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A lang cat production for The Transparency Task Force



“We need to think critically, act ethically, and keep asking the questions that others either won’t or can’t.” Making sure the history of the Global Financial Crisis never repeats itself. P7

The importance of transparency for post-Brexit Britain Robo-advice is now officially mainstream



Examining the human cost of financial fraud


How US companies are taking advantage of inconsistent regulation


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3 Hello from the Editor 4  Real investment charge transparency will supercharge the City and give savers a fair deal 6  The Transparency Task Force Teams 7 “It must never happen again!” 10 What’s in a name? 11 Transparency Statements 12 The financial and social impact of investment losses 16 The Directory of Pro-Transparency Organisations 20 Transparency loopholes in US insurance investment products

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Hello from the Editor This month I’m going to continue with my overview of Transparency Task Force Teams and the fantastic people involved. In the September edition I covered the Banking Team, Foreign Exchange Team and the Market Integrity Team. This month we’ll take a look at: The Scams & Scandals Team This team is led by the amazing Angie Brooks, who is the Chair at Ark Class Action. Angie has been battling for years on behalf of individuals who have had their pension schemes defrauded from them. Of all our teams, it is Angela’s Scams & Scandals unit that deserves as much support as possible, to help right the grotesque wrongs that are taking place under our very noses, right now. To say the work of this team is incredibly important is an extreme understatement. The lives of real people are being ruined by the awful, scandalous and fraudulent activity of crooks that seemingly cannot be stopped by the regulators or the Police. Furthermore, it isn’t just pensions through which people are being scammed out of their money – there seems to be no limit to the scope of fraudsters’ abilities to deceive their way into other people’s pockets. The team is working hard to produce a White Paper that will outline further actions that could and should be taken by the powers that be to better protect UK consumers from financial criminals. We’ll be presenting our White Paper at a special Transparency Symposium in London on 15th November. You can read more and view the members of our Scams & Scandals Team through this link. The International Best Practice Team The issue of financial services transparency is extremely topical in

many parts of the world as consumer advocacy movements demand more from financial institutions. One particular problem is the hidden costs in investments, particularly in pensions. Our International Best Practice Team is comprised of an impressive list of individuals from over 10 countries, including academics and key individuals that help run well-respected professional bodies, trade associations and successful companies. The team is developing our Global Transparency Index, which will highlight best practice in the most transparent countries and allow different countries to benchmark themselves against others. It will be a countryby-country assessment of the transparency of different pension systems around the world. The initial focus is the UK, USA, Canada, Australia and the Netherlands. In essence, the Global Transparency Index will make it easier for people around the world to get the information they need to make wellinformed decisions. The team is led by Paul Secunda (USA) and Ian Fryer (Australia), two of the TTF’s Ambassadors. You can read more and view the members of our International Best Practice Team here. Team PISCES Team PISCES is for those that like the idea of the world’s capital markets becoming a ‘force for good’ and at worst want the financial ecosystems around the world to ‘do no harm’. Why is the team called PISCES? The letter P is for Purpose; I is for Impact Investing; S Sustainability; C Corporate Social Responsibility; E Environment,

Andy Agathangelou Founding Chair, Transparency Task Force

Social and Governance; and S is for Socially Responsible Investing. Team PISCES has grown very quickly since it was launched on 17 May and it now has several squads within it, each focused on a particular campaign initiative: The Purpose Statements Squad; The Purpose Meta-Study Squad – led by Stuart Woollard, Managing Partner of Organizational Maturity Services LLP and Co-founder and Council member at the Maturity Institute; The Mandatory Fact-Finding Squad – led by Julia Dreblow, Founder of sriServices and Fund EcoMarket; The Concept Map Squad – led by Hamish Stewart, Head of Investor Engagement at ET Index Research; plus Julia Kochetygova, Senior ESG Research Analyst for Northern Trust Asset Management; The Standardised Reporting Squad; The Measurement of Impact Squad; The Tools for Trustees Squad – led by Alan Salamon, Principal at Corpias; The Response Team Squad – led by Sandy Trust, Senior Manager, Grant Thornton UK LLP; plus JB Beckett, UK Director, APFI and an Ambassador of the Transparency Task Force. Click here for more on Team PISCES. Don’t stand by, stand up. We’re always on the lookout for collaboratively-minded people that want to work with us to help fix what’s wrong in financial services. To get involved please contact me through andy.agathangelou@ Huge thanks to our Team Leaders and our 250+ valiant volunteers for what they are doing.

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Real investment charge transparency will supercharge the City and give savers a fair deal

Based on an article first published in

the Telegraph 19 August 2017 click here


The past year has seen the beginning of many changes to our economy. We are getting ready for Liam Fox to strike new trade deals, David Davis to safeguard old alliances and Boris Johnson to introduce global Britain to the world. This is an exciting time for British business. It would be easy to think that all we need to do is sit back and wait for the opportunities to roll in, but that would be wrong. We need to ensure that we are ready not just to compete but to succeed in this new world. That means looking at the old ways we have done things and thinking again. How can we make our markets more attractive, our industries more productive and our nation ready to grasp the new opportunities promised? There are many places we could start, but I will look at the City of London. For centuries Britain led the world by allocating capital efficiently to spur the economy and exploit opportunities around the globe. Our trading empire was built on coffee houses which became insurance shops so individuals could pool risk and could try new trade routes safe in the knowledge that they weren’t in danger of destitution if a storm sunk their ship. Across the country, savers provided capital to businesses through stock markets that

allowed entrepreneurs to seize the initiative and communities to share in their success. That history means Britain is still a world leader in the efficient use of capital. But we could do better. Today, too much is lost in charges and tied up in fees. This acts as a tax on business and, more importantly, a tax on growth. It costs us all. As we leave the European Union we will have no excuse for complacency. We must reform our ways and ensure that every penny is used as efficiently as possible. That means openness. Over the coming years we need to push for greater transparency in the City. We need to align authority, responsibility and accountability.

