Whitman Target Market and Fair Value Information for Distributors

This document is designed to provide you with the appropriate information to enable you to understand the key features of our solutions, our identified target market and expected distribution strategy. It also provides the outcome of our fair value assessment, which we will formally review at least annually, and monitor for changes throughout the year. It details:

  • Whether we are a manufacturer or distributor of financial instruments;
  • Whether we invest in complex or non-complex products;
  • The nature of our solutions and the investor types they are designed for (i.e. our target market);
  • The types of investors for whom we do not consider our solutions to be appropriate (i.e., negative target markets);
  • Instances where we might deviate from a manufacturer’s distribution strategy;
  • Price & Fair Value information;
  • Information reporting to and from Whitman.


Whitman Asset Management Limited (shown as either ‘Whitman’, ‘we’ or ‘us’ hereafter) are investment managers, providing asset management services to a wide range of investor types. This includes managing investment portfolios for private individuals via general investment accounts, individual savings accounts, pensions and investment bonds, as well as the investment management of funds and execution only solutions.

Our portfolios are constructed on a bespoke basis, each with differing commitments to equity markets and other asset classes that are designed to cater for a specific investor’s objectives and risk appetites.

Certain solutions contain solely AIM listed companies that qualify for Business Property Relief. Prospective clients will consider AIM investment as part of a broader Inheritance Tax mitigation strategy. Professional financial advice should be sought by prospective clients before investing in these solutions for inheritance tax mitigation purposes.

Manufacturer or distributor

Under the FCA Consumer Duty requirements, Whitman meets the definition of a manufacturer, but it does not meet the definition of a manufacturer under PROD rules. Whitman does not manufacture any financial instruments, but under the Consumer Duty is considered a manufacturer because we provide portfolio construction solutions for clients using financial instruments manufactured by other providers.

Whilst Whitman is not formally appointed as a distributor by these providers, its actions are those of a distributor of financial instruments manufactured by others. Whitman can provide a discretionary portfolio management solution, an AIM IHT solution and an Execution Only solution to its clients. None of these solutions meet the definition of a “financial instrument” under PROD rules.

Under Consumer Duty rules, Whitman Asset Management is considered a “co-manufacturer” of the TB Whitman Small Cap Growth Fund. This solution does meet the definition of a financial instrument under PROD rules; however, Whitman is not considered a manufacturer under PROD rules and therefore is not required to meet the regulatory obligations of a Manufacturer under the PROD rules.

The composition of the solutions offered by Whitman will change over time, depending on our economic and market views, and on expectations for the different asset classes and financial instruments used where possible.

Complex or non-complex products

The solutions we construct comprise predominantly non-complex products as defined by the FCA, but we may also select complex products to form part of a portfolio for diversification purposes, including as alternative sources of return or protection.

Target market and negative target market information for Whitman solutions

Target market categoryTarget market
Client typeOur investment management services are accessible to both Retail and Professional investors (as defined by the FCA).
Distribution channels


Advice on discretionary portfolio management services may be given by professional advisers (such as independent financial advisers), and (if no current adviser) given directly by our investment managers. Funds managed by Whitman are not generally intended to be sold on an Execution Only basis.
Knowledge and experienceOur services are available to all levels of investor knowledge and experience (Low, Medium and High).
Client objectives and needs


Our services are designed for investors seeking a range of financial objectives, including capital growth, income provision, or a combination of both.

Solutions comprising solely of AIM listed companies that qualify for Business Property Relief may be suitable for clients as part of a broader Inheritance Tax mitigation strategy.

Financial situation and ability to bear lossesInvestors in our solutions should be willing and able to bear a partial loss of their investment.
Investment time horizonOur solutions are generally for investors with a time horizon of at least five years. A shorter time horizon may be agreed based on specific client requirements.

Solutions comprising solely of AIM listed companies that qualify for Business Property Relief will typically be suitable for clients with a time horizon of two years.

Negative target marketsWe would not expect our portfolios to be recommended to:

·       Clients requiring full capital protection;

·       Clients seeking full, on-demand, repayment of the amounts invested;

·       Clients who have no tolerance for any loss.


Deviation from manufacturers’ distribution strategy

As Investment Managers, we take note of the target markets stated by the product manufacturers and will only deviate from a product manufacturer’s distribution strategy after a thorough analysis of the product and the Whitman target market. However, Whitman may deviate from this guidance for portfolio structuring and diversification purposes.

Price & Fair Value Information

Overall price

The price for the solutions offered by Whitman is set out within the schedule of charges supplied with the client application form relevant to the service. We recognise that individual Financial Advisers may have a different charging structure with their retail clients in line with the specific services/benefits provided, and this may vary and need not be disclosed to Whitman. Financial Advisers are thus expected to further undertake their own assessments to ensure the overall price represents fair value to the underlying retail client.

Benefits of services to Target Market

As a manufacturer under Consumer Duty rules, we must assess the price of each solution in the context of the benefits it provides to retail clients within the target market. The benefits of each solution are detailed in the marketing literature below:

Private Client Brochure

Private Client AIM Brochure

Execution Only Brochure

TB Whitman OEIC KIID B Class (Retail)

Fair Value confirmation statement

Whitman has undertaken a fair value assessment of each solution in line with internally defined criteria and regulatory expectations. Whitman considers that the benefits of each solution provided are proportionate to the anticipated costs.

While our assessments cover a broad range of metrics, the core fair value indicators assessed include:

FeaturePricing and CostsService Assessment (Including Complaints)Distribution
Assessment will review:

·       The range of benefits the solution provides

·       The quality of the solution

·       Target Market Assessment

·       Competitor comparison


Assessment will review:

·       Pricing value for money criteria

·       The fees and charges customers pay for the solution

·       Comparable market rates and charges

·       Non-financial costs associated with operating the product

Assessment will review:

·       Quality of service delivered, and the action taken if there is any negative impact on customer experience

·       Complaints data

·       Intermediary feedback

·       Customer experience

·       Customers with characteristics of vulnerability and ensuring they do not receive poor outcomes

Assessment will review:

·       Whether the distribution strategy remains appropriate and whether there are any areas which negatively impact on customer outcomes

·       Terms of Business with advisors

Information reporting to Whitman

If you are a further distributor (e.g. professional adviser) of our solutions and you choose to distribute Whitman portfolios to a stated negative market (such as for the purpose of diversification within an investor’s wider investment strategy), we must be notified of the details of such an event. Please send this information to compliance@whitman.co.uk.

For financial intermediary use only. Not for use with retail clients.

View Whitman Target Market and Fair Value Information for Distributors.

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