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Complaints Policy

The Compliance Officer for DJWM Ltd (trading as The Investment Fitness Club) is Mr.Saul Djanogly email address:  [email protected]

On receipt of a complaint from a client or potential client DJWM Ltd (trading as The Investment Fitness Club) will:-

  • Send the complainant a prompt written acknowledgement providing early reassurance that it has received the complaint and is dealing with it.
  • Ensure the complainant is kept informed thereafter of the progress of the measures being taken for the resolution of the complaint.
  • Within 8 weeks from receipt of the complaint send the complainant a ‘final response’ in written form which-
  • Accepts the complaint and, where appropriate, offers redress or remedial action, or
  • Offers redress or remedial action without accepting the complaint,


  • Rejects the complaint and gives reasons for doing so enclosing a copy of the Financial Ombudsman’s Service.
  • Provides the website of the Financial Ombudsman
  • Informs the complainant that if he/she remains dissatisfied with The Investment Fitness Club’s response, he/she may refer his/her complaint to the Financial Ombudsman Service.
  • Indicates whether or not The Investment Fitness Club consents to waive the relevant time limits in DISP 2.8.2 R or DISP 2.8.7 R (Was the complaint referred to the Financial Ombudsman Service in time?) by including the appropriate wording set out in DISP 1 Annex 3R

Or a written response which:-

  • Explains why The Investment Fitness Club is not in a position to make a final response and indicates when it expects to be able to provide one;
  • Informs the complainant that he/she may now refer the complaint to the Financial Ombudsman Service;
  • Indicates whether or not The Investment Fitness Club consents to waive the relevant time limits in DISP 2.8.2 R or DISP 2.8.7 R (Was the complaint referred to the Financial Ombudsman Service in time?) If it becomes apparent that the complaint has been made or is referred outside those time limits;
  • Encloses a copy of the Financial Ombudsman Service standard explanatory leaflet;
  • Provides the website of the Financial Ombudsman Service.

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Preparing for Prime Minister Corbyn?

UK investors and taxpayers should be asking themselves the following three questions. What is the likelihood of a Corbyn led government sometime between now and 2022? How would such a government affect my tax position? What is the wider market impact of the Labour government or Labour led coalition likely to be?

Jeremy Corbyn is the most likely future prime minister both according to recent polls and the bookmakers. Labour only needs to win seven more seats in order to be in a position to form a coalition with other parties such as the Scottish Nationalists. With many having been wrong-footed by the results of the Brexit vote, it would be prudent to accept the very real possibility of Corbyn as Prime Minister. Although the next general election is not due until 2022, many think the current government will fall sooner.

In its last election manifesto, Labour promised to raise public spending by £48 billion. This is to be partly funded by higher personal taxation on top earners whilst significantly increasing corporation tax. Tax will also be levied on private school fees and private medical insurance. According to the Taxpayers Alliance, Labour’s additional spending commitments came to around £100 billion excluding its re-nationalization plans, so taxes may have to go up even further. Tax payers should consider the impact of these proposals on their personal tax bill and what steps they might consider taking now.

How will investors and those with long-term retirement savings be affected by a Labour victory? There are two schools of thought. The first sees the long-term impact as mild with the UK, in effect, changing course to follow a Scandinavian model of higher taxes combined with higher welfare spending. At the other end of the spectrum, Morgan Stanley recently advised their clients that a Corbyn government would wreak havoc on the UK stock market and the pound. Other commentators have also said that the U.K. government’s credit rating is likely to be downgraded leading to a rise in interest rates. What is for sure is that Labour has openly acknowledged it has plans for a likely run on the pound if it wins at the polls. Likewise it has committed to re-nationalising railway, water and energy companies as well as the Royal Mail Group. Investors therefore need to run through a basic checklist of how their savings and investments are likely to be affected in this scenario.

At Best Interest Consultants, our view is ‘forewarned is forearmed’. Although a Labour or Labour led government may not materialise, the prospect combined with the host of unknowns surrounding Brexit, may lead to the reassessment of the UK as a high-risk economy and investment destination. Some have pointed to the overall relative weakness of the pound and the UK stock market, as already reflecting this as a reality. Over the coming months, we will be addressing these issues in a series of complimentary briefing papers and webinars.

Saul Djanogly, CEO Best Interests [email protected]

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Best Execution Policy

Best Execution Policy

As a regulated firm DJWM Ltd is required by the Financial Conduct Authority (FCA) to put in place a Best Execution Policy to ensure when transmitting orders on your behalf that we take all suitable steps to achieve the best possible result for you.

