Complaints procedure
Guide to Making a Complaint
At ebi Portfolios Ltd we aim to provide great products and excellent service to our customers. However, we know that sometimes things can go wrong and that you may have cause to complain. If you have a complaint, then please let us know as soon as possible.
We will do our very best to resolve your complaint as soon as you get in touch with us:
By telephone: +44 (0)1922472226 (Monday to Friday 9.00am to 5.00pm excluding Bank Holidays)
By email: harry.hitchcock@ebip.co.uk
By post: Chief Operating Officer, ebi Portfolios Ltd, Suite 7 Beecham Business Park, Northgate, Aldridge Walsall, West Midlands WS9 8TZ, UK
Information we need from you:
To assist us in understanding the nature of your complaint it would be helpful if you can provide us with the following information:
Name & account details
Details regarding your concern or complaint
What you would like us to do to put it right
Any relevant documents to support your complaint
Investigating your complaint
We aim to resolve your complaint within 3 working days following the receipt of your complaint.
Once an agreed resolution has been reached, we will confirm details in writing to you in a final resolution letter.
However, there may be occasions when it will take longer to respond to your complaint. If this happens, we will send you an acknowledgement within 5 business days. This acknowledgement will include the name and contact details of the person handling your complaint, this may not be the same person who received your complaint.
In the unlikely event that we have not resolved your complaint within four weeks we will write to you to advise the reason why and when we expect to resolve it. We aim to send you a final response within eight weeks of your original complaint.
The Financial Ombudsman Service (FOS)
The FOS is an independent complaint resolution service that was set up to resolve complaints between financial businesses and their customers.
If you are dissatisfied with our response to your complaint, you have the right to contact the FOS, free of charge, but you must do so within six months of the date of our final response letter.
If you do not refer your complaint in time, the FOS will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances.
The FOS contact details are:
By telephone: Freephone number is 0800 023 4567 or 0300 123 9123 from a mobile
By email: complaint.info@financial-ombudsman.org.uk
By Post: The Financial Ombudsman Service, Exchange Tower, Harbour Exchange, London, E14 9SR
Visit their website: www.financial-ombudsman.org.uk
EBI Disclosure & Conflicts of Interest Statement
This statement explains how fees may be charged where ebi manage both a model portfolio service, as well as one or more funds that may be held within that model portfolio for which ebi acts as the investment manager.
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1. Dual Management Fees and Potential Conflicts of Interest
ebi’s model portfolios may include funds for which ebi acts as the investment manager. In these instances, ebi receives a fee for managing the model portfolio and may receive a separate fee for investment management services provided to the underlying fund(s).
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This arrangement gives rise to a conflict of interest, as it provides a financial incentive to select funds in which ebi acts as the investment manager over unrelated alternatives.
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This risk is mitigated through a governance framework, including oversight and regular suitability reviews. ebi are confident these funds are cost-effective and bring a range of benefits to its portfolio suites (including tracking leading MSCI indices, providing strengthened factor exposures, and benefitting from preferential withholding tax treatment for US dividends with a positive potential impact on performance). However, clients should be aware that this structure results in ebi receiving revenue from two layers of investment management (at the portfolio level, and at the underlying fund level).
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All funds contained within ebi’s model portfolios are subjected to ongoing monitoring, including regular Investment Committee and Product Governance Committee reviews, to ensure they remain in the client’s best interest.
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2. What does it mean when ebi acts as investment manager to underlying funds?
It means that for certain funds within ebi’s model portfolios (specifically the AFH – World IMI Value Advanced, AFH – World Minimum Volatility Advanced, AFH – World Momentum Advanced, and AFH – World Small Cap ESG Broad Transition funds), ebi acts as the investment manager to these funds. While these funds are built in partnership with Amundi, ebi is responsible for the investment decisions within them.
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When ebi acts as an investment manager to a fund in its model portfolios, ebi receives two fees:
• A fee for managing the overall model portfolio.
• A separate investment management fee from the underlying fund.
