnglishFrançais2 Saint Clements house 27, Clements Lane, EC4N 7AE London 0203 318 1742
Contact@hilbert-is.com
Regulated Status

The regulated status of our organisation is set out below.

Hilbert Investment Solutions Ltd (“Hilbert”) is authorised and regulated by the Financial Conduct Authority. Financial Services Register number 698380. Companies House number 08956837.

Hilbert is registered in England with its Principal place of business address St. Clements House, 27 Clement’s Lane, London EC4N 7AE, UNITED KINGDOM

The information contained on this website is based on our understanding of rates of tax, current legislation, regulations and practice, all of which are subject to change in the future and may be applied retrospectively. This information does not constitute financial, investment or tax advice. If you want such advice, please contact an authorised financial adviser and/or tax adviser.

COMPLAINTS PROCEDURE
CONFLICT OF INTEREST

If clients are unhappy with the service provided, we will provide them with our complaints procedure upon request. We endeavour to resolve any issues for a client before a formal complaint is necessary, but if they do still wish to proceed with their complaint, our compliance team will handle this as quickly and effectively as possible.

All formal complaints should be sent, in writing, to the Compliance Officer at Hilbert Investment Solutions, St Clements House, 27-28 Clements Lane, London, EC4N 7AE.

We will acknowledge complaints within five business days of receipt. This acknowledgment will also provide a summary of the complaint to the client and will confirm the department who will be handling the matter for them. A final response will be sent to clients within four weeks. If we are not yet in a position to resolve the matter, we will provide the client with a timeframe of when they can expect us to make further contact.

Within 8 weeks, we will send clients a final response letter, upon resolution of the complaint. This will explain the resolution and any resolutions, where applicable.

Our clients are provided with the contact details of the Financial Ombudsman should they be unsatisfied with our response.

Please download the full Procedure here

A conflict of interest is a situation in which a person in a position of trust has competing personal or professional interests. Such competing interests can make it difficult to impartially fill the expected duties. A conflict of interest may exist even if no unethical or improper act has resulted from it.

At Hilbert Investment Solutions, we are committed to identifying, monitoring and managing any actual and potential conflicts of interest that may occur between us and our clients and between clients.

The purpose of this policy is to provide clients with the appropriate information regarding the policies Hilbert have in place to manage conflicts of interest.

We have summarised below the principal conflicts that exist in our business, and the steps we continue to take to mitigate them.

Employee dealing

At Hilbert, we understand that it is not uncommon for our employees to undertake deals on their own behalf. We acknowledge that this can create a conflict with the duties owed to our clients, therefore all of our employees are required to comply with our Personal Account Dealing Policy.

Gifts and hospitality

Through our internal policies, Hilbert takes great care to ensure that gifts received from clients are not extravagant and are designed to enhance the quality of the service we provide to our clients. Hilbert employees will not accept any gifts and or hospitality other than those considered normal in their line of business. Excessive gifts may result in a conflict of interest, something we are committed to avoiding. We maintain a register of all gifts and or hospitality, whether given or received, which is subject to Senior Manager oversight.

Please download the full Procedure here

ORDER EXECUTION POLICY

As required by the Financial Conduct Authority (“FCA”) rules implementing the Markets in Financial Instruments Directive (‘MiFID’), our Order Execution Policy sets out the steps Hilbert Investment Solutions take to ensure we comply with our obligation when executing, or transmitting to other entities for execution, ensuring all reasonable steps are taken to obtain the best possible result for its clients.

In our dealings with you, we have a general duty to act fairly, honestly, and professionally, taking into account our clients best interests. In relation to order execution, Hilbert Investment Solutions is required to take all reasonable steps to obtain the best possible result when executing client orders or when placing orders with or transmitting orders to, other entities to execute. The definition of ‘best possible result’ varies and Hilbert Investment Solutions must take into account a range of execution factors and determine their relative importance based on the characteristics of our clients, the orders that we receive and the markets in which we operate. The factors that we need to consider include but are not limited to costs, price, speed, the likelihood of execution and settlement, size, nature, and timing of the transactions, or any other consideration relevant to the execution of the order. In some markets, we may need to take into account matters such as the prevailing liquidity of the market in question, credit risk and the tenure of the contract.

A full copy of the Hilbert Investment Solutions Order Execution policy can be downloaded below. Requests for further information should be directed to our Compliance Department.

Please download the full Procedure here

TERMS OF BUSINESS FOR REGISTERED INTERMEDIARIES

Terms of Business for Registered Intermediaries
These Terms of Business are effective from 1st May 2018

These Terms of Business define the basis of the business relationship between Hilbert Investment Solutions (“Hilbert”) and each UK Regulated Advisers or Platform (of whatever legal nature). They also include Conditions for the basis upon which Hilbert may permit online access to information and services to Intermediaries who have been successfully registered.

Within these Terms of Business, the following definitions will apply:
• “We”, “us”, “our(s)” or  Hilbert means Hilbert Investment Solutions
• “You” or “your(s)” means the UK Regulated Advisers or Platform (of whatever legal nature) who has applied to become a Registered Intermediary with Hilbert.

If you are a UK regulated Advisers please download our Term of Business here

If you are a Platform please download our Term of Business here