KMG Investment Management Limited is authorised and regulated by the

Financial Conduct Authority. Our registration number is 610230.

Investment Management Limited

Our discretionary fund

management services

Rough Beech Court

Dowlands Lane

Smallfield

Surrey

RH6 9SD

www.kmg.co.uk

kmg@kmg.co.uk

01342 840 179

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Overview About us

KMG Investment Management Limited was established in 2014 to provide discretionary fund

management for clients that do not wish to be involved with the day-to-day running of their

portfolios.

As a team we have over 40 years’ experience and run more than £270 million of funds for clients

for whom we already provide investment planning, fund research and construct portfolios to

meet their individual needs.

What is discretionary portfolio management?

Discretionary management involves you appointing KMG Investment Management Limited

(KMGIM) to manage the portfolio and make changes to the fund strategy on your behalf.

With our discretionary portfolio management service, we will provide you with active fund

management services involving constant review of the markets and your funds. When changes

need to be made to the funds these will be implemented on your behalf by our team, saving

paperwork and time.

KMGIM do not hold assets as custodian and we utilise the services of third party platform providers

for this service. This ensures that the investments are held within your name and control should you

decide to no longer use our services in the future.

Our services - the investment process

We work hand in hand with your financial planner to design a portfolio to meet your objectives

and risk appetite.

Portfolio construction

Our dedicated in-house research team continually analyse the market for new funds. Past

performance alone is not a reliable guide to the future potential of an investment fund; it needs

to be considered along with the track record of each fund manager and an understanding of

each fund’s market positioning, aims and philosophy.

Our investment committee review many funds. We look at the transparency of charges and the

simplicity and quality of the fund. Frequently we interview the fund managers to gain a first-hand

understanding of the fund’s strategy.

We have developed five model portfolios based on different risk levels which form a starting point

from which we create a portfolio to match each client’s needs, whether for capital growth,

income or a combination of both if required.

We recognise the importance of adding further value with tax efficiency and low product

charges and for this reason work alongside your financial planner who advises you on the best

portfolio in which to house your investments.

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Ongoing service

Once you have invested into a portfolio, the process does not stop there. We constantly monitor

funds and report to you if we feel changes to your portfolio are required. We continually

challenge our investment process and asset allocation in order to provide you with a

comprehensive and professional service.

Our investment committee meet monthly to assess the current economic climate and then apply

our thoughts to the investment strategy making adjustments as required.

We have a robust investment process that is designed to ensure that all funds are screened in a

uniform manner and only when they pass our criteria will they be added to the portfolios.

New or additional funds to invest or disposal of investments

When you have funds to invest or require funds from your portfolio we will:

• On receipt of new funds to invest, blend them into the adopted investment strategy at that

point in time. Please be aware that when funds are invested, they may not immediately be

allocated for investment depending on timing and any planned restructuring to your portfolio

that is due. For example, we will not be able to place any trades in your portfolio whilst there

are pending transactions.

• For a withdrawal from your portfolio, we will work with your financial planner to make suitable

recommendations from which account you should draw funds.

Valuations

Valuations will be provided on a half-yearly basis. Ad hoc valuations can be arranged at request

and a charge will be applied for this service – see charges.

Other services

Other services may be provided as agreed in writing with you from time to time.

We would be pleased to undertake specific market research as requested by you/your financial

planner and this will be an additional chargeable service. We will discuss specific requirements

and charges with you at the time of the request.

Limitations to our services

Our recommended funds may not always be available on the platform or in the investment

vehicle in which you are invested. In these circumstances we will make suitable alternative fund

selections to meet the general investment themes and objectives of your portfolio.

We will endeavour to trade as soon as possible your funds, but may decide on your behalf to hold

investment increments in cash. This may happen from time to time when you invest and we are

aware that a rebalance of your portfolio will be due short term. We may then hold and trade the

cash into the strategy at the same time as rebalances to reduce the number of trades placed on

your account.

Should you have any concerns then please speak with your financial planner for more details.

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Our team

Patrick McIntosh

Director and Chartered Financial Planner

Patrick has 40 years’ experience in financial services with a wide range of

knowledge and experience, Patrick loves the macro overview and thrives on

investment planning and achieving results for our clients. An avid fitness fanatic,

Patrick often participates in challenges most of us would never contemplate. His

most recent challenge was walking 222 kilometers to the South Pole raising funds

for our charity, the KMG Foundation.

Patrick is a member of the Institute of Directors, a Fellow of the Royal Society of

Arts, actively involved with the Institute of Economic Affairs, as well as a Board

member of the VLV (Voice of the Listener & Viewer). He regularly supports local

charities including the Outwood Cricket Club of which he was recently

appointed Vice Chairman.

