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Consumer Duty

Statement from our CEO

When we launched O-IM, we were intent on creating an Investment Manager that acts with integrity and transparency. These are core pillars of how we work and therefore Consumer Duty has been a welcome opportunity for us to review how effectively we are doing this, and involve the whole team in the process.

As part of the review, we engaged a third party compliance company to provide guidance and support, to both myself and the team, to ensure we are compliant with the changing regulations.

Our findings have been encouraging, and across our Fair Value Assessments we have compared well to our peers across both the AIM and Risk-Rated Portfolio propositions.

Carl Stelfox, CEO.

Complying with Consumer Duty

What is Consumer Duty?

On the 27th July 2022, the Financial Conduct Authority announced new a Consumer Duty that will aim to ‘set higher and clearer standards of consumer protection across financial services and require firms to put their customers’ needs first.’ (


Consumer Duty aims to introduce new rules, comprising of:


  • A new Consumer Principle that requires firms to act to deliver good outcomes for retail customers.
  • Cross-cutting rules providing greater clarity on our expectations under the new Principle and helping firms interpret the four outcomes (see below).
  • Rules relating to the four outcomes we want to see under the Consumer Duty. These represent key elements of the firm-consumer relationship which are instrumental in helping to drive good outcomes for customers.


These outcomes relate to:


  • products and services
  • price and value
  • consumer understanding
  • consumer support


The introduction of these rules require firms to consider the needs, characteristics and objectives of their customers – including those with characteristics of vulnerability – and how they behave, at every stage of the customer journey. As well as acting to deliver good customer outcomes, firms will need to understand and evidence whether those outcomes are being met.


Further information about the FCA’s Consumer Duty guidelines, deadlines that firms must adhere to and what ongoing monitoring is expected are detailed on the FCA’s website which you can access through the below link.


Find out more on Consumer Duty

What are we doing about it?

Ahead of the FCA’s final Consumer Duty implementation deadline of 31 July 2023, we have undertaken an internal review process to evidence the key outcomes across the action areas the FCA have identified. These can largely be catagorised into our five target areas for this project:


  1. Benefits and Outcomes
  2. Price Value Assessments
  3. Investment Proposition
  4. Target Market
  5. Distribution Strategy


Following our review process we have completed Fair Value Assessments for both the O-IM AIM Portfolio and the O-IM Risk-Rated Model Portfolio Services across both Advised and Non-Advised investors.


We have also produced a response to the FCA’s ’10 Questions to Consider Around Consumer Duty’ document which was released on the 28th June 2023 and is available here. 


Moving forward, we have installed a Consumer Duty committee as part of our ongoing commitment to complying with the new regulations which will meet on a quarterly basis.

Please contact us if you wish to receive our Consumer Duty Documents.