Too much of the City doesn’t work this way. Investment funds can mask charges in complex agreements and scalp small percentages of our savings. This doesn’t sound serious but over the 40-year life of a pension a few percent a year can act as a drag on growth and take as much as a third out of overall returns. But this isn’t just bad for British people in or nearing retirement; it is bad for everyone. Our children will have to fill the void left by charges and our economy will suffer from having seen capital shaved when it should have been invested. That’s why we need transparency. Transaction costs, ongoing charges, management fees and exit costs could be better advertised. By putting the figures

out there more clearly, people would be able to evaluate the benefits of one investment option over another and choose which product best suits them. Britain isn’t alone in this: many markets suffer more from opacity than us. But this should only spur us on. By making the UK the most transparent destination for capital, we could reinforce our existing position in the global financial market. Our existing advantages – common law, the English language and our time zone – could be matched with our spirit of fair play to draw in money from around the world through our markets to place it where returns are best. While some may complain at first, the growth in business from a more open system would buoy our economy and attract investment.

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I’m not the first person to have noticed this. Back in June, the Financial Conduct Authority (FCA) criticised asset managers for their opaque charging structure and, in 2013, the Office of Fair Trading said there was “insufficient transparency and comparability of charges” in the pension market. They said providers weren’t including costs and charges within the annual management charge in a consistent way, so comparisons were not like with like. This hasn’t changed fast enough and we can’t wait any longer. That’s why I’m pushing for more action and I welcome the appointment of Dr. Chris Sier to chair the new working group that will establish disclosure standards for institutional investment fees for the FCA.

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campaigned for openness and he played an important part in conceiving what has gone on to become the Transparency Task Force. Dr. Sier is right – we need to ensure our markets are the fairest possible to attract the greatest share of global capital. Markets and competition liberate and empower. They enable each of us to match what we have with what we want and to prepare for an uncertain future. But they only work if they’re fair. What we need to see today is not just a market solution but a transparent market and that means letting in the sunlight and looking hard into the mirror. Only then can we convince others what we know well – Britain’s place is assured because we are the fairest of them all.

As a former policeman turned professor at Newcastle University Business School he has long


Tom Tugendhat was first elected Conservative MP for Tonbridge and Malling in May 2015 and in July this year he was elected Chair of the Foreign Affairs Committee. Before Parliament, Tom served as military assistant to the Chief of the Defence Staff (adviser to the professional head of Britain’s Armed Forces) and contributed to publications around the world on foreign affairs and politics. Tom served in combat in Iraq and Afghanistan and with the Foreign and Commonwealth Office. He helped establish the National Security Council of Afghanistan; the first non-warlord administration in Helmand, Afghanistan; and maritime security operations along the Atlantic coast of Africa. Tom began his career as a journalist in Lebanon before creating a public relations firm for international clients operating in Beirut, Damascus and Amman. He returned to London to work as a management consultant on financial products in EU and EUaccession nations before moving to the City as an energy analyst. He commissioned and joined the Intelligence Corps, Reserve. Tom graduated in Theology and Religious Studies from Bristol University and went on to take an MPhil in Islamics from Cambridge University. He is fluent in French and Italian. His Arabic, Dari, Spanish and Helmandi Pashto are now pretty rusty.

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The Transparency Task Force Teams The teams are the Transparency Task Force’s collective response to what we see across the global financial services industry that needs to change. We firmly believe that those who can see problems, admit to them and are motivated to tackle them should collaborate to put things right. It’s in everyone’s interest to do so. The Transparency Task Force teams are less about individual experience and more about understanding the potential power of working together to drive much needed change.




Improving transparency and professionalism.

Foreign Exchange

Challenging the opacity.

Market Integrity

Championing ethical practices.

Costs and Charges

Helping investors access better value for money.

Stewardship and Decision Making

Working to correct the ‘asymmetry of information’ problem.

Scams and Scandals

Raising awareness to help shut them down.

International Best Practise

Mutual learning to inform the Global Transparency Index.


Purpose, Impact Investing, Sustainability, CSR, ESG and SRI.


Progressive asset managers working together.

Financial Stability

Working to mitigate the risk of another Global Financial Crisis.

If you want to make your opinion count by joining our 250+ strong group of volunteer team members, contact for more information and details of the monthly conference calls.

The Transparency Task Force Ambassadors While we value every member of our campaigning community, some go over and above. They are particularly aligned to our cause and, as such, are profoundly impactful for positive change. They are our Transparency Task Force Ambassadors. Name




Jackie Beard

Director of Manager Research Services EMEA Morningstar Europe Ltd

JB Beckett

UK Lead

Association of Professional Fund Investors


Steve Conley

Chief Executive

Values Based Adviser


Ralph Frank




Ian Fryer

Head of Research

Chant West

Daniel Godfrey


The People’s Trust


Catherine Howarth Chief Executive



Con Keating

Head of Research

BrightonRock Group


David Pitt-Watson

Excecutive Fellow

London Business School


Robin Powell


The Evidence-Based Investor


Paul Secunda

Professor of Law and Director, Labor and Employment Law Program

Marquette University Law School


Anna Tilba

Lecturer in Strategy and Corporate Governance

Newcastle University Business School





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“It Must Never Happen Again!” was the eye-catching title of the London Transparency Symposium hosted by Morningstar on 13 September. The day’s sessions looked back at the last 10 years, since Northern Rock announced it had received emergency funding from the Bank of England as lender of last resort. The question posed was: What can we do to avoid a repetition of the events that led to the global financial crisis in 2008? Human behaviour is flawed, history repeats itself and events happen beyond our control. Indeed, we can look back nearly 200 years to a time when a hurricane had catastrophic effects in the United States; devastating fires broke out in Europe; there was a knife-edge election for the American presidency; and risk-taking investments were very much in vogue. It sounds rather like a recap of events happening today. The more things change, the more it seems they stay the same. Numerous key factors have been cited as contributors to the Global Financial Crisis of 2007-08, such as a failure in financial regulation and supervision; a breakdown in corporate governance; and excessive borrowing in the US for residential property and subsequent defaults on those subprime mortgages.