Jenna Duffett

Director, Chartered Financial Planner and Compliance Officer

Jenna has worked in the financial services sector for 17 years including 12 years

with the KMG team. Advising clients on all areas of financial planning, Jenna is

qualified to advise on specialist areas including pensions, mortgages, post

retirement mortgages (lifetime mortgages) and long term care planning. As

Compliance Officer, Jenna is responsible for maintaining our authorisation with

the Financial Conduct Authority.

In her spare time Jenna is a parent Governor as well as an active member of the

schools’ PTA acting as Treasurer and fundraising for the school.

Andrew Heath

Investment Manager

Andrew has worked in the financial services industry for over 18 years,

predominately working within investment research developing portfolio strategies

and fund selection. Andrew has worked for Multi-Managers and independent

wealth managers gaining a broad and in-depth knowledge of both markets and

investment research. He currently holds the IMC and ACSI qualifications.

Raj Hallen

Investment Manager

Raj started in the investment management industry in 1990 and has managed

money for clients on both an advisory and discretionary basis during that time; a

period which has seen a number of different stock market investment cycles.

During his career he has also spent some time as a Deputy Chief Investment

Officer for a leading financial institution. Raj holds both financial planning and

investment qualifications and is currently a Chartered Wealth Planner.

When not working Raj enjoys going to the gym, playing squash and dancing.

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Lisa Jones

Investment Research and Fund Analyst

Lisa has worked in the Financial Services industry for 21 years, the last two at KMG.

In her previous role at Coutts she attained the Investment Operations Certificate

and last year completed the Certificate in Discretionary Investment

Management. She is currently studying towards the IMC qualification.

Having a mathematics background, Lisa enjoys the quantitative analysis that is

integral to her role. She works closely with the Investment Managers to assess new

funds and review existing funds to ensure that our recommendations are suitable.

Alongside this she completes research on a wide variety of investment products.

Lisa’s twin daughters are both in their first year at University so she is enjoying the

peace and quiet at home, finding the time to run regularly and experiment in the

kitchen.

As well as the above individuals, all of the financial planners of KMG Independent Limited attend

our Investment Committee which meets every month and decides upon the investment process

and strategy for the company. This ensures a robust process and that the decisions made are

based on the needs of our clients.

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Our service levels and charges

Before we provide you with investment advice, we will discuss our charges and payment options

with you and answer any questions you may have. We will not charge you anything until we have

agreed with you how we are to be paid.

Initial consultation

A no obligation initial consultation will be provided by your financial planner.

Initial portfolio implementation

This will be in conjunction with your financial planner who will:

• provide an initial meeting to agree your objectives and risk appetite

• provide a personalised recommendation report detailing the portfolio proposed

• with your initial agreement, implement the portfolio recommendation

Our fees:

There are no initial charges for the creation of your portfolio or additional contributions paid in.

Service and charges for ongoing portfolio management

We provide the following services to all our individual clients:

• Discretionary Investment management providing implementation at outset to a portfolio

suitable to your needs and financial objectives as well as continued active management of

your funds

• Bespoke research on request

• Regular valuations on an annual or six-monthly basis through your financial planner

• Tax summaries provided to you and your financial planner for assisting you with the

completion of tax returns each year

• Regular newsletters and investment bulletins

• Discretionary fund management – avoiding endless papers to sign!

• Access to our investment specialist when needed via your financial planner

• Proactive management of your affairs

• Regular updates via your financial planner and bulletins.

Our fees:

0.25% charge for ongoing management of your funds plus VAT (0.3% inclusive of VAT).

For bespoke research we will charge £300 plus VAT per hour chargeable in 15 minute sessions.

Charges for additional services

Ad hoc valuations £500 each

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Appendix 1 – Best execution policy summary

Overview

It is in the interests of our clients and our firm that we obtain the best possible result when placing

orders with other firms e.g. third party brokers and fund managers for the execution of client

orders or when transmitting orders on behalf of clients. We are required to take all reasonable

steps to provide best execution when carrying out such transactions and, on your request, to

provide you with a copy of the policy that we have adopted to achieve that objective.

This best execution policy applies to orders in financial instruments such as funds and other

securities. You should read this policy in conjunction with your discretionary management

agreement.

