Introduction to the Axis Financial Consultants Business Continuity Plan

Axis Financial Consultants has developed a Business Continuity Plan (BCP) outlining how we will respond to events that significantly disrupt our business operations. The plan aims to help minimise revenue losses during periods of disruption while maintaining order within our organisation. Since the timing and impact of disruptions are unpredictable, we will be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

The firm's core activities

Our company is a brokerage firm that advises expatriates on pension and investment planning. Our firm does not maintain custody of customers’ funds or securities; we act as intermediaries specialising in the transfer of UK pensions and advising on tax-efficient investments. These providers maintain custody of customers’ funds or securities.

The business is registered in France, at the home of the Gérant, Mr Desmond Cooney, at 374 Avenue de la Gaule, Ile de la Dérivation, 78955 Carrières Sous Poissy. The second Director, Mr Loughton, also works from home at Calle Violeta 5, Las Lagunas de Mijas, 29651 Malaga, Spain.
In recent years, we have automated many of our business processes, enabling the two Directors and the admin assistant to work from home. There has been a concerted move towards a paperless office environment. This allows us to work more efficiently and reclaim valuable hours in the day.

Most client consultations are conducted online using Microsoft Teams or Zoom. Where circumstances permit, consultations can also be conducted at the client’s place of work or their home. Clients are supported with online content and regular communications. Our clients rely on us to help them stay disciplined and secure, while always remaining committed to long-term financial prosperity.

Our Business Continuity Plan

We have a business continuity plan in place, so we are prepared if hit with unexpected disruption or disaster. We plan to quickly recover and resume business operations after a significant business disruption, responding by safeguarding our employees and property, conducting a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business as usual. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.   Our business continuity plan addresses: data backup and recovery; all mission-critical systems; financial and operational assessments; alternate communications with customers, employees, and regulators; alternate physical location of Directors; the impact on the companies we represent (Insurance Companies and Investment Providers); regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

The Insurance Companies and Investment Providers we represent maintain records of all client asset holdings and activity related to their portfolios in a geographically separate location. While every emergency poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our Providers that, in such an event, their objective is to restore their operations and be able to complete existing transactions and accept new transactions and payments within the minimum time required to restore operations. Customer orders and requests for funds and securities could be delayed during this period.

Originally created in:
January 2025
Updated:
May 2025:
Noted:
To ensure traceability of compliance with updateconstraints, keep each version.

Contacting Us

As the company consists of only two Directors and an admin/marketing assistant, the emergency responsibilities are divided between the two Directors. Should a significant business disruption occur, and you are unable to contact us as you normally do at 00 33 1 39 70 98 54 or contact@axis-finance.com, please call our alternative number 00 33 6 71 62 90 79 or visit our website at www.axis-finance.com. The second person to contact in an emergency is Phil Loughton, the compliance officer, at 00 34 6 2787 3168 or phil.loughton@axis-finance.com   

Our firm’s two emergency contact persons are:
Name and Function
Contact Details
BCP Manager
Desmond Cooney
des.cooney@axis-finance.com
Mobile: 00 33 6 71 62 90 79
Compliance Officer:
Phil Loughton
phil.loughton@axis-finance.com  
Mobile: 00 34 6 2787 3168

If you cannot access us through either of these means, please contact David Carrolan at Digitalico, our IT support company, at david@digitalico.com or mobile: 00 33 63 35 88 043.

Risk assessment of the essential activities of the firm

We have conducted a risk assessment to help determine which threats or contingencies we may need to plan for. The assessment covers the most essential functions of the business that must continue, even during periods of disruption. It informs you of the key people in the business and who is equipped to assume which roles should the need arise. The plan also outlines the following:

  • What would need to happen and in what order to bring the business back online following a disruption, and how quickly that would happen.
  • The people who need to be contacted and in what order should a disruption occur.
  • How communications are handled if phone calls and email are not an option.
Risk Considered
Yes
No
Urgent Contact
Notes
Damage to Premises
phil.loughton@axis-finance.com  
Mobile: 00 34 6 2787 3168
Both Directors and the admin assistant work from home/teleworking. There is house and contents insurance for the premises that covers fires, burglaries, water damage, alternative accommodation and other situations.
Theft/Destruction of Files or Databases
Yes
All files are stored on Microsoft 365 for business. The cloud CRM software provided by Zoho (https://crm.zoho.com/)  is used as an alternate or backup location. Both Directors can access the client files at any time from a remote location.
Theft/Destruction of Computer Equipment
Yes
Both Directors work remotely and have backup equipment, i.e. access to more than one computer.
Manager's illness/unavailability of human resources
Yes
Phil Loughton
phil.loughton@axis-finance.com
Mobile: 00 34 6 2787 3168
In the event of Desmond Cooney’s illness or unavailability, Mr Phil Loughton will communicate with customers and the admin staff member. Communications will be conducted via our website, phone or email. Should temporary or support staff need to be hired, we will contact the Federation of European Independent Financial Advisers (FEIFA) at https://feifa.eu/ for replacements.
Premises inaccessibility
No
All business is conducted remotely by the two Directors. Our firm maintains its primary or original records in electronic form. Both Directors are responsible for maintaining their client records.