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There were a series of decisions made leading up to the crisis, all of which encouraged a relaxation of regulations, intentional or otherwise. • In 1980 Jimmy Carter brought in the Depository Institutions Deregulation & Monetary Control Act, which phased out restrictions on banks’ financial practices and broadened their lending powers; • In 1982 Ronald Reagan signed into law the Garn-St Germain Depository Institutions Act, which provided for adjustablerate mortgage loans, began deregulation in banking and contributed to the savings and loan crisis of the late 1980s/ early 1990s; • In 1999 Bill Clinton repealed provisions of the Glass-Steagall Act, removing the separation between investment banks and depository banks, and putting the former into competition with the latter; • In 2004 the SEC relaxed the Net Capital Rule, which allowed investment banks to take on more debt, which then spurred growth in mortgage-backed securities that were supporting subprime mortgages. From 1987, each of these moves was overseen by Alan Greenspan, a man who spent nearly 20 years as chairman of the Federal Reserve, and who was supported by four consecutive presidents. That’s a long time for anyone to hold such a position of power, and he was a man on whose every word the financial world hung. Such status brings its own challenges; no one likes to stand out in the crowd, or disagree publicly with someone of such import. One only has to look back to the late 1990s and the example

of Tony Dye, Chief Investment Officer at Phillips & Drew and someone who earned the nickname ‘Dr Doom’ for predicting the TMT crash. He stuck to his guns, his funds underperformed, and just weeks before the crash happened, he lost his job— primarily for having a contrarian view. Of course, in the last 10 years we’ve also had numerous individuals claim their part in predicting events, or saving markets, economies, countries— none of whom have suffered such a public bashing as Dye received prior to the market correction. As Morningstar analysts, we spend a lot of time interviewing fund managers. So many times in those meetings, I’ve heard them say ‘we saw it coming,’ and ‘it was obvious it was going to happen.’ Or my personal favourite—‘this was an

unprecedented event.’ In his session at the symposium, Andrew Clare spoke of the similarity in characteristics of the crisis of 2007-08, and nearly every other financial crisis that has happened, suggesting that ‘unprecedented’ isn’t nearly as unprecedented as might commonly be thought. Stock market crashes are a regular occurrence globally. Doommongers who spend their entire career saying the next crash is around the corner, will of course, at some point, be right. We all heard about Black Swans soon after the Global Financial Crisis: ‘An event that is inconsistent with past data but that happens anyway.’ But Morningstar’s own Dr Paul Kaplan observed that ‘We seem to have a once-in-a-lifetime crisis every three or four years’, so it wasn’t so much a Black Swan as a black turkey: ‘An event that’s entirely consistent with past data but that no one thought would happen.’ Then we have Gordon Brown and Alistair Darling who ‘saved the world,’ having brokered the UK’s. bank rescue package, and set the model for Europe and the US. In every market crisis, taxpayers and investors bear the greatest losses. Yes, leaders have their reputations or legacies tarnished. But they aren’t necessarily subject to the financial pain borne by everyday people who are trying to make ends meet and support their families. What have Northern Rock shareholders got back in the way of compensation? The fight is STILL going on. Martin White of the UK Shareholders Association continues to pursue this battle and many others on behalf of shareholders. That’s no small task and one that consumes hours upon hours of relentless campaigning.

While we can’t influence those events that are out of our control, we can do more to influence those that are, such as human behaviour. We can speak out when others can’t or won’t. This is at the heart of our mission at Morningstar, and underpins every piece of analysis that we write. We are compelled to say the truth, even when we know it may cause upset. Investors depend on us for our independent and unbiased stance and they know they can trust our views. Advisers rely on us in the knowledge we don’t pander to the assetmanagement community. Our forward-looking Morningstar Analyst Ratings are the most widely used qualitative ratings among financial advisers in the UK when selecting funds, according to the most recent study by Investment Trends.

Transparency is in our DNA at Morningstar. We aren’t afraid to call out bad practice, particularly when it comes to fees. Investors have the right to know what they own, and what that cost of ownership is. Costs matter. People want value for money, and we’re not afraid to take asset managers to task on this. We believe in passing on economies of scale. We’re watching with interest as to which asset managers plan to pass on equity research costs under MiFID II and which will absorb them themselves, and the reversal of some decisions in recent days. We’ll be looking at it as we review those firms within the Parent Pillar of our fund research methodology, with regards the stewardship of those firms. You’ll see those views and our Positive/ Neutral/Negative stance for all five pillars for every fund we rate. For more than 30 years Morningstar has conducted independent research and spoken out on behalf of investors. Speaking out is something that

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the Transparency Task Force isn’t afraid to do, either, and that’s why I am proud to be an Ambassador of the TTF. We’re all championing the same cause, and have the investor at the forefront of everything we do. Transparency leads to betterinformed decisions. It doesn’t necessarily help to avoid crises in their entirety and it won’t guarantee to change human behaviour. Regulation has a key role to play. But transparency can achieve much. It can help the industry to rebuild the trust following the crisis of 10 years ago. Transparency means that we’re being honest and open with investors. It empowers them to compare the choices available to them, in a way that they can understand and interpret. We all need to think critically, act ethically, and keep asking the questions that others either won’t or can’t. We all have a part to play on behalf of the investor, and collectively we can and will make a difference.


Jackie Beard is the Director of Manager Research Services for Europe, the Middle East and Africa at Morningstar. She leads Morningstar’s engagement with the due diligence teams of institutional investors who engage with Morningstar for external support in the evaluation of active and passive funds, investment strategies and asset management firms. Jackie joined Morningstar in September 2008 as Director of Fund Research for Morningstar UK, leading the roll out of Morningstar’s qualitative fund research and ratings for funds available for sale to UK investors. From mid-2010, Jackie focused on the UK investment trust market, and in 2012 led the launch of Morningstar’s qualitative research and ratings on closed-end funds for the UK. She is a leading industry voice on investment trusts and has pioneered greater transparency from closed-end funds on their holdings, authoring the paper “Investment Trusts: Why Transparency Matters”. She is a regular presenter to fund boards, investors and advisors. Jackie is a fellow of the Chartered Institute of Securities and Investment and an MSI Diploma holder; and an Ambassador of the Transparency Task Force.

