Legal & Compliance

Regulatory Status and Definitionsread more +

Bartholomew Hawkins Asset Management Limited (BHAM) is authorised and regulated by the Financial Conduct Authority (626359).  Registered office: 5 Oaktree Court, Cardiff Gate Business Park, Cardiff CF23 8RS.  Registered in England and Wales (8215198);

Credo Capital Plc (Credo) is authorised and regulated by the Financial Conduct Authority (192204) and is a member of the London Stock Exchange. Credo is registered in England and Wales (3681529) and has its registered office at 8-12 York Gate, London. NW1 4QG;

Pershing Securities Limited (PSL) is authorised and regulated by the FCA and is a member of the London Stock Exchange and Euronext-LIFFE. Pershing Securities Limited is registered in England and Wales (2474912) and has its registered office at Capstan House, One Clove Crescent, East India Dock, London E14 2BH.

BHAM have entered into a pre-existing agreement with Credo for the provision of an investment management platform and dealing services on an execution-only basis through instruction from BHAM.  Credo Capital plc shall be entitled to rely on any such instructions or information without further enquiry.

Credo have appointed PSL as custodian who are authorised to hold cash and investments on your behalf and transfer investments or cash from your account to meet your settlement or other obligations. PSL reserves the right to refuse to hold any securities on your behalf in its safe custody and nominee service. 

BHAM retain responsibility for compliance and regulatory requirements regarding its own operations. Credo and PSL neither provides investment advice nor gives advice or offers any opinion regarding the suitability or appropriateness of any transaction or order and relies on information provided by BHAM in respect of all such matters. 

BHAM retain responsibility for compliance and regulatory requirements regarding its own operations. Credo and PSL neither provides investment advice nor gives advice or offers any opinion regarding the suitability or appropriateness of any transaction or order and relies on information provided by BHAM in respect of all such matters. 

Website Terms of Useread more +

The information on this site is not intended for distribution to, directed at nor for use by residents outside the United Kingdom, if such distribution, direction or use would be contrary to local law or regulatory requirements BHAM would accordingly not be able to provide any services described in this site to any person in such circumstances. Investors are responsible for satisfying themselves that they may lawfully access this site, under the laws of their home jurisdiction.

The content on this site is provided for information purposes only and should not be construed as an offer or as solicitation to conduct investment business, as defined by the Financial Services and Markets Act 2000, in any jurisdiction other than the United Kingdom. Investors who are resident in or citizens of countries other than the United Kingdom may be subject to local restrictions. In particular, no offer or invitation is made to any US persons (being residents of the United States of America or partnerships or corporations organised under the laws of the United States of America or any state, territory or possession thereof), who are excluded from the products or services offered in this site. 

Please note that the value of investments and the income derived from them may fall and you may get back less than you invested. Past performance is not a guide to future performance. The performance quoted may be before charges which will have the effect of reducing illustrated performance. No investment is suitable in all cases and if you have any doubts as to an investment's suitability then you should contact us. Any tax allowances or thresholds mentioned are based on personal circumstances and current legislation which is subject to change.

The information on this website has been obtained from sources which we believe to be reliable and accurate, but without further investigation this cannot be warranted. We are not responsible for the content of external websites that are linked from our web pages. Any opinions and comment expressed in this website are not necessarily the views held throughout BHAM.

We reserve the right to amend, alter, or withdraw any of the information contained in this website at any time and without notice. No liability is accepted for such changes, or for the pages of this website not being available at all times.

This site may include forward looking statements that are based upon current opinions, expectations and projections. We undertake no obligation to update or revise any forward looking statements. Actual results could differ materially from those anticipated in the forward looking statements.

The internet is not a completely reliable transmission medium and there may be arbitrary delays and omissions in the provision of service. BHAM will not be liable for any loss (insofar as is permitted by the rules of the FCA, where applicable) resulting from a cause over which it does not have direct control. BHAM will not be responsible for any damage to investors' computers, hardware, software, or other property resulting from investors' use of this site. Whilst endeavouring to ensure availability of this site 24 hours a day, BHAM will not be liable for any loss or damage suffered by any person as a result of this site not being available. Access to this site may be suspended temporarily or permanently and without notice.

