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Suspicious Transaction or Order Report (STOR) Form

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11.2.2 Insider List Template

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12 Threshold Conditions (COND)

12.1 Introduction

The Threshold Conditions are the minimum conditions for which the FCA is responsible and which a firm is required to satisfy under the regulatory system.

As a firm regulated by the FCA, the company confirms that it complies with all Threshold Conditions,  detailed below and that is it aware that failure to comply with one or more of the Threshold Conditions may result in further action being taken by the regulator.

12.1.1 Location of Offices

The company confirms that it has its main office and any registered office located in the United Kingdom and that our business is carried out within the United Kingdom.

For the purposes of this manual, the company defines our main Head Office as the place where our Senior Management and Control functions take place and where the material day-to-day decision are made.

12.1.2 Effective Supervision

The company confirms that it has the appropriate operational procedures, business functions and organised structured to enable the effective supervision of the firm by the FCA.

This includes being effectively supervised in relation to: –

a) the nature (including the complexity) of the regulated activities that we carry on or seek to carry on

b) the complexity of any products that we provide or will provide in carrying on those activities

c) the way in which our firm is organised

We aim to operate in a clear and transparent manner at all times and have clear and defined procedures and controls in place to ensure that we comply with any and all rules under the regulatory system and that those procedures and controls can be audited by the regulator at any given time.

12.1.3 Appropriate Resources

The company confirms that our resources are appropriate for the products and/or services that we offer and that such resources are monitored and reviewed on a frequent basis to ensure that they remain appropriate and proportionate to the needs of the firm.

We confirm that we have adequate financial resources to carry on our business activities and functions and we are capable of meeting any creditor agreements as and when they fall due. Our financial stability is also capable of providing the skills, support and training to our staff to ensure that we can manage our affairs and provide a high-quality service and/or product to our clients and customers as well as being compliant with all regulatory requirements.