E. Investment Account Terms Supplement
We appreciate that our customers are placing significant faith in us when investing in our products, and we want to make sure that you, as our customer, understand the ins and outs of how our services work. We are also required to present certain information to you by law or regulation.
We have included all this information in the following terms, which govern your dozens investment account.
1. Important information
We provide certain investment services through our app. Our approach is to empower customers to make investment decisions for themselves, and we support you with information and guidance so that you can make the best choices for you. We don’t provide investment advice or personalised recommendations – that means we won’t tell you what to invest in. However we want to give you the right tools so that you can make the best investment choices for yourself.
Definitions are set out at the end of this supplement.
We provide the following services to our customers:
- unique financial products
- strategies (which may be exchange traded funds (ETFs) or exchange traded certificates (ETCs) or other open-end funds, which will be clearly disclosed to you) to suit your interests, created and managed by highly skilled investment managers
- discretionary investment management services to ensure your account is kept in-line which whichever strategies you choose
- arranging safekeeping of your investments
- facilitating your payments for investments
- education, guidance and tools to empower you to make investment decisions for yourself
- a user-friendly app.
3. Checking done by us
Suitability: Before you make an investment with us, we will ask you a number of questions to assess whether the investment you want to make is suitable for you. We base the outcome of the assessment on the information you have told us about your knowledge and experience of investing, your financial situation and objectives. The questions are designed to ensure you do not invest into a product that does not meet your needs.
4. Customer categorisation
We are required by our regulator to categorise our customers into groups so that we can treat them according to their level of knowledge about investments. We will treat you as a retail client as defined by the FCA Rules, in accordance with the FCA’s client categorisation criteria. This gives you the greatest level of protection under the FCA Rules.
We have entered an agreement with Third Platform Services (TPS) to provide execution services on your behalf.
We have also arranged for TPS to provide custody services to you, in accordance with instructions submitted by dozens on your behalf. You agree to dozens providing such instructions to TPS on your behalf.
6. Conflicts of Interest
Our conflicts of interest policy is an important aspect of our procedures and more detail on this can be found in Appendix 3.
Occasions may arise where dozens, one of our affiliates or one of our customers have some form of interest in business being transacted by you and a conflict of interest may arise. We will manage any such conflict, or potential conflict to ensure that it does not materially affect the transactions we carry out for you. We will inform you if we consider that we cannot adequately manage a conflict.
dozens also has in place procedures to comply with the Bribery Act 2010. We treat accusations of bribery and corruption with the utmost seriousness and deal with them accordingly.
7. Discretionary management
You instruct us to carry out certain functions on your behalf, or make certain decisions on your behalf without the need to ask you for permission each time, which means we would act for you in a discretionary manner. These functions are namely to allocate the money you want to invest between payments and investments, and carry out any required rebalancing in relation to a strategy. Any discretionary service enables us to make investment decisions on your behalf without needing to obtain your approval for those transactions.
dozens offers discretionary investment management and our investments may cover all world markets without geographical spread or type of investment being restricted.
We have set out thematic strategies for you to choose from in the app. By selecting a strategy you will be selecting to invest in an exchange traded fund/certificate or other open-ended fund, and should read carefully the relevant fund documentation. We have chosen these products from global investment managers as we believe the strategies shown will be relevant to our customers. We will only make products available to you if they match the outcome of your suitability assessment.
You are required to accept the risk profile and characteristics of the relevant strategy you select. Where additional investment is made into a strategy it will be invested and managed in accordance with the risk profile selected.
Income arising from investments in a strategy will be reinvested at the discretion of dozens in line with your investment goals.
We cannot accept specific instructions relating to individual components or investments within a strategy.
When your investment cash have arrived, they will typically be invested within three working days. There may be occasions when it will take longer than this.
The impact of events and circumstances outside dozens’ control, including but not limited to the ongoing movements in the markets and fluctuations in the value of investments, will not automatically be deemed to be a breach of any strategy’s investment objectives or risk profile.
We will pool (aggregate) your transactions with those of other customers without seeking prior agreement from you. This is standard market practice, and we will only do so where we believe that this is unlikely to disadvantage your overall position, although it may do so in relation to any specific order.
10. Funding your dozens investment account
dozens has minimum investment levels depending on the investment you are interested in. Minimum investment levels will be set out in the specific investment product documents and on the app. You cannot investment in a product for less than the minimum amount.