We accept no responsibility for information or software provided by other sites which may be accessed by hypertext link from these pages and we are not responsible for the maintenance or availability of such pages or the information or software which they contain.

Privacy Policyread more +

Bartholomew Hawkins Ltd is the Operator and Copyright Holder respectively of this website ("the Site"). Bartholomew Hawkins Ltd respects your privacy and will not sell or make available in any way the personal information we collect from you ("Data") except where we have previously obtained your consent. The nature of the Services provided via the Site means that we might obtain certain information about you. This statement sets out the principles governing our use of your Data ("Use"). By Registering to use the Services and by using the Site generally, you agree to this Use. Defined terms have the same meanings as in the terms and conditions set out above.
When you Register and use the Site, we will ask you to provide certain Data, such as your contact details and demographic information. We will store this Data and use it to contact you, provide you with details of Services and otherwise for the normal use and improvement of the Site, unless you have asked us not to do so by clicking on the appropriate tickbox at Registration or by modifying your profile anytime thereafter.
We may also use the Data you provide us in response to surveys or provided during Registration to aggregate user profiles and to make you aware of relevant events and content by post, phone, email/SMS. For the avoidance of doubt, we do not pass Data to any third parties except in the following circumstances:
where stated in;
where we have previously obtained your permission; 
to enable you to receive information you have requested to be sent to you by post (we will disclose your address).

To enable us to monitor and improve the Site, we may gather certain information about you when you use the Site. This includes details of your operating system, browser version, domain name and IP address, and the details of the website you referred from.
We may use cookies only to store information such as your User ID and your session identifiers to enable us to identify whether you are Registered on to the Site and, if so, to shortcut your access to the Sites. We will only read cookies from your cookie file placed there through your web browser's interaction with the Site. Please refer to documentation provided by your browser for more information on how disabling your cookies and withholding information outlined in paragraph 3 will affect your operability with our Site. We cannot guarantee full operability of our Site if you disable your cookies.
We maintain a record of all the articles that have been sent via the Email a Friend facility on the Site. We will keep a record of the email addresses that articles are sent to and from. We keep a record of the content and comments sent by Registered Users and Visitors using the Email a Friend facility for research purposes and from time to time we may publish on our Site some of the comments made by Registered Users and Visitors in their emails. These comments will be ANONYMISED and will not be associated to any individual sender or recipient. You accept that by using the Email a Friend facility that your comments may be published, anonymously, on our Site.
We are not responsible for the data policies, procedures or content of any other website that are linked to our Site.
We endeavour to take all reasonable steps to protect your Data, including the use of encryption technology, but cannot guarantee the security of any Data you disclose online. You accept the inherent security implications of dealing on-line over the Internet and will not hold us responsible for any breach of security unless we have been negligent or in wilful default.
We may supplement the information that you provide us with information we receive from third parties. You have the right to receive information about the personal information we hold on you. You can obtain a copy of the information we hold about you by sending an email to or contacting us on 029 2050 8000. If you are concerned that any of the information we hold on you is incorrect, please contact us at 029 2050 8000.
We have certain responsibilities under legislation to verify the identity of Registered Users and users and may need to make certain enquiries and obtain certain information from you for that purpose. By using the Site you confirm that all information you supply will be accurate and that we may pass on such information, as we consider necessary, to comply with any reporting requirements.
To ensure that our records are up-to-date, we may contact you from time to time to check that the information you have provided is still accurate. If, at any stage, any of your details change and you would like us to reflect that change, please email the details of any changes
If you have any questions about our privacy policy, please contact us on 029 2050 8002.

Accessibilityread more +

BHAM is committed to providing a website that is accessible to the widest possible audience, regardless of technology or ability. We are actively working to increase the accessibility and usability of our website and in doing so adhere to many of the available standards and guidelines.

Browser Compatibility

We have tried to ensure that all of the pages on this site are readable in most browsers, including mobile devices. In particular we have checked compatibility with the latest versions of the most used browsers such as:

  • Internet Explorer
  • Chrome
  • FireFox
  • Opera
  • Safari

Text Resizing

We have tried to ensure that all text throughout the site can be scaled up and down as you require it. In most of the modern browsers, the 'text size' option can be found in the 'view' menu in the top left of the browser window.

