Vanguard Personal

Financial Planning Service

Vanguard Investment Advice Service Terms

APRIL 2021
Introduction
These are the Terms for the Vanguard Investment Advice
Service (“VIAS”) provided as part of the Vanguard Personal
Financial Planning (“VPFP”) Service. We will ask you to
accept these Terms prior to completing your online financial
profile on the Vanguard website. Once you have completed
your financial profile, we will then ask you to submit a
declaration so that we can generate a financial plan for you.
Together with your declaration, these VIAS Terms form a
binding legal agreement between you and Vanguard Asset
Management Limited (“Vanguard”) for the VIAS.
Although VIAS forms part of the overall VPFP Service, these
VIAS Terms will only apply to the one-off provision of the
financial plan to you and will not apply to the Financial Plan
Management Service (“FPMS”) you may agree to if you
accept the financial plan. If you sign up to the FPMS, we will
implement your financial plan and will review it periodically
to check it remains suitable for you.
Before accepting these services, you should read these
VIAS Terms, together with the important disclosures in the
Legal Information page at www.vanguardinvestor.co.uk
and the Initial Disclosure Document. Information on how to
access these documents is available on request.
If there is anything in these VIAS Terms which you do not
understand, please contact us using the details set out
below.
The definitions explaining the phrases we use in these
Terms are set out in Appendix 1.
Vanguard
Vanguard Asset Management Limited is authorised and
regulated by the Financial Conduct Authority in the UK
(under firm reference number 527839). Its registered office
is at 4th Floor, The Walbrook Building, 25 Walbrook, London
EC4N 8AF. The contact address for the FCA is 12 Endeavour
Square, London E20 1JN.
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How to contact Vanguard
We recommend that you contact us through secure mail
via your online account at www.vanguardinvestor.co.uk or
through your VPFP Profile. Alternatively, you may email us
at personalinvestors@vanguard.co.uk. Please do not include
any account details if you contact us by email.
You can also call us on 0800 5870475 (Monday to Friday,
excluding public and bank holidays).
Complaints
If you have a complaint in respect of the Vanguard Personal
Financial Planning Service or any part thereof, please
contact us using the details above. A copy of our Complaints
Handling Policy is available on the website. If you are not
happy with our response, you can refer your complaint
to the Financial Ombudsman Service or The Pensions
Ombudsman (as relevant) by one of the methods below:
Financial Ombudsman Service
Exchange Tower,
Harbour Exchange Square,
London E14 9SR
Telephone: 0800 023 4567 (call charges will vary)
Email: complaint.info@financial-ombudsman.org.uk
Website: www.financial-ombudsman.org.uk
The Pensions Ombudsman
10 South Colonnade,
Canary Wharf,
London E14 4PU
Telephone: 0800 917 4487 (call charges will vary)
Email: helpline@pensions-ombudman.org.uk
Website: www.pensions-ombudsman.org.uk
Vanguard and the Vanguard Personal Financial Planning
Service are covered by the Financial Services Compensation
Scheme (“FSCS”). You may be entitled to compensation from
the FSCS if we are no longer trading or are declared to be in
default and cannot meet our obligations to you. This depends
on the type of investment and the circumstances of your
claim. Most types of investment business are covered up to a
maximum of 100% of the first £85,000 per person. In respect
of money held with a bank (i.e. cash within your Vanguard
Personal Pension) the maximum amount of compensation in
respect of the account-holding bank’s insolvency is £85,000.
Our current banking partner is HSBC plc and we will inform
you if this changes. The limits may change in the future. For
more information about how the FSCS might apply to you,
please contact us or visit the FSCS website at fscs.org.uk.
The FSCS’s address is 10th Floor, Beaufort House, 15 St
Botolph Street, London EC3A 7QU.
Contents
1. Description of Services 3

