Legal notices for our financial services

We follow strict legal regulations, to provide you with the best service and protection.

Regulatory Information

Tees and Tees Financial are trading names of Tees Financial Limited.

Tees Financial Ltd is authorised and regulated by the Financial Conduct Authority to conduct investment, pension, protection and equity release business. Tees Financial Ltd appears on the Financial Services Register under number 211314. Tees Financial Ltd is registered in England and Wales with number 4342506 and with VAT number 801 4348 64.

Tees Financial Ltd is a wholly owned subsidiary of Trust Tees Ltd which is registered in England and Wales under number 07497167. The Registered Office of both Tees Financial Ltd and Trust Tees Ltd is Tees House, 95 London Road, Bishop’s Stortford, Hertfordshire CM23 3GW.

Terms of Use

The material on this website has been prepared to provide useful information but does not constitute financial or other professional advice and should not be considered as a substitute for financial or other professional advice on any specific case. Nothing on this site constitutes an advertisement or a binding offer to perform any financial service in any jurisdiction.

Tees Financial Ltd and its directors and employees will endeavour to keep the content of this website accurate and up-to-date but do not accept any liability for any loss caused in connection with use or reliance on the contents of this website except as prohibited by law.

We are not responsible for the content of any other website, including any website through which you may have gained access to our website or to which you may gain access from our website. We do not accept any liability in connection with any such websites or links.

Copyright and Intellectual Property

The copyright and other intellectual property rights in the contents of this website, including any Tees, Tees Financial Ltd and/or Stanley Tee LLP marks, logos and brands, belong to Tees Financial Ltd and/or Stanley Tee LLP (or any licensors who have expressly licensed content to Tees Financial Ltd and/or Stanley Tee LLP). All rights, save as expressly granted, are reserved except that:

You are permitted to print or download extracts from this website for your own personal use provided the material is not incorporated in any other work or publication;

You may copy extracts from this website to provide to individual third parties for their own personal use provided you inform the individual that Tees Financial Ltd and/or Stanley Tee LLP is the source of the material and that its use is subject to the terms set out on this website.

Links to this website may not be included on any other website without our prior written permission. If you are in doubt whether an item is copyright or a trade mark of Tees, Tees Financial Ltd and/or Stanley Tee LLP please contact us for clarification.

Client Agreement

We provide our clients with our Client Agreement at the start of each new matter, but you can also view our Client Agreement by clicking here. You can view our Discretionary Management Agreement by clicking here.


We are committed to providing a high quality service to all our clients but we recognise that occasionally problems and concerns do arise.

Dealing promptly and effectively with your concerns is an important aspect of our approach to client care. If you are dissatisfied with the service we have provided to you as a client we hope you will raise your concerns with us so that we can try to resolve the issue(s). The procedure we follow to investigate and try to resolve a client’s concerns can be viewed by clicking here.

The Financial Ombudsman Service is available to sort out individual complaints that clients and financial services businesses aren't able to resolve themselves. To contact the Financial Ombudsman Service please visit

Governing Law

Our website relates only to the laws of England and Wales except as expressly stated to the contrary.

In the event of any dispute arising as a result of content posted on this website, the jurisdiction and applicable law to be invoked is that of England and Wales.

To find out more, talk to us now on 01279 658304

Legal Notices

Regulatory Information

Tees Financial Ltd is authorised and regulated by the Financial Conduct Authority to conduct investment business. Tees Financial Ltd appears on the FCA register under number 211314. Tees Financial Ltd is registered in England and Wales (4342506).

Tees Financial Ltd is a wholly owned subsidiary of Trust Tees Ltd which is registered in England and Wales (07497167). Tees is a trading name of Tees Financial Limited and any reference to Tees in this document incorporates Tees Financial Limited.

Whilst care has been taken in preparing this publication it is for information only. It is not and should not be construed as advice and accordingly no reliance should be placed on the information contained therein. Any views or opinions expressed herein are not necessarily the views or opinions of Tees or any part thereof and no assurances are made as to their accuracy. Please contact Tees to discuss matters in the context of your particular circumstances.

Issued in the UK only. This document is only for your use and must not be circulated to anyone else without our consent. 

Pillar 3 Disclosure (including Remuneration Code)


  1. Background
  2. Overview of Firm
  3. Frequency of Disclosure
  4. Management of Risk
  5. Capital Resources
  6. Remuneration

1. Background

Having adequate capital resources is a key threshold condition and firms with Investment Management permissions are subject to higher capital resource requirements and more stringent rules surrounding the monitoring of this. This is because this type of firm falls within the scope of MiFID and under the full scope of the Capital Requirements Directive (CRD) which fully came into force on 1 January 2008.

The CRD approach is based around 3 ‘Pillars’ i.e. ‘Pillar 1’ / ‘Pillar 2’ and ‘Pillar 3’. These 3 Pillars collectively form the framework for the prudential supervision of banks, credit institutions and certain investment firms – including BIPRU firms. The CRD specifies the amount and nature of capital, credit institutions and investment firms must hold.

  • Pillar 1 - Pillar 1 revises existing minimum regulatory capital standards for three major ‘risks’ that firms face i.e. credit, market and operational risk.
  • Pillar 2 -  Pillar 2 requires firms to assess the amount of internal capital they consider will cover all of the risks they are, or likely to be, exposed to.
  • Pillar 3  - Pillar 3 requires firms to publish key information about their underlying risks, models, controls and capital position, to the market forces brought to bear in these areas.