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the lang cat view Each month the lang cat shares its cat’s eye view of all things transparency-related.

This month, consulting director Mike Barrett discusses the importance of meaning for investors.

What’s in a name? Every so often the Oxford English Dictionary (OED) publishes an update containing details and definitions of words and phrases that have recently become part of the public vernacular. More often than not these serve as a good reminder of technological and social developments, as previously niche activities become mainstream. The late September update1 is a case in point, containing a number of terms that you might have heard of, such as ‘fidget spinners’, ‘snollygoster2’, and ‘dabbing’. Proudly taking its place in the OED, alongside these new terms, we now find the phrase ‘robo advice’. Which makes it official – digital investing, robo advice, whatever you want to call it, is now mainstream. The OED boffins define robo advice as “An online application that provides automated financial guidance and services”. While this is as good a definition as any, the market is much broader and it’s becoming increasingly challenging for consumers to compare the features and benefits of the different services on offer, as well as clearly understanding the regulatory protection available. Many providers of these services have long bemoaned the use of the phrase ‘robo advice’, correctly pointing out that there are no actual robots involved and that actual advice (as currently defined by the FCA) is rarely on offer. The naming convention ship may have sailed but the wider point stands; the market is now collectively defined by a term that doesn’t accurately reflect what’s on offer. At the lang cat we produce an annual guide to direct investing, which you can download for free from our website. Within this research we assess 52 direct-to-consumer providers, all of whom offer

a range of services to consumers. We group these into three segments: do it for me, do it with me, and do it yourself, with the ‘it’ being the decision making process. If you want advice at the point of sale/investment and then an ongoing discretionary service, the ‘do it for you’ services are for you. ‘Do it with you’ won’t actually give you advice, but will manage your investments for you from the point of sale. And ‘do it yourself’ is the Ronseal option. The recent FCA Investment Platforms Market Study Terms of Reference document3 contains a requirement for research to help “...understand the extent to which consumers are choosing platform services and products on platforms which reflect their preferences” and will also “explore the reasons for any significant differences between what consumers value and the outcomes they want, the choices they make and outcomes they receive.” In a market of over 40 propositions, with more arriving all the time, this work is increasingly important. But alongside the need for greater understanding of the consumer decision-making process there is also a need for the industry and the regulator to provide consumers with greater clarity as to what is and isn’t on offer. Transparency is as much about clarity of services and especially with regards to who is taking responsibility for the investment decisions being made. Rightly or wrongly, the phrase ‘robo-advice’ is here to stay. The industry needs to recognise this reality and clearly communicate to its customers in a way that will allow them to make the best decisions as to how and where to invest.

1. 2. Which may or may not have already featured in a Roald Dahl book. 3.

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Transparency Statements

the link work fine just need to set it in

Transparency statements are a great way for individuals and organisations to show support for our international campaign for improved transparency in financial services. We believe that higher levels of transparency are a pre-requisite for fairer, safer, more stable and more efficient markets that deliver better value for money and better outcomes for consumers. Transparency breeds trust. By fostering greater transparency across financial services, together we can positively impact the reputation of the market as a whole. Which is good for everyone. You can add your transparency statement by completing this sentence: ‘I believe there ought to be higher levels of transparency in financial services because…’ and sending it to

Here are some examples from thought leaders showing their support. Brandon Horwitz

Guy Plater

Head of Proposition, Vitality Life

Investment Adviser, Punter Southall Investment Consulting

“I believe there ought to be higher levels of transparency in financial services because it will benefit consumers, the industry and society as a whole.”

Ramin Nakisa Owner, PensionCraft

“I believe there ought to be higher levels of transparency in financial services because it will improve decision making and lead to better outcomes.”

Frank Shore Trustee, The Pensions Trust

“I believe there ought to be higher levels of transparency in financial services because the industry has to serve its clients better.”

“I believe there ought to be higher levels of transparency in financial services because it’s difficult to work out charges as an investor.”

Peter O’Meara

Anna Tilba

Trustee Director, Compass Group plc

Director of Corporate Engagement, Newcastle University

“I believe there ought to be higher levels of transparency in financial services because confidence and trust in asset managers is eroding.”

“I believe there ought to be higher levels of transparency in financial services because it can help consumers access value for money and therefore make better investment decisions.”

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The financial and social impact of investment losses

KEN KIVENKO | PRESIDENT, KENMAR ASSOCIATES “Not only have our lives and plans been ruined and our financial situation crumbled, but possibly the worst part is – our health has suffered. You never get that back, it just means more doctor’s visits and more prescriptions.” Most headlines on investment losses focus on the scam and the perpetrator, but what about the impact on those affected? In this article we define fraud broadly so as to include outright fraud like Ponzi schemes, off-book transactions, misappropriation of assets and

unsuitable investment advice. The latter includes recommending unduly risky investments, selling expensive products, poor portfolio construction, excessive leveraging/margins, unauthorised trading, account churning and the like. Losses under the prevailing low suitability standard are not often outright fraud, but the devastating effects are the same. “My advisor was charming – she always remembered my birthday. I lost $49,000 in a very risky mining stick and now she won’t pick up the phone.”

Over the 15 years in which we’ve been assisting people with restitution we’ve seen victims lose their homes, dip into a line of credit to afford home repairs, lose access to a credit card, live through “No Christmas” periods and become addicted to drugs and alcohol. Some market frauds were truly horrific. The infamous Bre-X scandal came at a great cost to the world. As the fraud rapidly unwound from its spool, its lashing claimed people’s savings, people’s retirements, and even people’s lives: some were

so devastated that they took their own lives. “That “free lunch “seminar was the most expensive meal I ever ate. My advice to others – stay away from these sales pitches disguised as educational.” Losing money is always stressful but the human impact is far more than that. The emotional impacts are deeply held and long lasting. Anger, fear, guilt, frustration, regret, shock and numbness. Under these conditions, it can take some time even to think about filing a complaint with a dealer or taking civil action. This why investor advocates are promoting longer statute of limitation time periods. “We have no future to look forward to – the thought of what lays ahead fills us with despair and we are constantly frightened.” One’s social world is impacted, including relationships with family and friends, engagement in community activities and familial/cultural roles. Financial victims perceive a sense of judgement from society about their losses, further exacerbating emotive and social impact. Social ‘connectedness’ is reduced… not playing sport, pulling out of charities, can’t afford to host a game of bridge, and general isolation. “I went through every feeling, through rage. This has made me very untrusting of people. It’s depriving me of feeling secure.” A 2007 Canadian Securities Administrator’s Investor Study, Understanding the Social Impact of Investment Fraud1, found that victims experience negative effects on their physical and mental