We may accept payments via debit cards (including your dozens card), a transfer from your dozens current account and bank transfers.
You can fund your investment account either using your dozens current account, a debit card or a bank account.
If you pay by debit card, your payment will be processed by a 3rd party that is subject to the Payment Services Regulations. These payments typically take up to 4 business days to reach us (with a maximum of 7 business days), during this time the money is held by the relevant service provider in an account protected by the relevant regulations.
If we need to sell some of your assets to settle amounts outstanding on your account, we will do so, and you may incur a profit or loss. If your account becomes overdrawn, we may sell your assets to settle the account, or we may ask you to settle that overdraft (we may sell your assets to do so), and you agree to do so within a reasonable period.
11. Fees and charges
Information on dozens’ standard fees and charges are set out in Appendix 1, and the latest fees can be found on our app. Importantly, dozens only makes money when you do. This means we will not charge a management fee on days where a strategy value was less than the cash invested into the strategy, whether original purchase money or from monthly contributions.
Where your account does not hold sufficient cash to pay fees, dozens will be entitled to sell investments to the extent necessary to cover outstanding amounts due.
All tax matters relating to your own tax position are your own responsibility and we have no liability towards you with regard to your personal tax position.
Your investments will be subject to the UK taxation regime. For UK residents invested in a non-ISA account where applicable tax will be deducted from strategies we invest in, generally by the product provider.
Interest is not currently payable on cash balances held in your cash savings account. In the event this changes we will let you know.
Withdrawals must be made in accordance with the terms of each specific product, which will be contained on the app.
We will endeavour to complete withdrawals in 10 working days. There may be occasions when withdrawals take longer than this.
In relation to strategies, we seek to invest in only very liquid investments so that we can process withdrawals quickly. In the rare event that we cannot sell down your investments immediately, we will send you back all the money available, with the rest to follow when the remaining sale (s) can be completed.
When you request a withdrawal, the amount displayed on the screen is an indicative amount only. Due to investment price fluctuations between the time that you place the request and the time that you sell, the actual amount you receive may differ slightly.
By default, we will always return money to your cash savings account, and you can choose to withdraw this into your dozens current account or a bank account.
We typically only transfer cash to or from you. In exceptional circumstances where we agree to transfer your assets “in-specie” we will levy a charge per investment (line of stock) as itemised below.
15. dozens notices and reports
We will send all notices, information and other correspondence to you in the app and/or by email. You agree as an ongoing obligation to provide us with an up to date email address and to inform us as soon as reasonably practicable if this should change. dozens is entitled to rely on the last email address you have provided and an email sent to that email address by dozens shall be good service under these terms.
dozens cannot guarantee that general emails will be successfully delivered, or that they will be secure and virus free. We will not be liable for any loss, damage, expense, harm or inconvenience caused as a result of an email being lost, delayed, intercepted, corrupted or otherwise altered, or for failing to be delivered for any reason beyond our reasonable control.
If we choose to correspond by post, communications will be sent to the address you provided when you set up your account. Alternatively, we may communicate with you when appropriate by telephone.
We will provide valuation reports on a quarterly basis. A valuation report will include a breakdown of holdings within your account, the current market value, income and interest earned, and fees charged. Details of all transactions carried out on your account by dozens will be shown, as will any cash transactions that you have made to your account.
Tax reports will be available via the app on an annual basis.
16. Telephone call recording
We record all telephone calls for quality and monitoring purposes. We will store recordings securely for as long as is appropriate in accordance with GDPR.
You can give us instructions and notifications in relation to investments we hold on your behalf via the app.
We will not be obliged to act on any instruction and, in particular, we will not act on any instruction where it is illegal or against any relevant rule or regulation to do so. Where we do act on your instructions we will do so as soon as reasonably practicable once we have received them.
Where instructions given orally or by electronic communication are directed at a specific person and that person is not present to receive them, there may be a delay in acting on such instructions until actual receipt by such person.
We may act on any instruction or other notification which we believe in good faith is from you without carrying out any further checks or investigations. We will not be liable for following an instruction or notification which is not in fact genuine, or for not following, or for investigating further any instruction or notification we believe may not be genuine. We will not be liable for any error of transmission or misunderstanding, or for the fraud of any other party (except in the case of our negligence, willful default or fraud). We are not obliged to acknowledge receipt of your instructions.
