What Does an Investment Introducer Do — and What Doesn’t an Introducer Do?
Published By FJP Investment Editorial Team
The word introducer appears frequently in private investment, corporate finance and financial services.
But what does an investment introducer actually do?
More importantly, what does an introducer not do?
The distinction matters because an introduction can bring an investor and an investment provider into contact without meaning that the introducer has advised the investor to proceed, assessed the investment as personally suitable, taken control of the underlying business or guaranteed what happens afterwards.
Those are very different functions.
In simple terms, an investment introducer can act as a connection point between parties.
But the precise legal and regulatory position depends upon the activities actually being carried out, rather than somebody simply describing themselves as an introducer.
This guide explains the role in general terms and also sets out how FJP Investment describes its own position when introducing qualifying investors to third-party private investment opportunities.
Important: This article is provided for general educational purposes only. It does not constitute investment, legal or regulatory advice. Financial-services regulation is highly fact specific. Whether a particular activity amounts to introducing, arranging, advising, communicating a financial promotion or another regulated activity depends upon the circumstances and applicable law.
What is an investment introducer?
In ordinary business language, an investment introducer is a person or company that brings together parties who may have a reason to deal with one another.
For example, an introducer might connect:
- a company seeking capital with potential investors;
- an investor with a private investment provider;
- a client with an authorised financial adviser;
- a borrower with a finance provider;
- a business owner with a corporate-finance specialist; or
- professional counterparties who might otherwise never have met.
The fundamental function is the introduction.
What happens beyond that point depends on the parties, the particular investment and the regulatory framework applying to the activity.
“Introducer” is not itself a universal regulatory status
This is one of the most important things to understand.
A company cannot determine its regulatory position simply by putting the word introducer on its website or business card.
The Financial Conduct Authority looks at what a business actually does.
Activities involving investments can potentially include:
- making introductions;
- communicating financial promotions;
- arranging transactions;
- advising on investments;
- dealing in investments;
- managing investments;
- safeguarding assets; or
- other regulated activities.
Different rules can apply to each.
The regulatory perimeter therefore depends on substance rather than job title.
An introduction and financial advice are not the same thing
A genuine introduction can be as simple as bringing two parties into contact.
Investment advice is different.
Under the UK regulatory framework, advising on investments can involve giving advice concerning the merits of buying, selling, subscribing for or otherwise dealing in particular investments.
For appropriately authorised firms, the concept of a personal recommendation is particularly important.
A personal recommendation can arise where a recommendation concerning a particular investment is:
- presented as suitable for the individual; or
- based on consideration of that individual’s personal circumstances.
An introducer that does not provide investment advice should therefore avoid presenting an investment as personally suitable for an individual.
What does suitability mean?
A suitability assessment is concerned with the investor personally.
Depending on the relevant regulated service, that can involve understanding matters such as:
- financial circumstances;
- investment objectives;
- knowledge and experience;
- capacity for loss;
- investment horizon;
- risk tolerance; and
- other personal circumstances.
An introducer acting only within an introductory role does not automatically perform that exercise.
That means statements such as:
“You should invest in this.”
“This is suitable for you.”
“Given your circumstances, this is the investment I would choose.”
are fundamentally different from providing factual information about how an opportunity is structured.
Investor eligibility and suitability are also different
This distinction is particularly relevant in private markets.
An investor may be asked whether they meet a particular high-net-worth or sophisticated-investor classification.
That process concerns whether particular investment information may be communicated under the applicable framework.
It does not mean somebody has assessed whether an individual investment is personally suitable.
An investor can meet an eligibility category and still decide not to proceed with any opportunity presented to them.
Our guide to high-net-worth and sophisticated investor self-certification explains that distinction in greater detail.
Can an introducer provide information?
Providing factual information and providing investment advice are not necessarily the same thing.
An investor considering a private opportunity may reasonably want to understand matters such as:
- the name of the issuer;
- what the company does;
- what type of investment is involved;
- the legal documentation available;
- the proposed use of funds;
- the investment term;
- whether security is described as being provided;
- who the relevant professional parties are; and
- where further information can be obtained.
The important boundary is between explaining information and moving into advice or recommendation.
That boundary can be fact sensitive.
An introducer can facilitate communication without becoming the issuer
Private investment structures can involve several distinct businesses.