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health. Fraud victims in the study reported higher stress levels, increased feelings or displays of anger, depression and feelings of extreme loss or isolation, as well as physical effects such as panic or anxiety attacks. “I’m struggling on despite overwhelming feelings of rejection and lack of support. It is as though a dark cloud has descended over my whole life… I have endured 10 months of absolute hell, overwhelmed by feelings of despair and worthlessness.” Financial loss for a senior is a life-altering event from which it is difficult or impossible to recover, either financially or emotionally. There is often increased anxiety/ insomnia and depression. Having to take a low paying job at age 75. Forced out of a comfortable retirement home. No money to buy gifts for grandchildren. Increased medical expenses due to stress. Bankruptcy. Divorce. Some elderly couples worry the burden may eventually fall on their children as their carefully laid-out retirement plans vanish. Retirees who are living longer also are wondering if they will outlive their money. The golden years are not looking so golden for many retirees impacted by significant capital loss. “All I wanted was regular monthly income, as I am retired. I’ve lost money, my funds are frozen. For me it’s a major change in lifestyle going forward.”

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It was commissioned to better understand the personal consequences of investors not being fully compensated and to help inform submissions to the Government’s review into whether a statutory compensation scheme should be introduced in Australia. The key findings of the study are that investors who suffered the most had invested all their money, had not diversified or went into debt as part of their investment strategy. The impact of the monetary loss on investors without a financial buffer was immediate; for others the first six months after they discovered their loss were critical. Most investors received no compensation, or only a few cents on the dollar. Investors had little knowledge of existing avenues of redress, such as their financial service provider’s internal dispute resolution system or the external dispute resolution scheme they belonged to. Investors were reluctant to commence legal action to recover their monetary loss, particularly where they blamed themselves. Some investors suffered ‘catastrophic loss’ as their loss was ‘so significant their life will never be the same’. Some felt prolonged anger, uncertainty, worry and depression. Further, investors who suffered monetary loss lacked confidence in the Australian financial system, financial advisers, the government and regulators including ASIC.

The social impact of investors suffering losses due to licensee misconduct in situations in which full compensation was not available was looked at by the Consumer Advisory Panel at the Australian Securities and Investments Commission (ASIC).2

1.’s-about-trust/ 2.

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costs, nearly half of fraud victims reported incurring indirect financial costs associated with the fraud, such as late fees, legal fees and bounced cheques. Almost one in three of respondents reported incurring more than $1,000 in indirect costs, and 9% declared bankruptcy as a result of the fraud. Additionally, nearly half of victims blame themselves for the fraud – an indication of the far-reaching effects of financial fraud on the lives of its victims. “I’m not a stupid person but I certainly feel like one now. My adviser hoodwinked me big time. Don’t borrow money to invest. It was a shock when I got a margin call. Any lessons to be learnt; yeah, don’t be so trusting. I mean what else can you do? There’s nothing you can do about it though, you can’t go through life not trusting people.” “My wife is heartbroken and sick with worry about the future… more so because of the inability to do the things parents and grandparents like to do, want to do and carefully planned their finances so they could do – and that is be there for their children and grandchildren.” Research by the FINRA Foundation in the US revealed that fraud victims are vulnerable to severe stress, anxiety and depression. The report, Non-Traditional Costs of Financial Fraud3 found that: nearly two thirds (65%) reported experiencing at least one type of non-financial cost to a serious degree; the most commonly cited non-financial costs of fraud are severe stress (50%), anxiety (44%), difficulty sleeping (38%) and depression (35%). The Report found that, beyond the psychological and emotional

The impact of investment fraud and mis-selling can be as serious as that of violent crimes, but most people think the criminal justice system as a whole does not treat white collar crime as seriously as other crimes. This has to change. The financial and social impact of investment losses is substantial. It is improbable that increased

financial literacy will be able to reach a level of competency that would prevent individual cases of significant loss of savings and investment capital. That is why investor advocates are proposing regulatory reforms. Regulators must strengthen efforts to educate people on how to recognise, avoid and report investment fraud and mis-selling (‘Streetproofing’). It is also imperative that the regulatory regime increase the standards of care imposed on investment firms. Adoption of a Best Interest standard coupled with enhanced adviser proficiency and Codes of Conduct and improved risk profiling should help prevent or at least contain undue investor losses. Better dealer complaint handling rules, effectively enforced, will help investors get a more just resolution of their complaints. And finally, as a protective backstop, an independent Ombudsman service can help improve dealer processes and provide fair compensation. The end result would be win-win for all stakeholders, greater market efficiency and increased trust in the financial services industry and its regulation.


Ken Kivenko is President of Kenmar Associates. Kenmar is an Ontario, Canadabased privately-funded organisation focused on retail investor education via online research papers and ALERTS hosted at Kenmar also publishes the Fund OBSERVER on a bi-weekly basis discussing investor protection issues. An affiliate, Kenmar Portfolio Analytics, assists, on a no-charge basis, abused investors and/or their counsel in filing investor complaints and restitution claims.


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DISCLOSURE; SCAMS & SCANDALS 15 November 2017 IG Group, Cannon Bridge House, 25 Dowgate Hill, London EC4R 2YA In the morning we will focus on pension scheme trustees’ duties around value for money. We’ll discuss how trustees ought to disclose cost information to scheme members, as well as what information they should provide to members in relation to the scheme’s underlying investment holdings – particularly holdings that would interest members with an eye on ESG. We’ll also be taking a look at the charge cap. This part of the day has been inspired by the raft of existing regulatory activity in this space and the potential for new consultation that the Pensions Minister has recently indicated may happen between now and the end of the year. Speakers include David Farrar, DC Pensions Policy – Investment, Decumulation and Transfers at the Department for Work and Pensions. In the afternoon we will focus on the truly terrible problem of scams and scandals impacting the pensions and investment markets, including scams relating to what is actually gambling but dressed up as investing. This is a subject that has recently attracted a great deal of attention from regulators, politicians, campaigners and the media at large; very understandably, given the harsh reality that people have been robbed of their life savings and pension funds. Speakers include a senior representative from the Financial Conduct Authority directly involved with the management of this Market Study.