18. Complaints process
If you wish to make a complaint in relation to dozens’ services, please contact us through the app, website or by emailing us at firstname.lastname@example.org. Our services team will generally come back to you very quickly, but we’ll certainly acknowledge your complaint within 5 working days. After that, we will investigate your complaint and keep you informed of progress. Within 8 weeks of receiving your complaint we will either (1) send you a “final response”, which accepts your complaint and offers redress or remedial action; or offers redress or remedial action without accepting your complaint; or reject your complaint and explain why we have done this; or (2) explain why we have not been able to complete our investigation, and inform you that you may then refer your complaint to the Financial Ombudsman Service (FOS).
The address of the FOS is Exchange Tower, London E14 9SR financial-ombudsman.org.uk. Certain customers, such as larger companies and trusts, may not have access to the FOS.
dozens maintains professional indemnity insurance to reflect the nature and scale of its business in accordance with the FCA Rules.
dozens’ investment activities are covered by the Financial Services Compensation Scheme (FSCS). This means that in the event that we are declared to be in default and cannot meet our obligations, you may be able to claim compensation. This depends upon the circumstances of the claim. The FSCS offers different levels of cover for different types of business. Most types of investment business are covered currently for 100 per cent of the first £50,000. Further information is available from the FSCS website (fscs.org.uk).
20. Circumstances on death
Should you pass away, dozens will need to receive notification as soon as possible. dozens requires official evidence of registration of death such as a registrar’s certified copy of the death certificate.
Upon receipt of evidence of your death, your investments will be frozen and will not be subject to any further rebalancing or changes. We will not be liable for any losses incurred while the account is frozen.
Your account will continue to incur fees at the normal rate, even when frozen. Fees will be taken from the available cash balance. If there is insufficient cash available we will sell down investments at our discretion to cover fees owed.
After freezing assets, we will await receipt of a letter of administration or probate to determine what to do with the assets.
You have a period of fourteen (14) calendar days, beginning on the date on which you accept these terms to cancel your account and these terms. If you wish to do this, you will need to provide us with clear notice in writing of your decision to cancel the terms, which notice must be posted to us prior to the end of the 14 day cancellation period. You are not required to give us any reason for exercising your right to cancel.
dozens will sell any investments made on your behalf but will not be responsible for any market loss that you may incur as a result of your cancellation.
If you cancel these terms within the cancellation period, we will refund any relevant fees received by us pursuant to these terms (in the event of full cancellation), except that you agree that the following will be paid if and to the extent applicable:
- for any service actually provided by us in accordance with these terms and our fees (available through the app), where you have expressly requested such performance (such as, for example, where we have provided custody of your assets and are due a custody fee in accordance with the fees);
- for any loss under a contract caused by market movements that we would reasonably incur in cancelling it, as any such market movements will be outside of our control; and/or
- for any other fees or charges due to us.
If you cancel more than fourteen (14) calendar days after the date that the terms become effective, you will not be refunded any associated fees.
It is important that you are aware that all instructions to buy or sell investments which are pending at the time of receipt of your notice to cancel, will be binding.
You may close your accounts and terminate these terms at any time by closing your account through the app. We will notify TPS of your decision to close your account and your account will terminate immediately upon receipt by TPS of our notification of termination of your account.
dozens may terminate these terms immediately by giving the customer notice via dozens app messaging and/or email in the following circumstances:
- in the event of a breach of these by the customer
- where any circumstance arises which, in dozens’ reasonable opinion, could cause a breach of law or regulation, or
- where dozens believes it is necessary to limit or protect any exposure of the customer to dozens.
We shall be entitled to terminate these terms at any time by providing you with not less than thirty (30) calendar days’ prior written notice, unless a shorter period of notice is required in order to comply with law or regulation. Any fees, charges and expenses which you owe to us under these terms will become due and payable at the expiry of this notice period.
Subject to any other provisions in these terms, the process of closing your account shall be as follows:
- we will close the account as instructed
- we will return any cash held in the account, and/or
- we will transfer your investments to another regulated financial services firm as nominated and instructed in accordance with these terms, or
- we will sell your investments and return the cash proceeds from such sale, if told to do so.
Termination of these terms by us or you shall not affect any rights or obligations which have already arisen, for example to settle transactions effected prior to the date of termination and/or to satisfy any liabilities or obligations owed to us. This shall include the making of any payments due, in respect of which we shall be entitled to retain any of your monies or assets and apply them to or towards satisfaction of such liabilities and obligations. We shall also continue to have the right to disclose information, where required, to a UK or overseas regulator.