For the great majority of our clients we refer all trades through our recommended Custodian, Raymond James. We therefore rely on Raymond James’s own Best Execution Policies and procedures in so far as they are carrying out any orders on your behalf. However, to meet your best interests, we regularly scrutinise and review their processes and effectiveness, and if we were to consider that they were not achieving the best possible result we would report to you and consider other options.

For sales and purchases that are for securities quoted outside the United Kingdom, or are above normal market size, Raymond James dealers will use their discretion in placing the trade. The execution venue that they will use will depend on the exact nature of the trade, but will typically be executed through Stifel, Winterflood Securities Limited, Instinet Limited or Peel Hunt LLP. These market makers have been selected by Raymond James according to the criteria outlined below.

A small number of our clients have decided to directly appoint their own Custodians. Where this happens, we rely on those Custodians to ensure best execution on your behalf. Here the dealing arrangements are out with our control, and we will only comment on them if requested to do so by you.

Execution Factors

The execution factors that we will take into account are:

  • Price
  • Cost/Commission of transaction
  • Client category
  • Size and complexity of the order
  • Speed of execution
  • Likelihood of execution and/or settlement
  • Characteristics of the order

DJWM Ltd has determined that, in almost all cases, the most important factor affecting best execution for our clients custodied with Raymond James is the cost of the trade to the client (i.e. the price, plus any fees, commissions and third-party charges).

 Timely Execution

DJWM Ltd.’s policy on timely execution is that trades should be placed as soon as reasonably practicable on receipt from the client.

If we are proposing a deal for both our advisory and discretionary managed clients, we will not delay dealing on behalf of our Discretionary Managed clients until consent is obtained from our advisory managed clients unless, in our opinion, all our clients will benefit from the aggregation of the orders.

For discretionary clients, the relevant time is the time at which we reach a decision. For advisory clients, the relevant time is the time we receive your consent.

Customer Order Priority

DJWM Ltd will deal for customers in the order in which their orders are received. Where we decide to deal for all discretionary customers in a similar manner, these trades will be allocated in order that all clients benefit from price improvements that may be available to more substantial orders. Similarly, we will aggregate dealer initiated trades if this is to your advantage. However, you should be aware that in volatile markets this may not be possible.

Clients who give specific instructions

You may, on occasion, give a specific instruction relating to an order (execution-only). If this is the case, we are relieved of the duty of best execution, but only to the extent that it relates to an execution-only deal

We are forbidden from persuading you to execute an order in a particular way.

We will keep a record of the fact that you have directed the order. We are required to disclose to you that the execution-only instruction may prevent us (including Raymond James) from achieving the best outcome for you. However, as this warning is contained in Raymond James’ Terms of Business, it does not have to be given on a case-by-case basis.

Circumstances where best execution may be achieved outside the best execution policy

There are a number of circumstances in which the fact that execution took place is evidence of best execution. These include:

  • Collective investment schemes that are traded directly with the fund manager
  • Over-the-counter derivative trades (available on US platform only)
  • Some structured products
  • Exchange traded stocks with limited liquidity (e.g. AIM stocks with a single market maker)

However, at the present time, DJWM Ltd does not trade any of the above-mentioned products, except for the collective investment schemes.

Churning and Switching

DJWM Ltd will not enter into transactions of an unnecessary frequency (“churn”) or switch between packaged products unless we can demonstrate that we have taken reasonable steps to ensure that the deal or switch is suitable for you.


You can learn more about Raymond James’s best execution policy by reading their Execution Policy. The procedure may help you further understand the process used to analyse the quality of execution obtained and as to how Raymond James monitors and verifies that the best possible results were obtained for its clients.

Please follow this link for details:



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12 reasons for practising KISS ‘keep it simple and stupid’ when it comes to your investments

A couple of days ago I came across this article with 12 reasons ‘Why simple beats complex’ when it comes to investments and I wanted to share it with you.

At its core, investment can be reduced to these 4 simple questions:

1.Where are you now financially and where you want to be in the future?

2. What needs to happen to get you there and what return do you need on your investments to reach your goal?

3. Do your required return and the risk it carries match your risk tolerance?

4. If not (which is usually the case), what trade-offs between?

To read the full article, please follow the link below.

”Why Simple Beats Complex”

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