2. Our role 3

3. Communications 3

4. Your Vanguard Personal Financial Planning Service Profile 4

5. Nature of the investment advice 4

6. Suitability of investment advice 4

7. Charges 4

8. Closing your VPFP Profile 5

9. Our responsibilities to you 5

10. Your responsibilities to us 6

11. Your personal information 6

12. Intellectual property 6

13. Changing these VIAS Terms 6

14. Disputes and governing law 7

APPENDIX 1 - Definitions 8

APPENDIX 2 - Summary Conflicts of Interest Policy 10

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1. Description of Services
1.1 The VIAS is an online financial planning service. The
VIAS is designed to create a personalised, goal-based
financial plan.
1.2 In order to access the VIAS, you must register to
create a VPFP Profile through the Vanguard Personal
Investor Platform. Access will be granted and
maintained in accordance with
www.vanguardinvestor.co.uk website terms and
conditions of use.
1.3 Once you have set up your VPFP Profile, you will be
taken through a detailed fact-find process to allow us
to gather information we need to provide you with
advice and better understand your financial goals.
This will all happen within the Vanguard Personal
Investor Platform and will include questions about (a)
you; (b) your financial circumstances; (c) your
knowledge and experience of investments and
investing; (d) your selected risk profile; and (e) your
financial goals.
1.4 Vanguard will rely on the information you provide
through your VPFP Profile to provide you with
investment advice. You accept that we will treat the
information as accurate and complete.
1.5 Once we provide you with a financial plan, we will
ask you whether you want us to provide you with the
our on-going financial plan management service (the
“FPMS”) in relation to some or all of your Accounts.
If you would like to proceed with the FPMS, we will
ask you to sign up to separate FPMS Terms which
will govern our relationship for the FPMS.
2. Our role
2.1 In all of our dealings with you we will comply with
these VIAS Terms and Applicable Regulations.
2.2 Your Vanguard Client Terms shall continue in full
force and effect in respect of your Accounts. In the
event of a conflict between these VIAS Terms and
the Vanguard Client Terms, these VIAS Terms shall
take precedence in respect of the financial planning
service provided through the VIAS.
2.3 Our Conflicts of Interest Policy sets out the types of
actual or potential conflicts of interest which affect
our business and provides details of how these are
identified and managed or prevented. A summary of
our current policy is set out in Appendix 2. You have
the right to ask us for further information regarding
our Conflicts of Interest Policy.
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2.4 The FCA Rules require us to classify all investors. The
VIAS is provided by us to “retail clients”. Unless we
tell you otherwise, we will treat you as a retail client
under the FCA Rules. This means you get the highest
level of protection available under the FCA Rules.
3. Communications
3.1 Our service is intended to be exclusively online. By
signing up to this service and accepting these VIAS
Terms, you agree that we will send documents to your
secure VPFP Profile mailbox. We will not generally
communicate with you by post. All our documents and
communications with you will be in English.
3.2 You should not enrol in the VIAS if you do not have
internet access or do not want to accept investment
advice from us by means of electronic delivery. You
are required to maintain an active email address.
3.3 If we do communicate with you by post, we will
write to you at the last address you gave us. You
must tell us if your address or any of your other
contact details change. If communications we send
to you are returned to us, we may put restrictions on
your VPFP Profile.
3.4 You can communicate with us securely by registering
for and using our online services at
www.vanguardinvestor.co.uk. You can also contact
us by email at personalinvestors@vanguard.co.uk or
by calling us on 0800 587 0475 (Monday to Friday,
excluding public and bank holidays).
3.5 We will act and/or rely on any communication which
we reasonably believe to have been made by you,
and so you should make sure you keep your security
details safe as required in accordance with the
Vanguard Client Terms. For security purposes, we
may ask you to confirm some information in writing
before we act on any communication from you.
3.6 You agree that Vanguard may provide, in accordance
with our Privacy Policy, alerts and notifications of our
products and services to you via electronic
transmission, including via any email address or
mobile number you provide to us.
3.7 We are obliged under the FCA Rules to record certain
communications (including telephone calls, video and
electronic communications and instant messaging)
which relate to, or are intended to lead to, the
conclusion of a contract in a financial instrument. You
have the right to request a copy of such recordings
relating to your VPFP Profile at any time in the five-
year period beginning on the date of the relevant
 recording. We may monitor and record other
communications and calls in accordance with the
Vanguard Client Terms and Applicable Regulations.
4. Your Vanguard Personal Financial Planning
Service Profile
4.1 You can generally open a VPFP Profile and use the VIAS
if you are (i) an individual aged 18 years or over; (ii) a UK
resident; (iii) you pay personal tax in the UK; (iv) you
have opened an ISA, a General Account or a Pension
Account with us in accordance with the Vanguard Client
Terms; and (v) you have a minimum balance of £50,000
in aggregate across your Account(s).
4.2 To open a VPFP Profile, you will be provided with a
link to a secure website which you will need to open
in a new web browser having logged onto the
Vanguard Personal Investor Platform. This will begin
the VPFP Profile opening process.
4.3 The VIAS is not available under these VIAS Terms to
US persons. “US persons” include any citizen of the