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Hotel Des Indes, Lange Voorhout 54-56, The Hague We have an outstanding line up of speakers for you including Robin Finer – Head of Wholesale & Investments Competition at the FCA; Dr. Chris Sier – Independent Chair of the FCA’s Investment Disclosure Working Group; Eric Veldpaus – Founder and Managing Director of the Institutional Benchmarking Institute (IBI) and Strategy Director, Novarca Group; Frits Meerdink – Manager, Fund Management, PGGM Investments; Tomas Wijffels, Senior Policy Advisor, Pensioen Federatie; Peter Kolthof, Partner and Head of the Netherlands, Avida International and (hopefully) Paul Resnik, Director, Global Markets, FinaMetrica & PlanPlus.

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f o y r o t c e r i D The ncy e r a p s n a r T o r P O r g a n i s at i o n s

A business shouldn’t stand out because it’s ‘pro-transparency’, it should be the norm. If you lead a pro-transparency organisation, join those already advertising in our directory. The more firms are seen here, the more weight gathers behind our argument that transparency is a commercial virtue and not a threat.

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ACADEMIC INSTITUTIONS Prof. Dr. Heinz-Dietrich Steinmeyer University of Muenster, Germany School of Law, Universitätsstrasse 14-16D-48143 e: Muenster phone: 49-251-8329744 m: 49-171-8384816 I am a professor for Social Security Law, Labour Law and Civil Law at the University of Muenster Law School. My special field is pensions – occupational/ supplementary pensions as well as public pensions. I am doing consulting work nationally and internationally including international organizations (EU etc.). I am the Chairman of the European Network for Research on Supplementary Pensions.

AUTO ENROLMENT Steve Conley, Managing Director, Workplace Pensions Direct e: w: t: 0113 457 4563 m: 07850 102070 Since 2015, Workplace Pensions Direct has made auto-enrolment simpler for small businesses, enabling employers to focus on running their companies without having to worry about pension law, and the cost of poor pension decisions. Workplace Pensions Direct offers an affordable, end-to-end, auto-enrolment solution that guarantees compliance with the law. With professional expertise, a century of payroll and pensions experience, and professional indemnity insurance – Workplace Pensions Direct has removed the worry and risk of autoenrolment for thousands of small businesses and their advisers.

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Gavin Perera-Betts, Chief customer officer, NEST e: w: t: 020 3056 3719 NEST has been set up by the government especially for auto enrolment. We’re here to make sure that every employer has access to a workplace pension scheme that meets the requirements of the new pension rules. But we do more than just meet the regulatory minimum. NEST comes packed with the sort of high-quality features you need, whether you’re saving with us, using us for your workers or helping your employer clients.

COMMUNICATIONS CONSULTANTS Lesley Alexander, Managing Director, Ferrier Pearce e: w: t: 020 3772 5360 Transparency – clarity, straightforwardness, honesty. As communications consultants, we support transparency in financial products, especially long-term savings. This applies not just to charges, but to the way we describe the products and their benefits to consumers. We believe the language we use should be clear, unambiguous and direct, helping people to make the most out of their money.

DATA SERVICES Larry McLaughlin, CEO | GSAV Ltd e: w: t: +44 203 655 2182 m: +44 7771 978 118 US m: x+1 646 946 5272 GSAV Ltd is Reg Tech/Fin Tech company exclusively serving the Buy-Side and delivering pricing solutions in the Collateral Lending Market to benefit Beneficial Owners and enable Managers to meet their Fiduciary and Regulatory obligations. GSAVr is a specialist pricing, tracking and regulatory tool and provides an independent price for collateral lending transactions that defines rate and use in a manner that the Regulators feels meets the test of both price and use. GSAVr is the only solution available today that addresses the current challenges of any form of collateralized lending, full price discovery and full price transparency.

David Rich MIod, CEO | Accurate Data Services e: w: t: 01603 813366 m: 07919918623 David is Chief Executive of Accurate Data Services, a specialistdata quality and positive people tracing business that is focused on unclaimed assets in the financial service sectors. ADS traces lost members, clients and policy holders for a variety of organisations including Life and Pensions funds, Banks and Asset Managers. The goal is to help businesses reunite their customers / members with their assets and deliver positive consumer outcomes. David is an active campaigner for transparency and action around the large unclaimed assets issues present in the UK.

FIDUCIARY MANAGERS Ralph Frank, CEO DC (UK), Cardano e: w: t: +44 (0)20 3170 5910 Cardano was founded in 2000 and now has over 150 staff with backgrounds in the areas of risk management, investment management, research, actuarial and investment advisory. Cardano studies the causes and impact of risk and costs in order to significantly improve financial performance and resilience. We currently provide Investment Advisory or Fiduciary Management services to over 1.3m pension fund beneficiaries with assets totalling over £120bn.

FINANCIAL PLANNING Mike Stafford CFP, Director, Stafford Wealth Management e: w: t: 01992 501601 Stafford Wealth Management was formed in 1986 to provide bespoke lifestyle financial planning and investment services to private clients. It is one of a small number of elite firms in the UK that is accredited by the Chartered Institute for Securities and Investment. Stafford Wealth Management is authorised and regulated by the Financial Conduct Authority for investment business.

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INVESTMENT CONSULTANTS Marcus Whitehead, Head of Investment Consulting, Partner, Barnett Waddingham e: w: t: 0333 11 11 222 Barnett Waddingham has grown to become the UK’s largest independent provider of actuarial, administration and consultancy services. Our total headcount is now over 850 – with offices in seven locations around the UK. The investment consulting practice provides bespoke, independent investment advice to over 360 pension schemes with assets from the millions to billions. We continue to provide the personal, quality, tailored approach that has made us successful and has led to high levels of client retention.