23. Last (and still important) points
The services that we will provide under the terms of these terms are only available to individual residents over the age of 18 who meet our suitability criteria. By clicking your acceptance to these terms you warrant to us that you meet this criteria.
If you will no longer be a UK resident or resident, you must inform us promptly in writing prior to your move outside the UK as there may be certain restrictions placed on your account.
dozens is currently unable to offer services to nationals of any country listed in the United States Department of Treasury’s Office of Foreign Assets Control website at treas.gov/ofac.
These terms are provided in English, which will be the language of all communications between the you and dozens.
These terms are personal to you and you may not transfer or assign rights and obligations to any third party. dozens may assign or transfer its rights and obligations under to any affiliate or to any successor business. If this occurs, you will be notified by email and/or in app. Where we do this, you authorise us to transfer any of your money/assets held by us or on our behalf to the third party, or someone nominated by that person. We will only transfer your money and/or assets to another person who we believe will hold them under the FCA Rules or in respect of whom we have exercised all required due skill, care and diligence in assessing whether that person will apply adequate measures to protect it. Where we intend to do this, we will give you at least ten business days prior written notice. If you object to such an assignment, you may terminate these terms and close your account with us in accordance with these terms.
You acknowledge and accept that the information and data provided to you during the application process in respect of any potential investment returns are for illustrative purposes only and do not guarantee the amount of returns which you may receive if you invest with us.
dozens may amend these terms where we have a valid reason for doing so. Notification of amendments will be provided to you via email and/or through the app before they are due to take effect. Changes will take effect 10 calendar days after the notice has been sent to you (unless a later date is provided for in the notice). Any amendment to these terms will not apply retrospectively. Customers will not normally be required to sign new agreements or consent to proposed amendments which will take effect as described above. If, as a result of the amendments we make to the terms you wish to close your account with us, you may do so in accordance with these terms.
A person who is not a party to these terms will not have any benefits under the Contracts (Rights of Third Parties) Act 1999 and will not have any rights to enforce its terms.
Fees and Charges
IMPORTANT: THE FEES AND CHARGES OUTLINED IN THIS APPENDIX INCLUDE THE CHARGES PAYABLE TO BOTH DOZENS AND TPS.
1. Strategy fees
In relation to strategies dozens charges an annual management fee. Our fee is based on a percentage of the assets held with us in strategies. It includes all costs associated with the daily maintenance and management of your strategy and includes VAT where applicable. It also includes TPS’s custody and dealing fees. Please note that whilst we quote the fee as ‘annual’ it is taken monthly in arrears.
We will deduct the fee directly from the cash portion held in a strategy, so you do not have to set up a monthly payment to us. Fees will be debited on or before the 28th day of each following month and will be clearly marked on your statements.
You will only be charged fees on the strategies in your investment account, so if you added £5,000 to a strategy halfway through the month, you would only be charged for the time it was invested with us during that month.
Importantly, dozens only makes money when you do. This means we will not charge a management fee on days where a strategy value was less than the cash invested into the strategy, whether original purchase money or from monthly contributions.
The most recent version of our fees is available to view through the app.
Please note that fees can be changed at the discretion of dozens. We will notify customers of any changes to their charges with at least 30 days’ written notice.
2. Fund charges
Money invested in strategies is invested in a number of carefully selected ETFs/ETCs/open-ended funds which are generally low cost (as shown in the app), each which incurs a small charge. This is taken directly from the fund at source and goes to the fund provider. So while you do not pay the charge directly, it will affect your overall return.
3. Bond fees
In relation to dozens fixed interest bonds, your fixed rate of return is not depleted by additional fees. dozens will earn an arrangement fee from the bond issuer for its services. Such fees are disclosed in the bond terms.
For your information dozens has provided a summary of the main risks that are associated with investing and opening an account with us. This list is not comprehensive but should act as a guide for you to better understand the risks involved.
1. No Advice
We do not provide investment advice and will not be regarded as having done so. You are solely responsible for making your own independent assessment of the risks of transactions (and seeking advice from advice-giving experts if necessary). dozens has not undertaken any assessment whatsoever of your personal circumstances and will not make any personal recommendation to you. If you are unsure on any matter, you should consider taking specialised professional advice, such as financial advice, legal and tax advice in relation to your individual circumstances and requirements.