United States of America (US), any person holding a
US passport (regardless of residency or domicile),
and any person who has an obligation to pay tax to
the US tax authorities on their worldwide income. If
you are or you become a US person, we may restrict
the services we offer you and inform the relevant
authorities and reserve the right to dispose of
investments from your Account(s) without notice. We
may alternatively close your VPFP Profile.
The Vanguard Investment Advice Service
5. Nature of the investment advice
5.1 e will provide you with investment advice in a
W we will implement your financial plan and will review
simplified and easy to understand format.
5.2 We will be providing “restricted” advice or “non-
independent” advice. This means that Vanguard,
when determining your personalised, goals-based
financial plan, will only advise you on Vanguard Funds,
the Pension Account, the ISA, and the General
Account available on the Vanguard Personal Investor
Platform and will not consider any other products
which might be otherwise available on the market.
5.3 The VIAS is a one-off service and we will provide you
with a financial plan, which you will be able to
download at any time from your VPFP Profile prior to
its closure in accordance with these VIAS Terms.
Your financial plan will not be updated as part of the
VIAS. Should you want to be provided with an
ongoing service you may elect to move onto our
FPMS, through which we will implement your
financial plan and will review and update it
periodically to check it remains suitable for you.
5.4 In your financial plan, we may also provide you with
strategic or generic financial planning advice to help
you achieve your financial goals, such as suggestions
on the level of employee contributions you make to
any employer pensions you have. This advice does
not involve the provision of personal
recommendations on specific investments.
6. Suitability of investment advice
6.1 In order for Vanguard to act in your best interests
when providing you with the financial plan and related
advice, we need to assess that the VPFP Service is
suitable for you. So that Vanguard can make this
assessment, you will be required to provide Vanguard
with a range of information. It is important that you
ensure that all information provided to Vanguard is
accurate and up-to-date, because this is the
information we use to provide you with investment
advice. Vanguard is entitled to rely on the information
provided by you unless it is aware that the information
is manifestly out of date, inaccurate or incomplete.
6.2 The financial plan and related advice you receive
through our VIAS service is provided as a one-off
service. It is not an ongoing service so doesn’t include
an annual review of how suitable the recommended
portfolio services, investments or pensions are for
you. You can request this kind of review at any time,
but it would be treated as a new round of financial
advice and would be charged as such. You may, of
course, elect to move onto our FPMS, through which
and update it periodically to check it remains suitable
for you. Further details of this are set out in your
financial plan.
7. Charges
7.1 Although you will be able to access your VPFP Profile
on an ongoing basis, the provision of the financial
plan is a one-off service for which there is no charge.
Should you require a new or updated financial plan in
the future, and you are not using our FPMS, you will
need to sign up to these terms again and we reserve
the right to introduce a fee at that time in accordance
with Clause 7.2. All other charges including any
account fees, transaction costs or expenses
applicable to your existing Account(s), as set out in
your Vanguard Client Terms.
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7.2 We may also decide to introduce a fee for the VIAS
and/or the VPFP Profile and will notify you in advance
9. Our responsibilities to you
in accordance with Clause 13 of these VIAS Terms.
9.1 If we are negligent, knowingly default, act fraudulently,
8. Closing your VPFP Profile
Your right to close your VPFP Profile
8.1 You may close your VPFP Profile at any time by
informing us (by secure message from your VPFP
9.2 We will not be legally responsible to you:
Profile) with immediate effect subject to the
completion of our VPFP Profile closure process in
accordance with Clause 8.7.
Our right to close your VPFP Profile
8.2 We will close your VPFP Profile if you have not
accepted the FPMS Terms within 30 days of us
providing you with your financial plan.
8.3 We will also close your VPFP Profile if you complete
it between 6 March to 5 April in any given year and
do not accept the FPMS Terms by midnight on 5
April in the same year.
8.4 We can close your VPFP Profile by giving you a
minimum of one week’s notice, although we will
always try to give more notice where reasonably
practicable.
8.5 We may, in exceptional circumstances (for example,
if you are abusive or threatening towards any of our
staff) or if legally required to do so, close or suspend
your VPFP Profile or any or all of your Accounts or
suspend the provision of certain or all services to you
without giving you advance notice.
What happens once your VPFP Profile is closed?
9.3 Whilst the VIAS aims to improve your chances of
8.6 Until the process of closing your VPFP Profile is
complete, these VIAS Terms will continue to apply.
This may take up to two Business Days. We shall
inform you via email once your VPFP Profile is closed.
8.7 Once we close your VPFP Profile you will no longer
be able to access the VPFP Profile and you should
download your financial plan and any other
information you might need beforehand.
8.8 If, as a result of us closing your VPFP Profile, you
wish to close your Account(s), you may ask us to do
so in accordance with the Vanguard Client Terms and
we will assist you in Transferring Out your Vanguard
Funds to an alternative service provider (or
Authorised Scheme in respect of your Pension
Account) of your choosing.
5
Our responsibilities to each other