Execution factors

When placing orders with other firms for the execution of orders or when transmitting orders, we

will make every effort to ensure the best possible result for our clients taking into account the

following factors:

• Price

• Cost

• Speed

• Likelihood of execution and settlement

• Size

• Nature of the order

• Any other relevant consideration

For retail clients, the price and cost of execution of the order will normally be the most important

aspect in obtaining the best possible result. We will therefore assume this is the most important

outcome for your transaction unless you tell us otherwise.

Executing your order

In arranging for the execution of your order:

• We may use a third party broker or platform to execute your order

• We may trade as an agent (where our scope of regulatory permissions allows us to do so)

Execution venues

All orders placed by us are executed through the following venues/third parties:

• Platform providers/trading platforms

We will regularly assess the venues/third parties available to us to identify those that will enable us,

on a consistent basis, to obtain the best possible result when arranging the execution of your

orders. The list will then be updated, where necessary, following such assessment.

The third parties have responsibilities in relation to best execution and client order handling

themselves. We will also undertake periodic monitoring to ensure that they are meeting the

relevant requirements.

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Client specific instructions

If you have given instructions that price is not the most important factor in executing your

instructions, we will make every effort to comply with your instructions but cannot guarantee this.

This may be due to either the nature of the order, or the type of financial instrument you wish to

trade in.

We will make all decisions as to where the orders are placed in relation to the execution venue.

We will therefore not accept specific instructions from clients regarding the venue where your

order is executed.

If we do accept any client specific instructions, you should be aware that this may prevent us

from following the processes set out in this policy which have been designed to obtain the best

possible results for the execution of those orders in respect of the elements covered by those

specific instructions.

Collective investment schemes

For orders in collective investment schemes e.g. unit trusts, OEICs and investment trusts, we will

place the order directly with the fund manager/platform provider and/or the operator of the

collective investment scheme.

Charges

It is our policy that fees and charging structures will not influence either the selection of execution

venues, or the order flow that follows as a result of the execution process. We will therefore not

discriminate between the execution venues we use to arrange execution of your orders.

Monitoring and review of our execution policy

We will regularly monitor the effectiveness of our best execution policy to identify and, where

appropriate, correct any deficiencies. In particular, this will cover the execution quality of any

third parties referred to in the policy.

We will also review this best execution policy at least annually and whenever there is a significant

change that affects our ability to continue to obtain the best possible results for our clients.

Staff understanding

All relevant staff are made aware of this policy to highlight and emphasise the importance of best

execution.

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Appendix 2 – Conflicts of interest policy summary

The purpose of our conflicts of interest policy is to:

• Identify the circumstances which constitute or may give rise to a conflict of interest entailing a

risk of damage to our clients

• Specify the procedures to be followed and measures to be adopted in order to manage such

conflicts.

In preparing the policy we have taken into account a number of factors including:

1. Whether circumstances might arise where we make a financial gain or avoid a financial loss

at the expense of you as a client

2. Whether we have an interest in the outcome of a service provided to you distinct from your

interests

3. Whether we have a financial or other incentive to favour the interest of another client or

group of clients over your interests

Examples of the potential conflicts of interest we have identified include:

1. Where we have confidential information regarding an existing or former client which would

be of value to another part of our firm or to other clients of our firm.

2. If a transaction carried out on your behalf relates to an investment in respect of which we or

an associate may benefit from a commission, fee, mark up or mark down payable otherwise

than by you as a client, and we or an associate may also receive fees from the counterparty

to such a transaction.

3. If we act as agent for you as a client in relation to transactions in which we are also acting as

agent for other clients and associates.

4. Where we have an interest in other financial services companies. Where this applies, details

will be disclosed in Section 5 – Our obligations of this Discretionary Management Agreement.

Against this background our conflicts policy can be summarised as follows:

1. Where a conflict arises, your interests as a client will always be put before our interests and

those of our employees.

2. Where our firm has a material interest in a transaction to be entered into for you, all

reasonable steps will be taken to ensure fair treatment for you.

3. We have established procedures to ensure fair treatment between clients. For example,

when executing an aggregated order for a client which is not filled, securities which are

obtained are allocated fairly between clients.

4. We will not enter into dealing arrangements that could compromise our ability to comply

with our best execution obligations.

5. We have a policy designed to minimise the risk of conflicts arising in situations where staff

receive or provide gifts/inducements from clients or third parties.

6. We have a personal account dealing procedure to reduce potential conflicts in situations

where staff deal for their own account.

7. We have internal organisational arrangements which act as information barriers controlling

the disclosure of information within the firm and preventing the unauthorised release of

restricted information to other areas of the firm.

8. We have an independence policy that requires staff to act disregarding any material interest

or conflict of interest when advising a client or dealing for a client in the exercise of

discretion.