Client meetings are impossible.
No
A policy and culture already exist for conducting client meetings via Microsoft 365 Teams or Zoom.

Other: Client access to their investment portfolios
Yes
Direct access details are provided in the Insurance or Investment Provider’s contract agreement and correspondence.
All clients are provided with access to their portfolios with Insurance or Investment Providers. This is in the form of access to the respective online investment platform or direct telephone access.
Operational risk regarding the company website and IT support
Yes
David Carralon david@digitalico.com
Mobile: 00 33 6 3358 8043
We have ensured that our current tech recovery needs align with what is outlined in our plan. In the event of internet disruptions, the company contracts support from Digitalico SARL, which provides web design, content management and SEO services.
John McCulloch
projects@motorcom.com
Mobile: 00 33 6 2306 4506
In the event of disruptions to our Microsoft 365 for business or Zoho CRM system, the company contracts support from Motorcom.
Cybersecurity risks
John McCulloch
projects@motorcom.com
Mobile: 00 33 6 2306 4506

The risk of cybersecurity events may be increased due to the use of remote offices or telework arrangements. Motorcom assist us in remaining vigilant in our surveillance against cyber threats.

Varying Disruptions

Significant business disruptions can vary in their scope, ranging from our firm’s two separate work-from-home offices to the city where we are located or the entire region or country. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In the event of a significant business disruption, we have plans in place to move to a backup location or remote locations as necessary. In either situation, we plan to continue operating and will notify you through our website (www.axis-finance.com) or via an outgoing message on our customer emergency number (00 33 6 71 62 90 79) on how to contact us.
 
If a significant business disruption is so severe that it prevents us from operating, we will ensure that our customers continue to have access to their funds and securities. Clients can obtain information at any time from their insurance or investment provider by using the login or contact details provided in their contract or correspondence with them.

Insurance coverage and risk prevention mechanisms

The company combines insurance coverage and risk prevention as mechanisms for managing potential financial losses. Insurance is used to cover potential losses in the event of certain risks occurring, such as damage to premises, theft or destruction of IT equipment and protection against claims of professional malpractice. Risk prevention measures are in place to minimise or eliminate risks in the first place.

Special Case Solutions
Yes
No
Description of Solution
Damage to Premises
Yes
The two Directors have house contents insurance for their place of abode. There is an OPTIMO contract with AGPM for the abode in France. There is a similar contract with CAIXA bank for the apartment used by the Director in Spain.
Theft/Destruction of Files or Databases
No
All files are stored on Microsoft 365 for business with backup on Zoho CRM. Microsoft 365 solutions, features, and tools include OneDrive for Business, which helps ensure that user data and user context are portable and resilient. Meanwhile, Zoho CRM offers dual security access, including Support for Authenticator apps. Data and files can be accessed remotely from any computer. 
Theft/Destruction of IT Equipment
Yes
This is covered under the house and contents insurance for the premises.
Illness/Long-Term Absence of the Manager
No
The company is a member of the Federation of European Independent Financial Advisers (FEIFA). This association can serve as a source for hiring new or replacement staff. In the event of long-term sickness or death of one of the Directors, FEIFA will be approached for a suitable replacement.
In the event of Mr Cooney's illness or absence, Phil Loughton will handle customer requests. His contact details are: phil.loughton@axis-finance.com Mobile: 00 34 6 2787 3168

Inaccessibility of premises
N/A
Should the home office of either Mr Cooney or Mr Loughton become inaccessible, all customer files are available online, allowing the Directors to work remotely.
Inability to meet with clients
N/A
Most meetings are conducted using Microsoft Teams or Zoom.
Other: Risk of claims arising from errors, omissions, negligence, or breaches of professional duty that could result in financial loss for our clients.
Yes
The company has Professional Indemnity insurance to protect the Directors when working with clients. The insurance could help to cover the cost of legal defence, and any potential compensation if inadequate or inaccurate advice is deemed to have been given.

Cybersecurity risks
No
Our tech support consultant from Motorcom has helped us take steps to reduce the risk of cyber events. These steps may include: (1) ensuring that remote access systems are properly patched with available security updates; (2) checking that system entitlements are current; (3) employing the use of multi-factor authentication for associated persons who access systems remotely; and (4) reminding associated persons of cyber risks through education and other exercises that promote heightened vigilance.

BCP testing

The BCP has been put to the test during recent power outages in France and Spain. This allowed us to assess its practical application, identify strengths and weaknesses and make further refinements to the plan. The processes in place for remote working were stress-tested during the pandemic, proving that they have the resilience to continue. 

Disclosure of BCP to Customers

Our written Business Continuity Plan (BCP) disclosure statement is available on our website and can be mailed to customers upon request.  

Updates and Annual Review of the BCP

The BCP is treated as a live document that evolves in line with changing business needs, customer demands and market conditions. Our firm will update this plan whenever there is a material change to our operations, ensuring it remains fit for purpose should it ever be needed. Additionally, our firm will review this BCP annually, on January 31, to determine whether any modifications are necessary.

Director Approval

I have approved this Business Continuity Plan as reasonably designed to enable our firm to meet its obligations to customers in the event of a significant business disruption.

Signed:_____________________________________
Title: _____________________________________
Managing Director :_____________________________________
Date: _____________________________________
31 May 2025:_____________________________________