or breach these VIAS Terms or Applicable Regulations
(as relevant), then we are legally responsible to you for
the direct results of our actions.
if you suffer a loss because you fail to comply
with these VIAS Terms (including, but not
limited to, providing Vanguard with inaccurate or
incomplete information) or with any applicable
legal requirement or because of any action which
we take or refrain from taking in order to ensure
that we comply with any legal requirement;
if you suffer an indirect, special or consequential
loss which is not directly related to your Vanguard
Funds, or the loss of an investment opportunity;
if you suffer any loss or damage as a result of an
external event or something else that is outside
our reasonable control, or as a result of any steps
which we reasonably take in response to such;
if you suffer a loss because you are unable to
access your VPFP Profile or a Vanguard financial
planner whilst our online and other systems are
unavailable due to maintenance or upgrade (and
we may not always be able to give you advance
notice when such an outage may occur); or
for any charges and expenses that we, or any of
our agents, legitimately make or receive.
investment success, you acknowledge that all
investment services and subsequent investing involve
some risk, including possible loss of capital. There’s
no guarantee that any particular asset allocation or
mix of funds or any suggestion we give in the
financial plan will meet your investment objectives or
provide you with your desired retirement goal. The
VIAS provides investment advice using analytics
supported by historical information. There is no
guarantee that any investment advice will meet your
investment objectives, provide you with a given level
of income, or protect against loss, particularly where
future market conditions are drastically different from
the information used to create your strategy.
Diversification does not ensure a profit or protect
against a loss and past performance is not a reliable
indicator of future returns.
10. Your responsibilities to us
10.1 You agree to reimburse us for any liabilities suffered
by us in connection with the VIAS if they are caused
by your negligence, default, fraud or breach of these
VIAS Terms.
10.2 By opening your VPFP Profile and using the VIAS,
you agree that you will not take part in activity that
may be considered to be Market Abuse. If we believe
that your VPFP Profile is being used to engage in
Market Abuse, we reserve the right to take such
action as we deem to be appropriate.
10.3 The information you provide to us will be used to
assess the suitability of the investment advice we
provide to you and therefore you agree that all of the
information you provide to us is true, accurate,
reliable, up-to-date and sufficiently detailed and that
Vanguard can rely on this information.
11. Your personal information
11.1 We are the data controller for the personal
information you give us. We will not pass your
personal information to anyone, other than as
detailed in our Privacy Policy (which can be found
at www.vanguardinvestor.co.uk/privacy-policy).
12. Intellectual property
12.1 All copyright, trademarks and other intellectual
property in the materials and information on our
website are owned or licensed by the Vanguard
Group or by external content providers. Nothing in
these VIAS Terms or on the website should be
regarded as granting any licence or right to or in any
trademark or service mark of the Vanguard Group or
any third party.
13. Changing these VIAS Terms
13.1 You agree to us transferring all or any of our rights
and obligations under these VIAS Terms to any
appropriate Vanguard Group Company or any third
party which is appropriately regulated and authorised
under the Applicable Regulations. If we do this, we
will give you reasonable advance written notice of
the transfer. The new provider will take on our
obligations to provide the services under these VIAS
Terms in our place. We will not transfer our rights
and obligations to the new provider if to do so would
put you in a worse position.
13.2 We may make reasonable and appropriate changes to
these VIAS Terms at any time whilst your VPFP
Profile is open as follows:
to meet any current or future change in law,
including rules established by the FCA or
regulation, guidance or regulatory approach;
to make these VIAS Terms easier to understand,
including to correct any inaccuracies, omissions,
errors or ambiguities;
to take account of any reorganisation of the
Vanguard Group of companies, or a transfer of
rights under Clause 13.1;
to reflect any changes to the services which we
offer under these VIAS Terms, or changes to our
systems, our processes and procedures, market
practice or customer requirements;
to reflect any changes to terms agreed between
us and any third parties which are relevant to your
VPFP Profile;
to increase the Charges you pay in accordance
with Clause 7 (including, but not limited to, to
reflect any changes to the costs that we or third
parties incur); or
to make any other changes which we believe in
good faith are reasonable provided that you are
not materially disadvantaged by such changes.
13.3 Where we reasonably consider that changes are
material or detrimental to you we will notify you,
giving you a minimum of one month’s notice of
the proposed change and our reasons for making
the changes. The latest version of these VIAS
Terms will always be available on our website at
www.vanguardinvestor.co.uk.
13.4 Changes that are necessary due to reasons
outside of our control (e.g. a change in legislation/
resulting from an act of a third party) and/or which
are immaterial and not to your detriment may take
effect immediately. We will tell you as soon as
possible after the change if we have not been
able to inform you in advance.
13.5 If you are not happy with any change we make or
plan to make to the VIAS Terms, you can close
your VPFP Profile in accordance with these VIAS
Terms. We will not charge you a fee for this.
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14. Disputes and governing law

