Where the Client always comes first.

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Terms of Business

Terms Of Business


This Terms of Business should only be read in conjunction with our Services document, which lay out the various personal service levels that you can choose from.

Spires Independent Ltd are authorised and regulated by the Financial Conduct Authority.


This document is important as it informs you of the various protections provided to you as a Client of Spires Independent Ltd as well as laying out the procedures which Spires Independent Ltd as a firm adhere to such as the Protection of your Personal Data, so you should familiarise yourself with this document.


Contact Details


We can be contacted in person or by post at,

Spires Independent Ltd,                                                                                

33 Market Street                                                                                                               

Lichfield                                                                                                              Or you can contact us via

Staffordshire                                                                                                                        Tel:           01543 624426

WS13 6LA                                                                                                                          Fax:          01543 624427

                                                                                                                                                Email:      This email address is being protected from spambots. You need JavaScript enabled to view it.

We are proud to say that Spires Independent Ltd is Authorised and Regulated by the Financial Conduct Authority.

The Financial Conduct Authority (FCA) regulates the financial services industry in the UK and their address is 25 The North Colonnade, Canary Wharf, London, E14 5HS. You can check this on the FCA’s Register by visiting the FCA’s website www.FCA.gov.uk/register FCA No. 585453 or by contacting the FCA on 0845 606 1234.

You will be treated as a “retail client” for investment business and a “consumer” for general insurance business.  This means that you are afforded the highest level of protection under the regulatory system and should have the right to take any complaint to the Financial Ombudsman Service.


We prefer our clients to give us instructions in writing, we will, however, accept oral instructions provided they are confirmed in writing.

Material Interest

We will act honestly, fairly and professionally known as conducting business in ‘Client’s best interest’ regulations. Occasionally situations may arise where we or one of our other clients have some form of interest in business transacted for you. If this happens or we become aware that our interests or those of one of our other clients conflict with your interest, we will write to you and obtain your consent before we carry out your instructions, and detail the steps we will take to ensure fair treatment.

We are prohibited from accepting any payment (commission or other non-monetary benefits) which is likely to conflict with our duty to you as our clients.

Anti-money laundering

We are required by the anti-money laundering regulations to verify the identity of our clients, to obtain information as to the purpose and nature of the business which we conduct on their behalf, and to ensure that the information we hold is up-to-date. For this purpose we may use electronic identity verification systems and we may conduct these checks from time to time throughout our relationship, not just at the beginning.

Client money

Spires Independent Ltdis not permitted to handle client money and we cannot accept a cheque made out to us (unless it is in respect of an item for which we have sent you an invoice) or handle cash.

Our services

Spires Independent Ltdis able to act on your behalf in advising you on investments and non-investment insurance contracts. We offer products and services as follows:


  •                                Investments - we offer an Independent advice service. We will recommend investments based on a comprehensive and fair analysis of the market.  We will place no restrictions on the Investment Markets we will consider before providing investment recommendations, unless you instruct us otherwise.  We will however only make a recommendation when we know it is suitable for you.
  •                                Non-investment protection contracts - we offer non investment protection products e.g. term assurance, income protection and critical illness from a range of insurers.
  •                                General Insurance Contracts - we offer General Insurance contracts e.g. Buildings and Contents from a range of insurers.

We offer you an initial discussion for which we will waive our standard fees during which we will describe our services more fully and explain the payment options.

The Financial Planning Process

There are four stages to the financial planning process, each of which is separately priced, although the initial consultation is at our cost:

  1.            Initial consultation
  2.            Financial Review and Recommendation
  3.            Policy arrangement and Implementation
  4.            Review – Ongoing care and advice through our ongoing Management Service

Each of these services and the associated costs are explained in more detail in our Service Level Agreement as the costs differ dependent on the level of advice required.

 Where you have retained our services and where our Advice recommendations and have necessitated the implementation of a regulated product i.e. an Individual Savings Account (ISA)

With very few exceptions, we will confirm to you in writing the basis of our recommendations along with details of any special risks associated with the products recommended.

Full details of the products we recommend to you including, for example, the minimum duration of the product, information on your right to cancel or whether no right to cancel exists, and any other early termination rights and penalties, will be covered in the relevant product disclosure information you will receive before conclusion of any contract.

We will issue any documentation/recommendations and any other communication to you in English.

We may also, on occasion, advise on other financial products which are not regulated by the FCA under the Financial Services and Markets Act 2000. The Financial Services Compensation Scheme does not apply to any of these products you will be made aware of these products and the risk’s entailed with them prior to Implementation.

