Client Money Handling Policy

As an RICS regulated firm it is mandatory that we comply with Rule 8 of the RICS Rules of
Conduct for firms, which sets out that “a firm shall preserve the security of clients’ money
entrusted to its care in the course of its practice or business”.
This policy sets out our approach to dealing with client money so that we can uphold our
firm’s values and comply with our obligations as a member of the RICS Client Money
Protection Scheme.

What is Client Money

We adhere to the definitions of “Client” and “Client Money” provided in RICS professional
standards and guidance, UK Client money handling 1st edition, October 2019:

Client: “Any person, firm, trust, body corporate or other organisation that is a client of an
RICS regulated firm”.

Client Money: “Money of any currency (whether in the form of cash, cheque, draft or
electronic transfer) that:

• An RICS regulated firm holds for or receives on behalf of another person, including
money held by a regulated firm as stakeholder and
• Is not immediately due and payable on demand to the RICS regulated firm for its own
account,

Excluding fees paid in advance for professional work agreed to be performed, and clearly
identifiable as such, unless the fees are for work undertaken as a property agent as defined by
the Rules of the RICS Client Money Protection Scheme for Property Agent.

Our approach

We recognise the responsibilities with which we are entrusted when we look after our clients’
money and we acknowledge the inherent risks. To mitigate the risk of funds being misused
or misappropriated, we have implemented a range of control measures, including this full
written procedure for handling Client Money, appropriate partnership level and supervisory
controls and a range of training to ensure the competence of accounts staff.
Should Clients’ money be misappropriated, the firm will inform our governing body, RICS
and, where appropriate, the police and our insurers.

Our Controls
General Controls
• Employees have clear segregation of duties and responsibilities and only a principal or
appropriately qualified individual oversees the client accounting function.
• Access to client accounts and information relating to client accounts is restricted to a
limited number of competent staff who are familiar with RICS requirements.
• Our firm’s Managing Partners and Account Manager closely supervise activity on all
client accounts and have implemented a range of procedures to ensure that client
money is dealt with in accordance with RICS rules.
• IT and software systems are encrypted and password protected.
• Adequate firewalls, back-ups and disaster recovery protections are in place.
• Training on applicable RICS professional statements is provided to any member of
staff with access to client money.
• All staff adhere to the firms Card Payment Procedures.

Client Bank Account Controls
We ensure that
• Clients’ money is held in one or more client bank accounts with the HSBC plc and is a
non-interest paying account, over which we have exclusive control.
• Clients’ money is held in one or more client bank accounts separate from all other
monies and that client money is available on demand.
• Client bank accounts are correctly titled to distinguish the accounts from an office or
any other account.
• Details of client bank accounts, including interest arrangements, are confirmed to the
client in writing.
• We have written confirmation from the Bank of the client account conditions.
• Copies of the bank accounts mandates are held and up to date.

Client Accounting Records and Controls
We ensure that
• Records are kept showing how client money is handled and that these records clearly
demonstrate the money is held in appropriate client accounts.
• Regular bank reconciliations are carried out for client accounts and these are reviewed
and signed off by a Partner of the firm.
• All transfers and withdrawals are authorised by a Partner in advance of payment and
records are maintained of the authorisation.
• Accounting records and systems are appropriate to the nature and volume of the client
transactions. We use a suitable software package to manage client money effectively.
• Accounting records are recorded chronologically and promptly.
• Systems are in place to record all payment and receipts for each client account and to
keep a running balance of monies held.
• All payments and receipts are recorded against the client account with an appropriate
and clear description to identify the transaction.
• Client accounting records, including copies of reconciliations, are securely kept for at
least six years plus the current accounting year.

Controls on Receipt of Client Money
We ensure that
• When client money is received it is promptly paid into the respective client account.
• All clients’ money is banked within three working days of receipt.
• All cash and cheques received by post or by hand are promptly recorded.
• Procedures exist to identify and distinguish between clients’ and office money.
• Any mixed monies are received into the relevant client account in the first instance
and any monies owing to the office account promptly transferred thereafter.
• Fees received in advance for professional work not yet invoiced are paid into a client
account pending completion of the work.
• Duplicate receipts are issued for cash received and controls over the physical security
of cash are effective.
• Unbanked client money receipts are kept secure.

Controls on Payments from Clients Accounts
We ensure that
• Checks are made to ensure that sufficient funds are held on behalf of the relevant
client before payments are made.
• Client money is returned immediately as soon as the reason for holding the money
ceases to apply and any subsequent payments received are promptly paid to the client.
• Adequate authorisation and supervision procedures are in place for payments made by
cheque, bank transfer and electronic methods.
• Payments are only made by a Principal or the Account Manager.
• All payment requests have supporting evidence and that documentation has been
authorised by a Principal or other appropriate person.
• Blank cheques are not signed and unused cheque are kept securely.
• Effective controls are in place over the setting up o new supplier accounts our system.
• Cash payments are avoided.