14.1 These VIAS Terms represent the entire agreement

between you and Vanguard in relation to the VIAS
and will be governed by and construed in accordance
with English law. You and Vanguard submit to the
exclusive jurisdiction of the English courts to settle
any disputes arising under these VIAS Terms.
Neither Vanguard nor you intend any provision of
these VIAS Terms to be enforceable by any person
other than ourselves or our respective permitted
successors or assignees. If any provision in these
VIAS Terms is held or made unlawful, void or for any
other reason unenforceable by a court, statute,
regulation or otherwise, the remainder of these VIAS
Terms will not be affected.

7
Appendix 1 - Definitions
The following words and expressions used in these VIAS
Terms have the meanings set out below:
Account – an account with Vanguard that enables you
to invest in Vanguard Funds. An Account may be a
Pension Account, an ISA, or a General Account.
Applicable Regulations – any rules, regulation or
guidance published by the FCA, together with any
other applicable rules, regulations or laws as may be
applicable to your Product.
Authorised Scheme – a “UK registered pension
scheme” or a “qualifying recognised pension scheme”,
such terms as defined in the Finance Act 2004.
Benefit - any payment made from your Vanguard
Personal Pension to you or person(s) legally entitled to
receive such payments.
Business Day – a normal business day, excluding
Saturdays, Sundays and any UK public holiday.
Charges – the charges that apply to the services we
provide you with under these Terms, set out in Clause 7.
Contribution – a payment by you, an individual on your
behalf and/or an employer to your Vanguard Personal
Pension.
Exchange Traded Fund (or ETF) – an investment fund
listed and traded on a stock exchange.
FCA – the Financial Conduct Authority, or any other
regulator that succeeds it.
FCA Rules – the FCA’s Handbook of rules and guidance,
as amended or replaced from time to time and
including, where relevant, any directly applicable EU
regulation.
Financial Plan Management Service (“FPMS”)
– means the automatic rebalancing service we can
provide to you within the parameters of the financial
plan generated by the VIAS.
FPMS Terms – the terms that apply to the FPMS (as
amended from time to time).
General Account – the investment dealing account
established in accordance with your Vanguard Client
Terms. Initial Disclosure Document – the document
which sets out the nature, scope, associated risks and
indicative costs of the VPFP Service (as applicable).
ISA – an Individual Savings account (excluding any
Junior ISA) managed under the ISA Regulations. For the
purposes of these Terms the term ISA includes a Stocks
and Shares ISA. When we refer to ISA, we mean your
Vanguard Funds and any cash balances held in your
Vanguard ISA and all income and other rights, and any
tax relief that you may receive on them.
ISA Regulations – the Individual Savings Account
Regulations 1998 (as amended from time to time).
HMRC – Her Majesty’s Revenue and Customs or any
entity that succeeds it.
Market Abuse – means any circumstances in which
investors are unreasonably disadvantaged, either
directly or indirectly, by others who have used
information which is not publicly available, have
distorted the price-setting mechanism of financial
instruments or have disseminated false or misleading
information.
OEIC – an open-ended investment company based in
the UK, including any sub-fund of an umbrella OEIC.
Pension Account – a cash and dealing account we open
for your Vanguard Personal Pension that enables you
to make Contributions to and take Benefits from the
Scheme.
Product – a Vanguard Personal Pension, ISA or General
Account.
Scheme – The registered self-invested personal pension
scheme known as the “Vanguard Personal Pension”
which has been established by the Trust Deed and
registered with HMRC in accordance with Chapter 2 of
Part 4 of the Finance Act 2004.
Stocks and Shares ISA – an ISA for stocks and shares
holdings.
Transfer Out – the transfer from us:
of the value of all or part of your Vanguard
Personal Pension to an Authorised Scheme;
of all or part of your ISA or cash or investments in
your ISA to another ISA manager; or
of all or part of the investments in your General
Account to another investment service provider.
Trust Deed – means the trust deed governing the
Vanguard Personal Pension dated 8th July 2018
between Vanguard and the Trustee (as amended from
time to time).
Unit Trust – an authorised unit trust scheme.
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 VAT – Value Added Tax
Vanguard – Vanguard Asset Management, Limited.
The term “Vanguard” also includes, where applicable,
certain affiliated companies within the Vanguard Group
and any company to which we might transfer our rights
and responsibilities under these Terms in future (under
Clause 13.1).
these Terms, through which Vanguard will deliver the
VPFP Service.
Vanguard Personal Investor Platform – means
the digital or internet interface platform operated by
Vanguard where you set up your VPFP Profile and
receive the VIAS, DMS and/or the fund dealing and
investment services (as applicable).