 You should be aware that investments carry varying degrees of risk and as their underlying value can fall as well as rise you may not get back the full amount invested and if you are relying on these investments to produce an income the level of income generated can fluctuate as well as the capital value of your investments.


Under current legislation our services where our Advice lead to Spires Independent Ltd arranging and implementing the recommendations then our fee’s are not subject to VAT but should this change in future, and where VAT becomes due, we will notify you before conducting any further work.


We will endeavour to make arrangements for all your investments to be registered in your name unless instructed otherwise in writing. All policy documents will be forwarded to you as soon as practicable after we receive them.

If there are a number of documents relating to a series of transactions, we will normally hold each document until the series is complete and then forward them to you.

Cancellation rights

In most cases you can exercise a right to cancel by withdrawing from the contract. In general terms you will normally have a 30 day cancellation period for a life, pure protection, payment protection or pension policy and a 14 day cancellation period for all other policies.

For pure protection policies the start of the cancellation period will normally begin when you are informed that the contract has been concluded or, if later, when you have received the contractual terms and conditions. In other cases, the cancellation period will begin on the day the contract is concluded or, if later, the day on which you receive the contractual terms and conditions. Instructions for exercising the right to cancel, if applicable, will be contained in the relevant product disclosure information which will be issued to you.

If you cancel a single premium contract, you may be required to pay for any loss you might reasonably incur in cancelling it which is caused by market movements. This means that, in certain circumstances, you might not get back the full amount you invested if you cancel the policy.


The authority to act on your behalf may be terminated at any time without penalty by either party giving seven days notice in writing to that effect to the other, but without prejudice to the completion of transactions already initiated. Any transactions effected before termination and a due proportion of any period charges for services shall be settled to that date.


If you wish to register a complaint, please contact us in any of the ways shown in the Contact Details above.

A summary of our internal complaints handling procedures for the reasonable and prompt handling of complaints is available on request and if you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service

Compensation Scheme

We are covered by the Financial Services Compensation scheme (FSCS) if we cannot meet our obligations. This is dependent upon the type of business and the circumstances of the claim. Most types of investment business are covered up to a maximum limit of £50,000, whereas Insurance business is covered for 90% of the claim, without any upper limit.

 Further information about this compensation scheme arrangement is available from the FSCS.


This client agreement is governed and shall be construed in accordance withEnglish Law and the parties shall submit to the exclusive jurisdiction of theEnglish Courts.

 Force Majeure

Spires Independent Ltdshall not be in breach of this Agreement and shall not incur any liability to you if there is any failure to perform its duties due to any circumstances reasonably beyond its control.

Client consent

 This is our standard client agreement upon which we intend to rely.  For your own benefit and protection you should read these terms carefully before entering into any Service Level Agreement with Spires Independent Ltd. 

If you do not understand any point please ask for further information.

Data Protection

The information you have provided is subject to the Data Protection Act 1998 (the “Act”). By signing a Service Agreement document you consent to us or any company associated with us for processing, both manually and by electronic means, your personal data for the purposes of providing advice, administration and management.

“Processing” includes obtaining, recording or holding information or data, transferring it to other companies associated with us, product providers, the FCA or any other statutory, governmental or regulatory body for legitimate purposes including, where relevant, to solicitors and/or other debt collection agencies for debt collection purposes and carrying out operations on the information or data.

In order to provide services to you we may be required to pass your personal information to parties located outside of the European Economic Area (EEA) in countries that do not have Data Protection Laws equivalent to those in the UK.  Where this is the case we will take reasonable steps to ensure the privacy of your information.

We may also contact you or pass your details to other companies associated with us to contact you (including by telephone) with details of any other similar products, promotions, or for related marketing purposes in which we think you may be interested.

The information provided may also contain sensitive personal data for the purposes of the Act, being information as to your physical or mental health or condition; the committing or alleged committing of any offence by you; any proceedings for an offence committed or alleged to have been committed by you, including the outcome or sentence in such proceedings; your political opinions; religious or similar beliefs; sexual life; or your membership of a Trade Union.

If at any time you wish us or any company associated with us to cease processing your personal data or sensitive personal data, or contacting you for marketing purposes, please contact The Data Protection Officer by any means shown in the contact details shown above.

You may be assured that we and any company associated with us will treat all personal data and sensitive personal data as confidential and will not process it other than for a legitimate purpose. Steps will be taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary. Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to the data.

Subject to certain exceptions, you are entitled to have access to your personal and sensitive personal data held by us. You may be charged a fee (subject to the statutory maximum) for supplying you with such data.

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