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3. Distinct Service Streams
The two fees, the DFM fee and Investment Management fee relate to separate and distinct service functions, performed at different levels of the investment structure:
• DFM/MPS services: portfolio construction and ongoing management of the model, asset allocation, rebalancing, research, model management, and client servicing at the model portfolio level.
• Investment Management services: sub-fund level management including execution, liquidity management, pre- and post-trade controls, regulatory oversight, and risk monitoring.
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4. Fair Value Assessment
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Under FCA Consumer Duty, ebi is required to demonstrate that the combined fees represent fair value. ebi conducts annual Consumer Duty value-for-money assessments reviewing cost appropriateness and suitability.
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5. Why were the Amundi factor funds selected for inclusion in ebi’s models?
As part of ebi’s role as a discretionary fund manager, ebi seeks to utilise the most appropriate funds for inclusion in its model portfolios, considering elements including quality of exposure, management track record, and cost. In absence of suitable alternatives in the market, ebi worked with Amundi to launch the four AFH factor funds, each of which were assessed as offering a number of advantages relative to the incumbent solutions. This includes greater tax efficiency (in relation to the withholding tax treatment of US dividends), strong factor exposures, as well as an alignment with MSCI indices – aligning methodologies across funds in the portfolio and reducing geographical and sector overlap between different index providers.
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6. Will ebi prioritise funds for which it acts as investment manager over potentially superior alternatives?
ebi does not select funds on the basis of whether it receives an investment management fee. Fund selection decisions are based on suitability, expected outcomes, risk characteristics and value considerations. As part of ongoing investment oversight process, ebi continuously reviews the wider fund universe and assesses available options against a range of factors, including suitability, performance, risk profile, and overall value.
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Any decision to include, retain or remove a fund is subject to oversight through ebi’s Investment Committee and Product Governance Committee, which assess suitability, value and client outcomes. Where a third-party fund is considered more appropriate or cost-effective than an incumbent solution within ebi’s models, ebi would take the necessary steps to ensure portfolios continue to be constructed in clients’ best interests.
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7. How do you ensure these funds stay “fit for purpose”?
Funds in which ebi acts as investment manager are subject to enhanced scrutiny at the underlying product governance level. This includes:
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• Investment Committee Oversight: Regular reviews of performance, risk, and cost.
• Product Governance: Ongoing fund monitoring, including assessing whether the funds continue to meet the needs of the target market
• Continuous Monitoring: Tracking flows, costs, and operational efficiency daily.
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8. Fee Disclosure Table
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The DFM fees are disclosed separately within client agreements, suitability documentation, and the factsheet for the model portfolio. The Investment Management fees for the funds are reflected within the fund-level OCF disclosed in the KIID, Fund Prospectus and periodic reports.
| Fee Component – Earth | Annual Percentage (%) | Annual Cost on £100,000 |
|---|---|---|
| Standard Discretionary Investment Management Fee | 0.12% | £120 |
| Underlying Fund Ongoing Charges Figure (OCF) (Weighted average, across all portfolios) |
0.18% | £180 |
| Underlying fund transaction costs (average across all portfolios) |
0.04% | £40 |
| Total Annual Cost (Potential) | 0.34% | £340 |
For investments in the ebi Earth, Earth UK, and World portfolio ranges, the weighted average underlying Fund OCF figure (illustrated through the Earth suite example in the table above) includes OCFs incurred in relation to the one of more of the four AFH Feeder Funds, each of which has an OCF of 0.30%. Please note that fund OCFs cover a range of costs, including investment management, administration, operational, and oversight fees.
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Fee data as at 30/04/26, source: ebi and Morningstar Direct
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Additional Costs:
Other fees should also be taken into account that have not been included in the table above, including platform charges and adviser fees.
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9. Options and considerations for clients
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Clients seeking alternative charging structures may wish to discuss the following options with their adviser:
(a) selecting a model portfolio that does not allocate to funds for which ebi serves as investment manager;
(b) investing into ebi’s new Global Factor 60 and Global Factor 80 funds, which only incur fund charges and no discretionary investment management fee; or
(c) discussing alternative arrangements with your client/ adviser.
