Referral Procedure

Solicitors’ compliance procedure for client referrals

1. This procedure will form part of the firm’s compliance plan and will be administered by the
    Compliance Officer for Legal Practice (‘COLP’).

2. The firm will follow the recommendation of the Law Society that clients requiring financial advice
    should be referred only to financial advisers who are independent of the influence of third
    parties.  Clients will therefore not be referred to financial advisers who are restricted to selling
    the products of the product providers they represent.

3. The COLP will consult with members of the firm’s management committee and compile a
    shortlist of IFA firms with which the firm has dealt or might in future deal with. Firms on that
    shortlist will then be invited to tender for the firm’s referral business and to submit a summary
    of their credentials which would provide evidence of the due diligence conducted by our firm.

4. The COLP will review the tender submissions, in conjunction with other members of the
    management committee as appropriate, and recommend the most appropriate, based on the
    following considerations:

    •  The suitability of the IFA’s business specialisations to the work of the firm
    •  Cultural compatibility with the firm and its clients
    •  The status of the firm and qualifications of the advisers
    •  The quality of the IFAs’ client reports
    •  The reputation of the firm and its regulatory record

5. In the event that more than one financial advice firm is to be appointed, a panel will be formed,
    based on the respective specialisations of the firms which are listed.

6. The appointee or panel of appointees will be notified to all members of the firm and no member
    of the firm will refer clients other than to the appointee or panel of appointees without the written
    consent of the COLP.

7. The following documents will be used in relation to client referrals:

    •  An Authorised Third Party Agreement confirming our firm’s relationship with the IFAs
    •  A client referral record summarising the instruction to the IFA
    •  Terms of Business for financial services leaflet to be provided to clients, which includes SRA
       disclosure statements and a statement that the firm will not receive any remuneration from the
       IFAs in consideration of the referrals which are made.

8. The Authorised Third Party Agreement requires the IFA firm to report to our firm any complaints
    received by clients who have been referred to their IFAs and any regulatory action taken against
    the IFA firm. This will entitle us to terminate the Agreement.

9. The IFA firm will provide feedback to our referring fee-earner, comprising:

    •  A short summary of the advice provided
    •  A note of any requirement for additional legal advice which may have come to light
    •  Comments made by clients about the quality of the service received from the IFA.

10. The shortlist of appointed IFAs will be subject to annual review by the firm’s management.