If you have a general problem with the size of text on websites (ours and others) there are two simple ways of increasing the size:

a) Change Operating System Preferences
You can change settings within Windows or Mac operating systems to increase the size of text used - this makes all text on your computer larger (not just websites).

b) Change Browser Preferences
You can change settings within your browser to increase the default size of "normal" text - this has the effect of enlarging the text on all the websites that you visit (provided those websites have been built in an accessible way).

  • Internet Explorer 6
    From the top menu bar, select View and set the Text size.
  • Internet Explorer 7
    From the menu bar underneath the search field, select Page and set the Text size.
  • Internet Explorer 8
    From the Change Zoom Level button on the bottom right of the Internet Explorer screen just set the desired percentage.
  • Internet Explorer 9
    From the Tools button on the top right of the Internet Explorer screen, select zoom and set the desired percentage.
  • Google Chrome, Safari, Mozilla Firefox and most other browsers
    Increase Text Size: Hold down the CTRL key and press +
    Decrease text size: Hold down the CTRL key and press –

If you are still having problems navigating or accessing content on this site then please  get in touch with us.

Service Proposition - Discretionary Portfoliosread more +

BHAM shall be the manager of your portfolio and we will use our best endeavours to manage your portfolio in accordance with your investment objectives. We shall have full authority, in our absolute discretion, over your portfolio, subject to your investment objectives and any restrictions you notify us of in writing. This means that unless you instruct us otherwise we shall have full discretion on the value of any one investment and the proportion of the portfolio which any one investment or a particular kind of investment may constitute. 

We conduct investment management on the basis of our best judgement at the time and cannot be held responsible if any investment fails to achieve our expectations. The value of investments may fall as well as rise and therefore you may receive back less than you invested. Past performance of investments is not a guide to future performance. 

BHAM will be investing in assets selected by us in accordance with your investment objectives within your discretionary portfolio.  You should be aware there is no guarantee that the investment objective of a portfolio will be achieved. 

Retail Distribution Reviewread more +

We provide discretionary investment management services for our clients by selecting and managing investments from the whole of the relevant market. It is not part of our service to provide clients with advice on other aspects of financial planning, such mortgages or life assurance arrangements. Therefore under the definitions of the regulator, the FCA, all recommendations and actions which we make in the provision of discretionary investment management services are neither ‘independent’ nor ‘restricted’, as defined by the Retail Distribution Review, since these labels only apply to Advisory services which BHAM do not provide.

Financial Services Compensation Schemeread more +

We are a participant in the Financial Services Compensation Scheme, which, subject to certain exceptions, provides limited compensation in respect of eligible liabilities if we are in default.  With effect from 1 January 2011 this scheme covers the first £50,000 of a valid claim in respect of designated investments and £85,000 in respect of cash deposits. Please note that these limits apply to individuals rather than to each account which an individual may hold. The right to claim under this scheme will only arise if you qualify as an eligible investor which, for the purpose of this scheme, applies only to Retail Clients as defined by the FCA. Further information can be obtained from the FCA or the Financial Services Compensation Scheme.

Conflicts of Interestread more +

BHAM does not hold principal positions or deal on its own account. However, when we provide you with investment services BHAM, Credo, or another person or company connected with us may have a material interest or arrangement in connection with the transaction or investment concerned which may lead to a conflict of interest. This may include matching your transaction with that of another client for whom we are also acting. However, to ensure that no conflict of interest arises, we require our employees to disregard any of these factors when advising you and to disclose any relevant material interest of which they are aware, unless the transaction is a reasonable one and in your best interests.

We take care through internal policies to ensure that gifts or hospitality our employees receive from clients, companies or other institutions are not extravagant and are designed to enhance the quality of the service we provide to our clients. BHAM employees will not accept any gifts and or hospitality other than those considered normal in their line of business. Excessive gifts may result in a conflict of interest, something we are committed to avoiding. 

We have relationships with many third parties such as product providers. We have processes in place to ensure that any fees or non-monetary benefits provided by third parties do not impair our duty to act in the best interests our clients.

Order Execution Policyread more +


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 allow us to do so);

Execution venues

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

Bartholomew Hawkins Asset Management Limited (BHAM) has entered into a pre-existing agreement with Credo Capital Plc (Credo) for the provision of an investment management platform and dealing services.  A copy of Credo’s ‘Best Execution Policy’ which lists all execution venues available to them is available upon request. 