2. Overview of Firm

The firm is authorised and regulated by the Financial Conduct Authority (FCA). The firm falls into the conduct category 4 and prudential category 3. 

It is an Investment Management firm, which comes under the prudential category for Banks, Building Societies and Investments firms (BIPRU) in the FCA Handbook.

The firm is a BIPRU for investment business and does not have permission to deal for its own account. The firm has permission to arrange the safeguarding and administration of client assets and to control but not hold client money

Tees Financial Limited has two elements; Financial Planning which consists of providing advice regarding investment, protection, retirement, equity release, long term care and inheritance tax planning and Investment Management which provides portfolio management services.

3. Frequency of Disclosure

The Firm will make its annual Pillar 3 disclosures on our website ( after approval of the year end financial statements and review of its ICAAP.

Except in relation to disclosures under Remuneration, we may omit information which we consider to be regarded as proprietary or confidential.

4. Management of Risk

The senior management have designed and implemented a strategy to mitigate the risks that the firm faces through the application of appropriate systems and controls.

The firm has identified the material risks to which it could be exposed and these have been assessed and quantified in the firm’s ICAAP.

5. Capital Resources

Pillar 1 – Minimum capital resource requirement
Its minimum capital resource requirement is the higher of:

  • The base capital resource of €50k, or
  • The sum of total it’s ‘credit risk’, ‘market risk’, ‘business risk’ and ‘operational risk’ requirements, or Its fixed overhead requirement (FOR).

Credit risk

‘The risk of loss due to a debtor’s non payment of monies owed at a stipulated time’.

This risk is analysed and considered as part of ICAAP and is not considered applicable.

Market risk

‘The risk of losses in on and off balance sheet positions arising from movement in market prices (BIPRU 7)’.

The board has considered this risk as part of ICAAP. In the event of a 25% downturn in world markets, income would fall to approximately £1,385,000. The board regards this a realistic assessment in the light of the exit of the UK from the EU. The firm would be able to continue trading if this were to occur.

Business Risk

The firm’s Pillar 2 business risk assessment principally takes the form of a fall in assets under management following a market downturn that leads to lower management fees, although other risks such as loss of advisers and systems failures are also considered. To mitigate our business risk, we regularly analyse various different economic scenarios to model the impact of economic downturns on our financial position.

Operational risk

‘The risks of poor investment performance of funds under management, legal and reputational risks’.

Investment performance is covered in the section above and there is an established disaster recovery/ business continuity plan in place.

It is considered that there are adequate staff to deal with the loss of experienced personnel both with the Financial Planning and Investment Management Teams.

Fixed Overheads Requirement (FOR)

The FOR is an amount equal to one quarter of the firm’s relevant fixed expenditure.

The FOR as set out in our annual audited accounts as at 31 March 2018 is £292,232.

Pillar 2

A firm must, amongst other things, assess regularly the amount of internal capital it considers adequate to cover all of the risks to which it is exposed within the context of its overall risk management framework. The process is known as the Internal Capital Adequacy Assessment Process (ICAAP).

The firm has considered and assessed the following areas of potential risks to its business and summarises its approach to each one:

Liquidity risk 

‘The risks of a firm not maintaining sufficient liquid resources to cover any potential imbalances and fluctuations in fees receivable and expenditure which is unknown and unplanned’.

There are adequate cash balances and in the event of a sustained and prolonged downturn, actions would be taken to reduce the cost base.

Securitisation risk

‘The effect on a firm’s financial position of a securitisation arrangement failing or of the values and risks transferred not emerging as expected’.

The board has considered this as part of its ICAAP analysis and has concluded that it does not constitute a risk.

Interest rate risk

‘The effect on a firm’s financial position as a result of interest rate changes and the effect of this on the balance sheet’.

The firm has no direct borrowings and would not be vulnerable to any interest rate rise even if such is considered unlikely in the current economic environment. Inter company liabilities carry no interest obligation.

Concentration risk

‘The effect of a firm having a large exposure to sectoral, geographical, liability and asset concentrations or to a particular client’.

Portfolios are diversified as per the relevant Asset Risk Consultants guidelines and there is no single dominant client.

Insurance risk

‘The effect of having inadequate insurance cover to cover a claim or the effect on a firm’s cash flow after payment of an excess on the policy’.

The firm has insurance cover of £1.75 million per claim and the excess payment of £5,000 is well within our ability to meet it, should a claim arise.


The firm’s Pillar 1 capital is the higher of €50k or the Fixed Overhead Requirement (FOR) which is £292,232.

The Firm’s Pillar 2 capital is calculated as any additional capital that the firm considers it should hold against any risks that are not adequately covered under the Pillar 1 requirement. The firm has calculated this to be £332,232 (based on audited accounts as at 31.3.18).

The firm’s regulatory capital resource requirement is £332,232, which is the unadjusted Pillar 2 capital.

The Firm holds Tier 1 capital of £684,435. This comprises of cash and current assets, less liabilities and produces a surplus over the capital requirement of £352,203.

6. Remuneration 

Remuneration currently consists of basic salary for all employees.

In 2017/18 the business had a total income of £1,904,636 and this was broken down as follows: 

Investment Management    £524,376

Financial Planning        £1,380,260

100% of this income came from code staff.

Compiled by

Name:        Martyn Allum
Position:    Executive Director

These disclosures have been based on the firm’s position as at 31 March 2018.

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