For example:
- A company wants to raise capital.
- The company creates an investment structure.
- An introducer becomes aware of the opportunity.
- The introducer decides whether it is willing to place information about that opportunity before qualifying investors.
- An interested investor receives information and asks questions.
- The investor ultimately decides independently whether to proceed.
- If the investor subscribes, the investment contract is entered into according to the relevant transaction documentation.
The introducer and issuer remain different parties.
What is the issuer?
The issuer is the legal entity issuing the relevant investment instrument.
Depending on the structure, this could be the company issuing:
- loan notes;
- bonds;
- shares;
- preference shares;
- another security; or
- another contractual investment.
The investor should establish exactly which legal entity is responsible for the obligations contained in the investment documents.
If Company A issues a loan note, the fact that an introducer first showed the opportunity to the investor does not normally make the introducer the debtor under that note.
The introducer does not run the underlying business
This distinction is equally important.
The directors and management of the investment company remain responsible for operating their business.
That can include decisions concerning:
- staff;
- customers;
- suppliers;
- property;
- construction;
- borrowing;
- business strategy;
- cash flow;
- sales;
- refinancing; and
- other commercial matters.
An introducer bringing investors into contact with that business does not ordinarily become part of its management team simply because the introduction took place.
The introducer does not control how a third-party company performs
Private investment ultimately involves the performance of another business, borrower, issuer or asset.
An introducer cannot guarantee that:
- management will execute its business plan successfully;
- revenue forecasts will be achieved;
- property will sell at an anticipated value;
- development work will finish on schedule;
- refinancing will be available;
- a borrower will never default;
- asset values will remain unchanged; or
- a company will remain solvent.
Those are risks associated with the underlying investment.
An introducer and an investment manager are different
Investment management involves making investment decisions or managing assets on behalf of somebody else.
An introducer does not automatically have authority to buy, sell or manage investments for an investor.
Where an investor makes their own decision following an introduction, the investor remains responsible for deciding whether to proceed.
That is fundamentally different from giving a discretionary manager authority to manage a portfolio.
An introducer and a financial adviser are different
A financial adviser can perform regulated advisory services within the scope of the firm’s permissions.
That can involve considering an individual’s circumstances and making a personal recommendation.
An introducer who does not provide that service should not be assumed to have:
- analysed the investor’s overall portfolio;
- recommended an allocation;
- determined an appropriate investment amount;
- assessed personal suitability;
- compared all available investments in the market; or
- advised the investor to proceed.
An investor who requires personalised investment advice should obtain it from an appropriately authorised adviser.
An introducer and a lawyer are different
Investment documentation can be complicated.
An introducer may provide documents supplied in connection with an opportunity or explain broadly what particular documents relate to.
That should not be confused with providing legal advice.
A solicitor may be required to advise upon matters including:
- contractual rights;
- security;
- enforceability;
- company law;
- property rights;
- cross-border issues;
- tax structuring;
- insolvency; and
- other legal matters.
The investor should use the appropriate professional where legal interpretation is required.
An introducer and an accountant or tax adviser are different
Likewise, an introducer may discuss an investment structure in general terms without providing personalised tax advice.
Tax can depend upon:
- residence;
- domicile or other connecting factors where relevant;
- legal ownership;
- the nature of the income;
- the type of investment;
- whether an individual or company invests;
- applicable tax treaties; and
- the investor’s wider circumstances.
An international investor may therefore need independent UK and local tax advice.
An introducer and a security trustee are different
Secured private investments may appoint a security trustee to hold and administer security for specified creditors.
The security trustee performs a legal role under the security documentation.
The introducer does not automatically hold the security simply because it introduced the investment.
Our guide What Is a Security Trustee and What Do They Actually Do? explains that role in detail.
An introducer and a custodian are different
A custodian holds or safeguards financial assets within a particular legal and regulatory structure.
An introducer does not automatically perform custody simply because it has a relationship with the investor.
Investors should establish:
- who receives their subscription money;
- whose bank account it enters;
- who issues the investment;
- who records ownership; and
- who holds any underlying assets or security.
These functions should not be assumed from the introduction process.
Does an introducer hold the investor’s money?
Not necessarily, and the handling of client money is a separate regulatory issue.
An investor should know exactly where funds are being sent.