Terms of Use
The following terminology applies to these Terms of Use and any or all subsequent agreements: “Client”, “You” and “Your” refers to each mutually exclusive user accessing this website and accepting these terms and conditions. “The Company”, “Ourselves”, “We” and “Us”, refers to ebi Portfolios Ltd. “Party”, “Parties”, or “Us”, refers to both the Client and ourselves, or either the Client or ourselves. Any use of the above terminology or other words in the singular, plural, capitalisation and/or he/she or they, are taken as interchangeable and therefore as referring to same.
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Disclaimer Notice
Our Company agrees to use all reasonable and practical endeavours to keep this website in a fully operational and fault free condition. However, we cannot guarantee that this will always be the case and therefore do not accept responsibility for any defects that may exist, or for any costs, loss of profits, loss of data, or any other consequential losses arising from your use of, or inability to use our website.
Our website is provided “as-is”, without any warranties or guarantees as to it or its content’s fitness for any specific purpose unless specifically stated with direct connection to that content. Our Company shall not be responsible for any unauthorised access to or alterations of your transmissions or data, any data sent or received or not sent or received or any electronic transactions entered into using this website.
If you do not agree to any of these terms of use, your only recourse is to immediately discontinue use of this website.
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You agree that you will only use this website in a manner that is consistent with these terms and in such a way as to ensure compliance with all applicable laws and regulations. In particular, you will not use this website to transmit or post any material, which is defamatory, offensive, or of an obscene or menacing character or which may, in our judgement, cause annoyance, inconvenience or anxiety to any person. To the extent to which your use, or the use by any person who may be authorised by you or for whom you are responsible (for example as the employer) causes loss or damage to any party, you agree to indemnify our Company immediately in relation to any such losses or damages attributable to a misuse of our website including any costs, loss or profits, loss of data or consequential losses arising.
You agree that the content contained within or provided by this website is for your own use and also agree that you will not modify, copy, reproduce, republish, upload, post, transmit or distribute in any way, the material and content contained within or provided by this website without first obtaining prior written permission from a duly authorised representative of our Company. You agree not to use this website or the services made available to you through this website in such a way that may cause the whole or part of this website to be interrupted, damaged, rendered less efficient or in any way impaired.
Security
Where applicable, you are responsible for maintaining the confidentiality of any usernames and the associated passwords assigned to you upon registration for any of our digital services. You are fully responsible for all activities, which occur using those credentials including the content of your transmissions through the service. If you are sharing a computer, you should always log out before leaving this website to protect access to your information from subsequent users. You must notify us immediately of any unauthorised use or any other breach of security.
Fees
You are responsible for obtaining the equipment and paying all applicable internet connection fees that are required to access this website.
Best Execution
All portfolios managed by ebi Portfolios are held on adviser investment (wrap) platforms. In all instances, ebi Portfolios places its trading instruction(s) at the model portfolio level using the platform portfolio trading capability. As a result, trade execution (Best Execution) of assets is entirely under the control of the respective platform.
Stewardship Code
ebi are not currently a signatory of the Financial Reporting Council (FRC) Stewardship Code, but are investigating becoming a signatory of the Code.
Other Terms of Use
This website and these terms may be amended from time to time without giving any prior notification. You are responsible for regularly reviewing these terms to confirm your continued agreement to them and how they apply to the use of this website. Continued use of this website following any such changes constitutes your acceptance of those changes and your agreement to be bound by them.
The disclaimers and limitations of liability notices contained within these terms of use are without prejudice to any disclaimers or limitations of liability contained in any other contract you may have with our Company and do not affect your statutory rights.
This agreement is governed by English law. You agree that the Courts of England and Wales shall have exclusive jurisdiction to hear and determine any action or proceedings arising from or in connection with the use of this website.
Our Legal Notices
Our website terms might change occasionally. Check back here regularly to stay updated, because the latest terms apply to you.
• Download our Conflicts of Interest Policy document
• Download our Remuneration Policy document
• Download our MIFIDPRU Disclosures document