Terms & Conditions

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TCF Policy statement

The firm has considered TCF has a TCF policy which puts its customers first. The policy ensures good industry practice and was initially challenged for feasibility and improvement by the board before approval and is reviewed on a regular basis for improvements. Stargate Investment Group Ltd, Stargate Capital Management Limited and Stargate Corporate Finance Limited consider the following with regards to Retail clients as defined in the FCA handbook COBS 3.4:

  • Suitability and appropriateness of the product to the client taking into account the clients knowledge and experience
  • The firms remuneration of its staff and associated parties does not incentivise bad practice
  • Clients can be confident that they are dealing with firms where their fair treatment is central to the corporate culture 
  • Products and services are marketed and sold in the retail market that are designed to meet the consumer groups and are targeted accordingly 
  • Consumers are provided with clear information and are kept appropriately informed, before, during and after the point of sale 
  • Where clients receive advice, the advice is suitable and takes account of their circumstances 
  • Clients are provided with products that perform as firms have led them to expect and the associated service is of an acceptable standard and as they have been led to expect 
  • Clients do not face unreasonable post/sale barriers imposed by firms to change product, switch provider, submit or make a compliant 

Whilst the above policy statement relates to the treatment specifically of retail clients, Stargate strives to achieve this for all clients and in particular PRIN 2.1.1R in the FCA handbook which sets out the obligation to act with honesty and integrity and to treat customers fairly amongst other requirements.

In addition to this the FCA also highlight other areas for consideration such as the product life cycle which can include but are not limited to the following:-

  • Product design
  • Financial promotion/marketing practices
  • The sales process
  • Information and customer support after the point of sale
  • Complaint handling

These desired outcomes and areas for consideration act as mere guidance towards particular required achievements, and it is therefore the firms themselves who are charged with the responsibility of ensuring that they satisfy the obligations of the initiative in whichever way they deem necessary. However the FCA are clear that firms’ actions on this basis must be justifiable and demonstrate the rationale behind their approach not only in an immediate context but also on an ongoing basis.