Depending on the investment structure, money might be paid to:
- the issuer;
- a solicitor;
- an escrow provider;
- a regulated custodian;
- a subscription account;
- another transaction party; or
- another recipient expressly identified in the legal documentation.
The payment route should be checked against the transaction documents rather than assumed from the identity of the person who made the introduction.
Does an introducer perform due diligence?
An introducer may decide to investigate opportunities before deciding whether they are ones it is prepared to place before its network.
The scope of that review can vary enormously between businesses.
Possible areas might include:
- management;
- corporate structure;
- financial information;
- existing borrowing;
- business model;
- use of capital;
- assets;
- security;
- valuations;
- legal documents;
- professional parties; and
- the intended mechanism for meeting obligations to investors.
But the word due diligence can itself create misunderstanding.
Due diligence does not mean an introducer guarantees the investment
Reviewing information does not establish that a future outcome is certain.
Nor should an introducer’s review be confused automatically with:
- a statutory audit;
- a legal opinion;
- an independent property valuation;
- a forensic investigation;
- a credit rating;
- an investment recommendation;
- a suitability assessment; or
- a guarantee.
An investor should still carry out their own assessment.
Our investment due diligence guide explains why independent verification remains important.
Why might an introducer review an opportunity at all?
An introducer is not obliged to place every opportunity it encounters before its network.
A business may have its own criteria for deciding what it is prepared to be associated with.
Questions may include:
- Do we understand the business?
- Can management explain why capital is required?
- Is supporting information available?
- Can material claims be independently checked?
- Does the investment structure make sense?
- Are legal documents available?
- Are the relevant risks identifiable?
- Can we understand how obligations are intended to be met?
Deciding that an opportunity is worthy of further consideration is not the same as recommending that every qualifying investor should invest in it.
Introduction does not equal endorsement
This distinction deserves to be explicit.
An introducer may decide that an opportunity contains enough information and substance to be placed before appropriate qualifying investors for their own consideration.
That should not automatically be translated into:
“The introducer says this investment cannot fail.”
No private investment should be understood that way.
The investor should instead examine the underlying issuer, documentation and risks independently.
What is arranging an investment?
This is where the regulatory position becomes particularly important.
Under Article 25 of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, regulated arranging activities can include:
- arrangements that bring about a particular investment transaction; and
- making arrangements with a view to persons buying, selling, subscribing for or underwriting specified investments.
The FCA describes the second limb as potentially broad.
Its perimeter guidance specifically notes that arrangements intended to enable or assist investors to transact through a particular firm can potentially include arrangements made by introducers.
This means the boundary between a pure introduction and regulated arranging cannot be determined simply by terminology.
When does an introduction become arranging?
There is no single sentence that can safely answer this for every business model.
The facts matter.
The FCA’s guidance distinguishes passive activities from more active arrangements designed to facilitate transactions.
Questions can include:
- What exactly is the introducer doing?
- How involved is it in the transaction process?
- Does it merely put the parties into contact?
- Does it participate in negotiations?
- Does it help bring about the transaction?
- Are its arrangements designed with a view to investment transactions taking place?
- What investment is involved?
- What exclusions or exemptions might apply?
Businesses operating near the regulatory perimeter should obtain specialist advice concerning their own activities.
There is an exclusion for certain introductions — but it is not universal
The Regulated Activities Order contains an exclusion concerning certain introductions.
However, it should not be understood as a general rule saying:
“If you call yourself an introducer, arranging regulation never applies.”
The Article 33 exclusion described by the FCA applies in defined circumstances where introductions are made to certain persons with a view to the provision of independent investment advice or independent discretionary services.
The precise conditions matter.
That is another reason the actual business model must be analysed rather than relying on the word introducer.
What is an Introducer Appointed Representative?
There is also a specific FCA concept called an Introducer Appointed Representative, commonly abbreviated to IAR.
This should not be confused with every business that informally describes itself as an introducer.
An IAR is an appointed representative of an authorised principal whose permitted appointment is deliberately limited.
Under the current FCA Handbook, its scope is limited to:
- effecting introductions to its principal or other members of the principal’s group; and
- distributing specified non-real-time financial promotions relating to products or services available from or through that principal or group.
The FCA specifically states that the permitted scope of an IAR does not include activities such as dealing in investments as agent or arranging transactions in the broader way permitted to some other appointed representatives.
