1. Introduction
This document outlines the regulatory compliance framework for Wedgewood Brokers Ltd (“the Firm”), a directly authorised insurance brokerage regulated by the Financial Conduct Authority (FCA). It ensures adherence to all applicable FCA rules, principles, and guidance governing insurance intermediaries in the United Kingdom.
2. Regulatory Status
The Firm is directly authorised and regulated by the FCA.
- The Firm operates as an insurance intermediary and does not underwrite risk
3. Scope of Business
Wedgewood Brokers Ltd provides:
- Commercial insurance broking services for SME clients
- Risk advisory services
- Policy placement and renewals
- Claims support (non-loss adjusting)
- Personal lines insurance (on a secondary, non-core basis)
The Firm acts on behalf of its clients unless otherwise disclosed.
4. FCA Principles for Businesses
The Firm adheres to the FCA’s Principles for Businesses, including:
- Conducting business with integrity
- Exercising due skill, care, and diligence
- Maintaining effective management and control
- Treating customers fairly and acting in their best interests
- Communicating clearly, fairly, and not misleadingly
- Managing conflicts of interest appropriately
5. Consumer Duty
The Firm complies with Consumer Duty requirements and ensures:
- Good outcomes for retail customers (including SME customers classed as consumers where applicable)
- Products represent fair value
- Communications are clear and understandable
- Ongoing monitoring of customer outcomes
6. Governance and Oversight
The Firm operates under the Senior Managers and Certification Regime (SMCR).
- A designated Compliance Officer oversees regulatory compliance
- Regular compliance monitoring and internal audits are conducted
- Senior management maintains full accountability for regulatory obligations
7. Conduct of Business (ICOBS Compliance)
The Firm complies with the Insurance Conduct of Business Sourcebook (ICOBS), including:
- Providing Demands and Needs statements for all customers
- Ensuring product suitability for both SME and personal lines clients
- Clear disclosure of remuneration where required
- Transparency regarding insurer relationships
- Ensuring all communications are fair, clear, and not misleading
8. Client Money Handling
The Firm does not handle client money.
- The Firm operates on a risk transfer or non-client money basis as applicable
- Appropriate disclosures are made to clients regarding payment arrangements
9. Financial Crime Prevention
The Firm maintains systems and controls to mitigate financial crime risks, including:
- Anti-Money Laundering (AML) procedures proportionate to the Firm’s risk profile
- Customer Due Diligence (CDD) and Know Your Customer (KYC) processes
- Sanctions and politically exposed persons (PEP) screening where applicable
- Internal reporting procedures for suspicious activity
Staff receive regular training on financial crime awareness.
10. Data Protection and GDPR
The Firm complies with UK GDPR and Data Protection Act requirements:
- Personal data is processed lawfully, fairly, and transparently
- Data is collected only for legitimate business purposes
- Appropriate technical and organisational safeguards are in place
- Clients are informed of their rights, including access and erasure
- Data breaches are reported in accordance with regulatory requirements
11. Complaints Handling
The Firm maintains a formal complaints handling procedure:
- Complaints are acknowledged promptly
- Investigations are conducted fairly and impartially
- Final responses are issued within 8 weeks
- Customers are informed of their right to refer complaints to the Financial Ombudsman Service
Complaint records are maintained and analysed to identify trends and improve service.
12. Training and Competence
All staff are assessed as competent for their roles.
- Staff receive training on FCA requirements, including Consumer Duty and ICOBS
- Competence is regularly reviewed and documented
13. Conflicts of Interest
The Firm maintains effective arrangements to identify and manage conflicts of interest:
- A conflicts of interest register is maintained
- Staff are trained to identify potential conflicts
- Conflicts are disclosed to clients where necessary
- Controls are implemented to mitigate risks
14. Record Keeping
The Firm maintains accurate and complete records, including:
- Client communications and advice records
- Policy documentation and renewal information
- Compliance monitoring activities
- Training and competence records
Records are retained in line with FCA requirements.
15. Business Continuity and Operational Resilience
The Firm maintains a Business Continuity Plan (BCP) to ensure:
- Continuity of critical services to SME and personal lines clients
- Recovery from operational disruptions
- Protection of client data and systems
- Regular testing and review of resilience measures
16. Reporting and Regulatory Engagement
The Firm submits all required regulatory returns via FCA systems (e.g., RegData).
- The Firm maintains an open and cooperative relationship with regulators
17. Monitoring and Review
This document is reviewed:
- At least annually
- Following regulatory updates
- After any significant change in business operations