INVESTMENT GOVERNANCE CONSULTANTS James N Meenan, Principal | JNM Investment Governance e: w: t: +353 (0)1 687 1027 m: +353 (0)86 257 2646 JNM Investment Governance gives trustees independent coaching and support to develop strategies and techniques to stem the overwhelming resource handicap they face in discussions with investment professionals. JNM’s objective is to facilitate a constructive two way dialogue with attendant benefits for all parties.

Henrik Pedersen, Managing Partner & Co-Founder, Clerus LLP e: w: t: +44 20 3356 2845 m: +44 7767 656234 We partner with pension schemes and other asset owners to review and improve investment decisions, governance and value-for-money, through independent and informed investment analysis. As a result, investment outcomes can be improved without the need to change service providers or taking on more investment risk. We offer a free initial assessment, so why not try us out?

INVESTMENT MANAGEMENT Robin O’Grady, Head of Business Development, Hawksmoor Investment Management e: w: t: 01392 410180 m: 07468 697900 Hawksmoor specialises in providing high quality discretionary investment management services for private clients including trusts, pension schemes and charities. We are a privately owned business with no ties to a bank or any other financial institution. Our experienced and well qualified team of investment professionals is focused solely on providing clients with the best service and consistently good performance.

NOT FOR PROFIT Dr. Kara Tan Bhala, President & founder, Seven Pillars Institute for Global Finance and Ethics e: w: t: +1(785)865-8824 (mobile) Seven Pillars Institute (SPI) for Global Finance and Ethics is an independent, nonprofit 501(c)(3), nonpartisan, organization whose mission is to highlight and analyze issues of moral philosophy in global financial markets with a view to enhancing ethical practice and policy.

PENSION ADMINISTRATION Margaret Snowdon OBE, Chairman, Pensions Administration Standards Association e: w: m: 07983 565955 The Pensions Administration Standards Association (PASA) is a not-for-profit organisation which acts as a focal point to engage with industry and government on pensions administration matters. It was created to provide an independent infrastructure to set, develop, and provide guidance on pensions administration standards. It is an independent accreditation body, assessing the achievement of good pension administration standards by schemes and providers.

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RESEARCH Jackie Beard, Director of Manager Research Services EMEA e: w: Morningstar is a leading provider of independent investment research in North America, Europe, Australia, and Asia. The company offers an extensive line of products and services for individual investors, financial advisors, asset managers, and retirement plan providers and sponsors. Morningstar provides data and research insights on a wide range of investment offerings including managed investment products, publicly listed companies, private capital markets, and real-time global market data. Morningstar also offers investment management services through its investment advisory subsidiaries, with more than USD $200 billion in assets under advisement and management as of 31 December 2016. The company has operations in 27 countries.


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Arno Kitts, Founder & Chief Investment Officer, Perspective Investments C0 M0 Y0 K0

e: w: t: +44 20 3290 6486 Perspective Investments is a multi-asset multi-strategy investment COLOURS CMYK C100 M88 Y0 K0 manager. We invest on behalf of our clients, including our founder C0 M0 Y0 K0 family. Our commitment to our clients is to help them achieve their financial objectives. We do this by aiming to deliver higher returns with lower volatility and better capital CMYKour investment performance track record preservation than conventional equity portfolios. Of course, COLOURS while C100 M96 Y8 K5 is consistent with this aim, past investment performance is not necessarily predictive of future results. C0 M0 Y0 K0


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30 November 2017 Morningstar, 1 Oliver’s Yard, 55–71 City Road, London EC1Y 1HQ This Transparency Symposium is wholly dedicated to the Financial Conduct Authority’s Investment Platforms Market Study. The event will be about hearing first-hand from the FCA about why this Market Study is being undertaken, its primary objectives and how it may improve competition in the market for the benefit of the consumer. We will also hear about what actions the FCA may take as a consequence of the Study. In addition, delegates will be able to listen to and engage with credible subject matter experts whose insights and experience will aid understanding and the development of wellconsidered views. Relevant market participants will also be given a platform (excuse the pun) to explain how they see this important regulatory development. This comment from Christopher Woolard, Executive Director of Strategy and Competition at the FCA about the Market Study provides useful background and context: “With the increasing use of platforms, and the issues raised by our previous work, we want to assess whether competition between platforms is working in the interest of consumers. Platforms have the potential to generate significant benefits for consumers and we want to ensure consumers are receiving these benefits in practice.”

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Transparency Loopholes in US Insurance Investment Products BY CHRIS TOBE | CFA

Insurance products in the United States are, for the most part, unregulated by the Federal Government and lack transparency in risk and fees. A 1992 Federal Reserve paper notes that the so-called insurance safety net is made of 50 different state regulators with a wide variety of regulations and is much weaker than most realise. This allows companies to shop for insurance regulation among the 50 states to find the softest regulations1. For example, a pension plan in California could have its insurance investment products regulated in an insurance-friendly state like Iowa or Connecticut. Insurance companies have lobbied Washington to have only cursory Federal regulation by the Department of Labor (DOL) over corporate pension plans.