Not every introducer is an IAR
This is worth emphasising.
Introducer is a description of a business role.
Introducer Appointed Representative is a specific regulatory relationship under which an authorised firm accepts responsibility for defined activities of the IAR.
The two should not be used interchangeably.
What is a financial promotion?
Another key distinction concerns investment communications.
Under UK law, a financial promotion broadly involves an invitation or inducement to engage in investment activity communicated in the course of business.
Financial promotions can take numerous forms, including:
- websites;
- emails;
- brochures;
- presentations;
- social-media posts;
- videos;
- telephone conversations; and
- other communications.
Section 21 of the Financial Services and Markets Act restricts the communication of financial promotions by unauthorised persons unless an applicable route permits the communication.
The precise route might involve an authorised communicator, approval by an appropriately authorised person or an applicable statutory exemption.
Being an introducer does not switch off financial-promotion law
An introducer therefore needs to consider not only what activities it performs but also what it communicates.
A website that simply provides general educational information presents different issues from a communication actively inviting an individual to subscribe to a particular security.
Likewise, sending information concerning a private investment to a qualifying investor can raise different considerations from publishing the same information indiscriminately to the general public.
Investor eligibility and the nature of the investment can therefore matter significantly.
What doesn’t an investment introducer automatically do?
Putting the distinctions together, the title investment introducer does not automatically mean the business:
- provides investment advice;
- makes personal recommendations;
- assesses personal suitability;
- manages investment portfolios;
- controls the underlying company;
- operates the investment;
- acts as security trustee;
- acts as custodian;
- provides legal advice;
- provides tax advice;
- audits the company;
- values secured property;
- guarantees the issuer;
- guarantees security values;
- guarantees repayment; or
- removes the investor’s need for their own due diligence.
The roles of the parties should be identified separately.
What can an investor reasonably expect from an introducer?
This depends on the introducer’s particular service.
In general, an investor should expect clarity about:
- who the introducer is;
- what role it performs;
- what role it does not perform;
- who the underlying investment provider is;
- where investment documentation comes from;
- who the investor contracts with;
- who receives investor money;
- who manages the underlying business;
- who holds any security; and
- where the investor can obtain independent advice.
The clearer these distinctions are, the less opportunity there is for misunderstanding later.
Who is responsible for the investment documentation?
The answer depends on the structure.
Private investments may involve documents prepared by:
- the issuer;
- the issuer’s lawyers;
- corporate-finance advisers;
- security professionals;
- fund administrators;
- other transaction advisers; or
- a combination of parties.
An introducer can pass documentation between the parties without thereby becoming the legal author of every document it transmits.
Investors should check the documents themselves to establish who has issued them and upon whom contractual obligations fall.
Who answers detailed questions about the underlying company?
An introducer may be able to provide information obtained during its review or seek answers from the investment provider.
But questions concerning the underlying company’s operations are ultimately matters for the people who run that company.
Those can include questions about:
- current sales;
- staffing;
- construction progress;
- customers;
- cash flow;
- asset sales;
- financing;
- commercial contracts; and
- business strategy.
An introduction does not transfer operational responsibility from management to the introducer.
What happens after an investor proceeds?
The precise process depends on the investment.
Generally, investors should understand:
- which contract they sign;
- which entity they contract with;
- where their money is sent;
- who acknowledges the investment;
- who provides subsequent reports;
- who is responsible for contractual payments;
- who deals with maturity or redemption; and
- what contractual rights exist if something goes wrong.
The fact that the investor originally learned about the opportunity from an introducer should not obscure the actual contractual relationships.
Can an introducer continue communicating after an investment?
Potentially.
An introducer may continue to act as a communication point between investors and the investment provider.
For example, it might:
- forward company updates;
- seek answers to investor questions;
- facilitate meetings;
- pass correspondence between parties; or
- assist communication when information is required.
Doing so does not necessarily mean the introducer has assumed management responsibility for the underlying investment.
The actual legal responsibilities still depend on the relevant agreements and activities.
Facilitating communication is not the same as acting as the investor’s representative
This is another potentially important distinction.
An introducer can help communication flow between parties without necessarily becoming the investor’s legal agent, adviser or representative.
If an investor requires somebody formally to act on their behalf, the existence and scope of that authority should be established expressly rather than assumed from ordinary communication assistance.
