Regulatory

Conflicts of interest.

We are required — and we intend — to act in your best interests. This policy explains the conflicts that can arise in mortgage and protection advice, and exactly how we manage them.

Purpose and scope

Equation Financial Services Ltd is authorised and regulated by the Financial Conduct Authority. This policy is maintained to meet our obligations under the FCA Handbook — in particular SYSC 10 (conflicts of interest), the Principles for Businesses, and the Consumer Duty requirement to act in good faith and avoid causing foreseeable harm. It applies to all directors, advisers, employees and contractors of the firm, and covers conflicts between the firm and a client, between an adviser and a client, and between two or more clients.

How we manage conflicts

01

Identify

Advisers and staff must consider, at the outset of every case and whenever circumstances change, whether our interests, an adviser's interests, or the interests of a connected party conflict with yours or with those of another client.
02

Record

Identified conflicts are entered in our conflicts of interest register, which records the nature of the conflict, the clients affected, the control applied and the date of review.
03

Manage

We apply controls proportionate to the risk: reassignment to another adviser, independent file review, removal of the incentive, or declining to act where the conflict cannot be managed fairly.
04

Disclose

Where the controls in place are not sufficient to prevent a risk of harm, we disclose the conflict to you in writing, in clear terms, before you decide whether to proceed.
05

Review

The register and this policy are reviewed at least annually by the Compliance Officer, and sooner if our business, panel or remuneration arrangements change.

Conflicts we have identified

The conflicts most relevant to our business and the controls we apply to each. Any new conflict is added to our register as soon as it is identified.

  1. Lender commission

    We are usually paid a procuration fee by the lender when a mortgage completes. Fee levels vary between lenders, which could in principle influence a recommendation.

    How we manage it

    Recommendations are based on documented suitability criteria — total cost over the deal period, features and eligibility — never on the fee payable. Every case records why the product was selected, and files are reviewed independently of the adviser.

  2. Insurance and protection commission

    Where you take protection or general insurance through us, the provider pays us commission, and rates differ between providers.

    How we manage it

    Provider selection follows a research process based on cover, underwriting, price and claims record. Commission is disclosed to you before you apply and confirmed in your suitability report.

  3. Client fees

    A fee of up to £300 may apply for complex advice where the mortgage is less than £200,000. We define complex advice as an instruction containing any element of adverse credit, unsecured debt consolidation, interest-only residential, lending into retirement or power of attorney.

    How we manage it

    Fee criteria are set at firm level, not by the adviser, disclosed in writing in the Initial Disclosure Document before any work begins, and are only payable as described there.

  4. Introducers and referrals

    We may receive or make referrals to estate agents, solicitors, surveyors, accountants or other professionals, and a referral fee may be payable in either direction.

    How we manage it

    Any referral fee is disclosed to you at the point of referral. You are never obliged to use a firm we introduce, and using an alternative does not affect our advice or fees.

  5. Personal relationships and connected parties

    Advisers may have personal, family or business relationships with clients, introducers or product providers.

    How we manage it

    Advisers must declare such relationships to the Compliance Officer. Where a material interest exists, the case is transferred to another adviser or subjected to pre-sale file review.

  6. Gifts and hospitality

    Lenders and providers may offer gifts, hospitality, training or promotional benefits.

    How we manage it

    All gifts and hospitality above a nominal value must be recorded in the gifts and hospitality register and approved by the Compliance Officer. Anything capable of influencing advice is declined.

  7. Remuneration and targets

    Adviser pay arrangements could, if poorly designed, encourage volume over suitability.

    How we manage it

    Remuneration is assessed against quality, compliance and client-outcome measures as well as activity. We do not operate provider-specific sales targets or product-linked incentives.

What this means for you

  • You will be told, in writing and before you apply, how we are paid for your case — fee, commission, or both.
  • You can ask at any time for the actual amount of commission payable on your mortgage or protection recommendation, and we will tell you.
  • Our recommendation is documented in a suitability report that explains why the product was chosen for your circumstances.
  • If we cannot manage a conflict fairly, we will tell you and, if necessary, decline to act rather than proceed.

See also our Consumer Duty and Fair Value pages, and the Initial Disclosure Documents for the specific terms that apply to your case.

Raising a concern

If you believe a conflict of interest has affected the advice you received, please contact our Compliance Officer, Geoffrey Arnold, at enquiries@equationfinancial.com or on 0151 707 9339. If you wish to make a formal complaint, our Complaints Officer is Ian Arnold — please use our complaints procedure, which is free to use and includes your right to refer the matter to the Financial Ombudsman Service.

At a glance

Policy owner
Geoffrey Arnold, Compliance Officer (SMF16)
Complaints Officer
Ian Arnold
Register
Maintained and reviewed at least annually
Disclosure
In writing, before you apply
Last reviewed
26 July 2026, and at least every 12 months

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