2. Investment value.
The value of your investment is not guaranteed and prices may go up as well as down. You may get back less than the amount that you originally invested.
3. Market risk
External factors may cause the value of your investments to fall. You are not certain to make a profit. You may make a loss. You may lose your entire investment.
4. Inflation risk
If the value of your investment changes by less than the rate of inflation, it will have less buying power in the future.
5. Tax risk
All UK residents are subject to the UK taxation regime. All offshore residents are subject to their local tax regimes. As a result of using our Service, your tax position may change. Levels of tax, tax rules and tax relief are subject to change. You have sole responsibility for the management of your legal and tax affairs and if you are unclear as to what your position is, you should seek professional advice.
6. Liquidity risk
dozens endeavour to ensure we only invest in liquid instruments which trade frequently and are easy to sell. Despite our best efforts, it is possible that market conditions may make it difficult to sell a position.
Conflicts of interest
We have a conflict of interest policy, which is reviewed at least annually.
We are committed to taking measures to recognise, supervise, examine and resolve conflicts of interest. We recognise that it is not possible to eliminate all sources of conflict of interest; however, safeguarding customers’ welfare remains our primary objective. This policy encompasses the relationships with customers and third parties.
We define a conflict of interest as being either:
- between us and you as a customer, or
- between yourself and another customer where your interests are materially affected.
We have identified areas where a conflict of interest may arise. They include, but are not limited to:
- services in different capacities at the same time;
- providing advice or management;
- acting for more than one customer in a transaction;
- holding information on other customers that would affect you or them if it was disclosed;
- receiving gifts or entertainment which could conflict with our duties to you;
- employees pursuing activities or personal relationships potentially detrimental to you; and
- personal account holdings in companies or other investments being recommended by us.
Protocols have been developed and introduced to manage conflicts of interest. Our employees are provided with relevant training about the protocols and standards of conduct expected thereafter. Our management remain responsible for ensuring the protocols and resources are sufficient to identify and attend to a conflict as it may arise.
We maintain an internal log of conflicts that arise, listing how each conflict was monitored and any solution which was developed and applied to resolve the problem and to prevent the customer’s interests from being disadvantaged.
We have in place protocols to prevent unauthorised access or inappropriate dissemination of information.
Where our functions could create an internal conflict our duty lines are kept separate and individual management and reporting structures are established. The operations functions are maintained and conducted separately from the front office functions and in both an appropriate level of qualification, expertise and supervision is applied.
Staff remuneration is by means of a basic salary which is not linked to the underlying performance of the company. A remuneration committee agrees and monitors awards to achieve consistency and equitability and does not lead to conditions which may foster conflict.
We do not give or receive inducements. i.e. fees or commission from third parties, except acceptable minor non-monetary benefits.
Minor non-monetary benefits will be acceptable with respect to the service that we provide to you if:
- they are intended to enhance the service that we provide to you; and
- are of a scale and nature that they objectively do not impair our duty to act honestly, fairly and professionally in your best interests.
Examples of acceptable minor non-monetary benefits include, but are not limited to: Participation in seminars and other training events on the benefits and features of a specific financial instrument or an investment service: and hospitality of a reasonable minimal value, such as food and drink, during a business meeting, conference, seminar or training event etc.
Any research that we receive from third parties will be paid for directly from our own resources.
Personal account dealing rules are enforced for each member of staff.
Where we are unable to resolve a conflict of interest we will notify you formally by email and/or in the app. This disclosure will permit you to evaluate whether it is appropriate to continue using our services in respect of the pertinent conflict.
Where we have examined the conflict of interest and its cause we may inform you of our decision not to act on your behalf if we determine no other course of action is possible.
References to “us” and “we” means dozens, the trading name for Project Imagine Ltd.
The term “customer” and “you” and “your” means any person operating an account with us.
business days means a day (other than a Saturday, Sunday or public holiday) when banks in London are open for business.
GDPR mean General Data Protection Regulation as may be amended, supplemented or replaced from time to time.
FCA means the Financial Conduct Authority.
FCA Rules means the conduct rules contained within the FCA Handbook as amended from time to time.
FSMA means the Financial services and Markets Act 2000 as may be amended, supplemented or replaced from time to time.
TPS means Third Platform Services Ltd, your custodian.