What happens if the underlying company runs into difficulty?
The contractual position remains important.
If a private company encounters financial difficulty, questions may arise concerning:
- missed contractual payments;
- maturity;
- extensions;
- restructuring;
- security;
- creditor voting;
- enforcement;
- insolvency; and
- potential recovery.
The introducer can potentially help investors obtain information or establish contact with the relevant parties.
But it cannot simply create money that the issuer does not possess or override the contractual rights of lenders, trustees and other creditors.
An introducer cannot guarantee recovery
This principle applies even where the introducer genuinely carried out substantial work before the investment was introduced.
A business can deteriorate after an investment is made.
Property values can change.
Management can make poor decisions.
Markets can move.
Refinancing can fail.
Legal disputes can arise.
An introducer’s involvement does not remove those risks.
Why understanding roles matters when things go wrong
When an investment performs as expected, investors may give relatively little thought to the legal role of every party.
When something goes wrong, the distinctions suddenly become extremely important.
Investors may need to establish:
- Who owes me the money?
- Who issued the investment?
- What rights do my documents give me?
- Who controls the business?
- Who holds the security?
- Who can enforce it?
- Who provided professional advice?
- Did anybody give me a personal recommendation?
- What role did the introducer actually agree to perform?
Clear role definitions at the beginning of the relationship reduce confusion later.
How FJP Investment describes its role
FJP Investment has operated in the alternative investment market since 2013.
Our role is that of an introducer.
We research and consider third-party private investment opportunities and decide whether they are ones we are prepared to place before qualifying investors for their own consideration.
Areas we may seek to understand before making that decision include:
- the people behind the business;
- corporate structure;
- financial information;
- business model;
- use of funds;
- existing borrowing;
- investment documentation;
- underlying assets;
- security where applicable;
- valuations;
- professional parties;
- commercial risks; and
- the intended mechanism for meeting obligations to investors.
That review helps us decide what we are prepared to introduce.
It is not a personal recommendation to an individual investor.
What FJP Investment does not do
FJP Investment does not:
- provide personalised investment recommendations;
- assess whether a particular investment is personally suitable for an investor;
- tell investors what proportion of their wealth they should invest;
- manage investor portfolios;
- exercise discretionary control over investor assets;
- manage the underlying investment companies;
- control how those businesses use their day-to-day operational resources;
- provide personalised legal advice;
- provide personalised tax advice;
- guarantee investment performance;
- guarantee asset values;
- guarantee contractual payments; or
- guarantee repayment of capital.
FJP Investment does not manage or hold investors’ money.
If an investor independently decides to proceed with an opportunity, the relevant subscription and payment arrangements are governed by the transaction documentation and the parties identified within it.
What FJP Investment can help investors understand
Within our introductory role, we can provide general information concerning opportunities we are prepared to introduce and facilitate communication with the relevant third-party providers.
An investor may want to understand:
- what the investment structure is;
- who the issuer is;
- what the company does;
- why capital is being raised;
- what documentation is available;
- what security is described as being provided;
- who the relevant professional parties are;
- what material risks have been identified; and
- where further information can be obtained.
Investors can then carry out their own assessment and obtain independent professional advice where appropriate.
Why FJP Investment limits detailed introductions to qualifying investors
Some private and alternative investment opportunities are subject to restrictions concerning the people to whom they can lawfully be promoted.
FJP Investment therefore uses an investor-qualification process before providing detailed information where the applicable framework requires it.
Qualification should not be confused with an investment recommendation.
An individual meeting the relevant eligibility criteria remains free to:
- request more information;
- ask questions;
- seek independent advice;
- carry out further due diligence;
- decide the opportunity is not for them; or
- take no action at all.
The investor still makes the investment decision
This is ultimately the defining feature of a non-advisory introduction.
The investor considers the information and decides independently whether to proceed.
The investor should understand the potential downside and should never proceed simply because:
- an introducer showed them the opportunity;
- other investors have participated;
- professional firms appear in the transaction;
- security exists;
- a company has operated successfully in the past; or
- the investment documents contain contractual obligations.
None of those things eliminates investment risk.
Questions investors should ask about an introducer relationship
A useful checklist includes:
- Who is introducing the opportunity?
- What exactly is the introducer’s role?
- Is the introducer providing advice or simply information and an introduction?