Vanguard Client Terms – the terms that you have with Vanguard Personal Pension – means the pension
us (as amended from time to time) in relation to our arrangement or arrangements established by you, or on
execution-only service, for the Pension Account, ISA, your behalf, under the Scheme.
and/or the General Account, as applicable.
VPFP Service – means the Vanguard Personal Financial
Vanguard Fund – any open-ended investment Planning Service, which comprises of the VIAS and
company, OEIC, unit trust, ETF or other form of DMS.
collective investment scheme operated by Vanguard and
We, our or us – Vanguard.
made available through the Vanguard Personal Investor
Platform. You, your or yourself – the person who does business
with us under these Terms, including your personal
Vanguard Group – Vanguard and any company affiliated
representatives, your authorised representatives or
to Vanguard.
agents.
Vanguard Investment Advice Service (“VIAS”) – an
online advisory service designed to support and help
investors understand their financial circumstances and
define their financial goals, leading to the creation of a
personalised, goal based financial plan.

Vanguard Personal Financial Planning Service

Profile (“VPFP Profile”) – the profile (based on your
personal and financial circumstances including income
and expenditure, assets and liabilities and attitude to
investment risk) established for you, in accordance with

9
Appendix 2 - summary conflicts of interest policy
Introduction
The Vanguard Group is a global organisation which provides
a range of different financial services. From time to time,
there is a possibility that we (or another member of the
Vanguard Group, or a partner firm with whom we have a
business relationship (an “associate”)) may have interests
which conflict with our clients’ interests, or with the duties
that we owe to our clients.
These include:
conflicts arising between our interests, our associates’
interests and our employees’ interests, on the one
hand, and the interests of our clients, on the other; and
conflicts between different clients themselves.
We have established procedures and implemented a
policy designed to identify, and either to manage or, where
possible, prevent such conflicts.
Our procedures include: systems and controls to ensure
that different parts of our business operate sufficiently
independently of each other; restrictions which are imposed
on staff in relation to gifts and entertainment and personal
dealing in securities; and a policy on remuneration to ensure
that we do not inappropriately incentivise our directors and
employees.
We do not give or receive inducements. From time to time
we may receive or accept minor non-monetary benefits
which are capable of enhancing the benefit to our clients
and in accordance with the FCA regulations.
Identification and management or
prevention of conflicts
We also keep a register listing all the types of conflict which
we have identified as a risk for our business and customers,
and detailing the controls to prevent or manage them to
ensure there is no risk of damage to our clients’ interests.
A key part of our policy involves making sure that persons
engaged in different business activities involving a conflict
of interest carry on those activities separately from one
another and without sharing information. In exceptional
circumstances, our procedures and controls may not be
sufficient to ensure that a potential conflict of interest does
not damage a client’s interests and it may not be possible to
prevent the conflict from arising altogether.
In such exceptional circumstances, we may be obliged:
to inform affected clients of the potential conflict,
providing full details of it to allow the client to form their
own view of its significance for them. We will seek
formal consent to proceed in those circumstances; or
to inform affected clients that we cannot act because
there remains an unacceptable risk of damage to their
interests.
If you have further questions about our conflicts of interests
procedures, you may request further information using the
contact details provided in the Terms.
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These VIAS Terms are issued by Vanguard Asset Management, Limited which is authorized and regulated by the Financial Conduct Authority.
Registered in England and Wales. VAT number 100127685
© 2021 Vanguard Asset Management, Limited. 363_0321