We reserve the right to use another execution venue should we deem appropriate in accordance with our Best Execution Policy.  We also reserve the right to execute orders outside a regulated market should we deem appropriate. 

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

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.

Collective investment schemes    

For orders in collective investment schemes e.g. Unit Trusts, OEICs and Investment Trusts we will place the order with Credo or directly with the fund manager/operator of the collective investment scheme.  


It is our policy that commission 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.

This review should be carried out regularly (on at least an annual basis) or whenever a material change occurs that affects your ability to continue to obtain the best possible result for your clients. 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. 

Treating Customers Fairlyread more +

Bartholomew Hawkins Asset Management Limited (BHAM) adheres to FCA Principle 6, “pay due regard to the interests of its customers and treat them fairly” and the processes of putting customers' interests at the heart of the business. 

General risk assessment: The firm is committed to the rules and general principles of the FCA and has close links with its clients. We are committed to keeping complaint levels low, and have excellent recording and administrative systems and regularly review staff competence. We monitor levels of client care on a regular basis, particularly where there is any evidence of client misunderstanding regarding the firm’s services and systems. Good communication with our customers provides a better understanding of their requirements and ultimately builds trust between customer and firm. The firm’s remuneration structure is regularly reviewed to ensure that it does not cause any conflicts of interest.

All of the above embodies TCF and why we assess our TCF risk as low. On an ongoing basis, we have the advantage of using external consultants, threesixty, who will assess our strengths and weaknesses in terms of TCF.

Financial promotions, correspondence and report letters: It is the policy of the firm to attempt to make all correspondence and promotions with clients as clear, concise, simple, fair and not misleading. 

We will at all times ensure that advice is appropriate and that due account has been taken of the client’s specific profile, needs, knowledge and attitude to risk. When assessing our client’s attitude to risk we will do our best to ensure they understand what this means and undertake a risk profiling exercise for each of our clients. We will always obtain sufficient client information to understand their circumstances, needs and requirements.

We will always ensure that we disclose information in a way that is understandable to our clients whilst complying with FCA rules and requirements. This particularly applies to the potential risks clients take when investing.

We will always ensure fair treatment.  We will always be open with our clients and will, if relevant, communicate with them on any matters that might affect them.

Flow of information between the firm and its customers: It is important that customers understand the nature of the services being offered by the firm and how they pay for them.

The firm is a fee only practice and we will always agree any fee charged before commencement of the work.  If additional charges are to be incurred, then we will agree and explain these to the customer before carrying out the actual work. We will maintain adequate records to account for client monies and invoices raised.

Accurate and timely record keeping: it is important that we keep accurate and adequate records of customer needs and instructions. It is also important that the administration of a client’s transaction is carried out efficiently. Accurate records are kept to record all advice and information given and received.

If a customer requires information, we will be open and responsive to their request, replying in a timely manner. We will be mindful of the need to review customer information to ensure its accuracy and to comply with the Data Protection Act. This will enable us to respond fairly to our customers in the unfortunate event of a customer dispute.

At all times we will ensure that client data remains confidential.

Disputes and complaint handling: We already have in place a written complaints procedure that every member of staff has read and understood. It is important that disputes are handled sympathetically and that the firm is open and honest about its mistakes. We recognise that a well-handled complaint can prevent a potentially difficult situation escalating and can ultimately retain customer loyalty.

We will be open in our complaint handling procedures and inform customers of areas outside of their complaint, if applicable, where we may have discovered errors of which they may not be aware. A complaint does not automatically lead to compensation, putting the matter right and offering an apology may often be more than enough. Customers readily accept that errors occur and in many cases are gratified that a firm will accept that they are fallible and keen to rectify the situation.

Staff training: We acknowledge that the dealings of all staff affect whether customers are treated fairly. Having members of staff who are adequately trained and mature enough to acknowledge whether a task is outside their expertise is important in this regard. Continuous professional development is important for all members of staff to maintain skills and competence. We also encourage our staff to obtain professional examinations. 

Keeping up to date: The Apportionment & Oversight Function will continue to monitor further FCA guidance, to ensure that TCF is consistently built into the overall culture of the business, at all times.