- Who is the underlying issuer?
- Who manages the underlying company?
- Who prepared the investment documentation?
- Who receives my money?
- Who owes me contractual obligations?
- Who holds any security?
- Who values the relevant assets?
- Who provides ongoing investor reporting?
- Who deals with repayment or maturity?
- What regulatory framework applies?
- What independent checks can I carry out?
- Where should I obtain legal or tax advice?
These questions help separate the introduction process from the investment itself.
Frequently asked questions
What is an investment introducer?
In general business terms, an investment introducer connects investors or potential investors with third-party investment providers or opportunities. The legal and regulatory position depends on the actual activities undertaken.
Is an investment introducer a financial adviser?
Not necessarily. Introducing and advising are different activities. An introducer who does not provide investment advice should not make personal recommendations or present a particular investment as suitable based on an individual’s circumstances.
Does an introducer decide whether I should invest?
Not where the service is non-advisory. The investor makes their own investment decision and may obtain independent professional advice where appropriate.
Does an introducer assess suitability?
Not automatically. Investor eligibility and personal suitability are different concepts. A non-advisory introducer does not determine whether a particular investment fits an individual’s personal objectives or circumstances.
Does an introducer manage the company I invest in?
No, not simply because it made the introduction. The directors and management of the underlying company remain responsible for operating their business.
Does an introducer hold investor money?
Not necessarily. The appropriate recipient of subscription funds should be identified from the transaction documentation. Handling client money is a separate regulatory matter.
Does an introducer guarantee an investment?
No. An introduction does not guarantee company performance, asset values, security recovery or repayment.
Can an introducer carry out due diligence?
An introducer may review opportunities before deciding whether they are ones it is prepared to introduce. The scope varies between businesses, and such a review does not guarantee the investment or replace the investor’s own due diligence and independent professional advice.
Is an introducer responsible for the issuer’s business decisions?
Not simply because it introduced the opportunity. Operational decisions remain the responsibility of the directors and management of the underlying business unless another legal arrangement expressly provides otherwise.
What is an Introducer Appointed Representative?
An Introducer Appointed Representative is a specific type of appointed representative under the FCA framework whose permitted appointment is limited to effecting introductions and distributing specified non-real-time financial promotions for its principal or group. It should not be confused with every business that describes itself as an introducer.
Can introducing become a regulated arranging activity?
Potentially. FCA guidance explains that regulated arranging can have a broad scope and that some arrangements made by introducers may fall within it. The position depends on what the business actually does and any applicable exclusions or exemptions.
Does calling something an introduction avoid the financial-promotion rules?
No. Financial-promotion rules look at the substance and content of communications. An invitation or inducement to engage in investment activity can be a financial promotion regardless of the label placed on the relationship.
What does FJP Investment do?
FJP Investment acts as an introducer to third-party private investment opportunities. We consider opportunities before deciding whether they are ones we are prepared to introduce and provide general information to qualifying investors. We do not provide personalised investment advice, assess personal suitability, manage investor money or guarantee investment outcomes.
Final thoughts
An investment introducer can perform a useful role.
Private companies need capital.
Investors want access to opportunities they may not discover through conventional public markets.
An introducer can help those parties find one another and can facilitate the flow of information between them.
But the introduction should not blur the responsibilities of the different parties.
The issuer remains the issuer.
Management remains responsible for the underlying business.
A security trustee remains responsible for the security functions allocated to it.
Professional advisers remain responsible for the advice they provide.
And the investor remains responsible for deciding whether to invest where no advisory service is being provided.
For that reason, one of the most useful questions an investor can ask is:
“Who is responsible for what?”
Understanding that answer can make the entire investment structure considerably clearer.
FJP Investment acts as an introducer to third-party private investment opportunities. If you meet the applicable investor eligibility requirements and wish to understand more about our introduction process, you can register your interest below.
Capital is at risk. Private and alternative investments can be unregulated, complex, illiquid and/or non-transferable, and investors may lose some or all of their capital. An introduction does not constitute a personal investment recommendation or suitability assessment and does not guarantee the performance of an underlying issuer or investment. FJP Investment acts as an introducer and does not provide personalised investment, legal or tax advice, manage investor money or guarantee repayment. Investors should carry out their own due diligence and obtain independent professional advice where appropriate.