1. Pg 6.

The specific product I want to highlight is the fixed annuity, sometimes known as stable value2. This is not to be confused with the stable value products put out by Fidelity, Vanguard, T.Rowe Price and others, which are transparent. These fixed annuity products are backed by the general account of a single insurance company, and thus take its single entity credit risk. Many take this risk based on flimsy state guarantees which the Federal Reserve has said have little worth3. The European Union, in 2017, has also shown concern with the weakness of state regulators of insurance companies4. By and large the Fortune 500 largest US Corporations have avoided these insurance company products in their 401(k) plans. This is not because of fear of regulators, but because of fear of lawsuits filed by employees under the Employee Retirement Income Security Act of 1974 (ERISA). Multimillion dollar verdicts in ERISA cases in the last 10 years have allowed plaintiff law firms to file these extremely complex costly cases. Thus, most of these non-transparent insurance products are in smaller company plans which are not cost effective for plaintiff bars to litigate individually. However, there have been class action suits to bring transparency to multiple smaller plans filed against individual insurance companies, and while a few have been settled, most are still in the beginning phases. In 2013 the US DOL put out new fee disclosure guidelines for 401(k) plans, which are defined

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contribution plans and the fastest growing in the US5 Stable value or guaranteed funds typically constitute 10-40% of assets in most 401(k) plans and have varied and complex structures which complicate fee disclosure. Billions of dollars in what I call spreadbased fees in insurance products remain undisclosed under the new DOL fee disclosure rules. This loophole allows insurance companies to hide as much 2% or 200 basis points (bps) in yearly spread profits. I was quoted in the Wall Street Journal’s Marketwatch, noting that “These excessive profits, even if called spread, act like fees and are used like fees”6. In addition they continue to pay commissions out of the hidden spread, which drive even more sales. The insurance lobby has been able to position these higher risk and higher fee bundled products in a way that makes them appear to have lower fees (and higher returns) compared to a diversified low risk low fee product like the Vanguard Stable Value collective trust. In this scenario a commissioned salesman with an insurance license can get a kickback in commissions for a product he can show is DOL approved with higher yields and no fees. We need to look more closely at the loophole that the insurance companies are using. “The preamble to the participant-level disclosure regulation provides that designated investment

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alternatives with fixed returns are those that provide a fixed or stated rate of return to the participant, for a stated duration, and with respect to which investment risks are borne by an entity other than the participant (e.g., insurance company). 75 FR 64910.”7 I believe insurance companies are twisting and manipulating this rule that likens their products to bank issued certificates of deposit (CDs). Insurance products being similar to Bank CDs is a ludicrous and misleading claim. If your bank goes under, your principle is guaranteed by the Federal Deposit Insurance Corporation (FDIC) – essentially the US Government. If an insurance product goes under, you are at the back of line with other creditors fighting for perhaps pennies on the dollar in a multiyear process. In 2008 the Federal Reserve Chairman, Ben Bernanke, said that “workers whose 401(k) plans had purchased $40 billion of insurance from AIG against the risk that their stable-value funds would decline in value would have seen that insurance disappear”8. Many investment professionals believe that a plan sponsor is taking a severe fiduciary risk by having a single contract with any one entity such as AIG. It can be argued that a plan is taking less risk by assuming that the single insurance company backing the stable value option is too big to fail and has an implied government guarantee. The National Association of Government Defined Contribution Administrators, Inc. (NAGDCA) created a brochure in September

2. 3. Federal Reserve Bank of Minneapolis Summer 1992 Todd, Wallace SPDA’s and GIC’s 4. 5. 6. 7.



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2010 with this characterisation of insurance company general account stable value that got beyond the high risks and right to fee disclosure: “Due to the fact that the plan sponsor does not own the underlying investments, the portfolio holdings, performance, risk, and management fees are generally not disclosed. This limits the ability of plan sponsors to compare returns with other SVFs [stable-value funds]. It also makes it nearly impossible for plan sponsors to know the fees (which can be increased without disclosure) paid by participants in these funds – a critical component of a fiduciary’s responsibility.” It is hard to comprehend why the DOL lets these products escape disclosure. Lack of transparency in U.S. Insurance Products has great costs to investors: 1. High hidden stable-value spread fees are subsidising administrative costs. Revenue from general and separate account stable value options have typically subsidised administration costs, making some participants pay higher administration costs than those in mutual funds, and making products appear competitive in requests-for-proposal that look at per head administrative costs. 2. Fees and commissions are not being fully disclosed. Insurance companies are still fighting not to disclose any spread profits. These excessive profits, even if called spread, act like fees and are used like fees. Commission kickbacks to consultants with insurance licenses are common in plans with general and separate account stable value. 3. The structure creates a higher level of fiduciary duty for vendors and risks for plans. Since general and separate account stable-value assets are on the balance sheet of the insurance company, this creates an inherent conflict between the fiduciary care of pension investors and company shareholders. If the firm needed more income they could get it by lowering rates paid to plans since they are in captive non-bid bundled arrangements.


Chris Tobe, CFA, CAIA is a top expert on DC investing and Stable Value and is the founder of Stable Value Consultants. He is the author of the “Consultants Guide to Stable Value” the only book published on Stable Value in the last 15 years. He has worked recently with a number of large DC plans and has been quoted in Wall Street Journal and Barron’s on Stable Value and published a number of whitepapers on stable value. He provided written testimony on stable value to DOL’s ERISA advisory committee and testified in person at the joint SEC-DOL hearing on Target Date Funds in summer of 2009. He has over 25 years of experience working with DC Plans working as a consultant, money manager and regulator. He was a Trustee for the Kentucky Retirement Systems and served as a Sr. Consultant for BCAP & NEPC. His stable value consulting practice over the last 3 years included 8 clients, with a total of 23 different stable value pools and over $34 billion in Stable Value assets. For nearly 7 years he served as a director for the Pension & Savings Group of AEGON Institutional Markets, where he was responsible for a number of major relationships with the over $40 billion wrapped Stable Value book. Tobe has published a number of articles on Stable Value and related topics including “The Consultants Guide to Stable Value,” in the Journal of Investment Consulting and “Stable Value – An Asset for All Seasons” (Plan Sponsor Magazine), He has spoken at a number of SVIA conferences and national conferences such as IFEBP, NAST, CIEBA and NAGDCA on stable value and other DC investment. He holds a BA in Economics from Tulane University, and an MBA in Finance from Indiana University – Bloomington.

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Huge thanks to Allan Gray for hosting this Transparency Symposium. We’re looking for speakers, panellists, delegates, media partners and sponsors. If you’re interested or would like more information, please contact If you don’t yet know about the services provided by Allan Gray you can check out their website here







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Transparency Times October 2017  

The Transparency Times is the official publication of the Transparency Task Force; the collaborative, campaigning community dedicated to dri...

Transparency Times October 2017  

The Transparency Times is the official publication of the Transparency Task Force; the collaborative, campaigning community dedicated to dri...