Q1. What do you consider have been the key developments that we have seen in the wealth management arena over the past 10 years since the financial crisis in 2008 and what has this meant for Jersey and UK providers?
Alan Binnington: “Perhaps the most significant development over the past 10 years has been the introduction of automatic reporting of information following the introduction of FATCA by the United States and CRS by the OECD.
“There is of course a substantial cost to service providers in setting up systems to capture and transmit the relevant information but Jersey has been well-positioned to deal with this given that much of the relevant information was already held as a result of our robust regulatory and anti-money laundering framework.”
Tim Childe: “The past decade has seen a transformation of the wealth management sector, driven primarily by increased regulation, but also by a greater demand by clients for communication and transparency. At the same time, too, the wealth management sector has become much more commercially aware; while a number of fiduciary firms have been acquired by private equity firms and implemented new growth strategies by looking overseas to build a range of key contacts, develop business networks and source new business opportunities. As an example of our own international growth strategy, Quilter Cheviot has opened a representative office in Dubai, which has proved very successful. The strategy has resulted in business relationships and partnerships that are much more reciprocal, enabling our business to develop by leveraging the specialist expertise of our partners at home and abroad.”
Jonathan Giles: “The view from offshore has been a decade of increasing professional service firm consolidation and the growth of global footprints. The expansion through acquisition of previously one or two jurisdiction fiduciary firms into truly global enterprises has been born out of the need to compete globally and take advantage as others de-risk. For some they’ve expanded with a truly competitive advantage whilst others have reacted to the changing face of technology, regulation, government policy and of course client demands. Whether offshore or in the UK the drive to internationalise your business, especially into the faster growth economies, remains a core focus. In one sense Jersey has become an increasing world leader due to its desire and ability to cooperate across these moving parts and support global capital flows. Jersey has worked collectively across industry, regulation and politics to deliver a multi-award winning jurisdiction built on professional skills, commerciality and transparency.”
Q2. Just how significant do you think Jersey’s reputation as a high quality, well regulated, compliant and stable jurisdiction is in attracting high – and ultra-high – net worth individuals and those looking to preserve existing wealth (including wills and pensions), as well as organisations accessing its range of bespoke corporate services, from investment portfolio management to employee benefit services?
Alan Binnington: “In a world of increasing political and financial uncertainty wealthy clients look to place their assets in stable, well-regulated jurisdictions. However, political stability and sound regulation are just a part of their requirements. If assets are to be held in a corporate or fiduciary structure one needs experienced administrators and fiduciaries, along with tax advisers, investment managers and legal advisers. Given the maturity of Jersey as a financial centre the major firms in these specialist areas have a substantial, rather than token, presence on the Island.”
Tim Childe: “Jersey’s reputation as a high quality, well regulated, legally compliant and stable jurisdiction is key to attracting all types of business, whether high and ultra-high net worth clients, or the wholesale, institutional or corporate side of business. Jersey has been proactive in creating a legal and business environment in which the wealth management business can flourish. As a result, Jersey has a full range of service providers with the highest professional standards, who can meet all the particular needs of even those clients with the most complex requirements. In terms of proactivity, Jersey has been on the front foot with various successful initiatives designed, for example, to promote the Island as the ‘Number One IFC’ globally, to promote itself as an ideal place to live, work and do business (Locate Jersey) and as an internationally recognised centre for the digital industries (Digital Jersey). It is a strategy that Jersey has been developing for some time, becoming a model jurisdiction for other offshore centres to emulate. It is no surprise therefore that Jersey was chosen as the hub for Quilter Cheviot’s international business.”
Jonathan Giles: “An often used quote is ‘May we live in interesting times’. Whether a country referendum, political elections, trade tariffs or fake news, we continue to be surprised by the outcome of ‘certainties’. Within this Jersey affords investors a tried, tested and stable route to preserving and enhancing their global wealth. Great professionals with a global perspective supported by modern regulation and infrastructure.”
Q3. Can you give us an insight into the impact on the operations of private banks and wealth managers of recent market developments and new technology, following a shift in focus to client service, value delivery and greater client expectations, accompanied by new regulations such as GDPR (General Data Protection Regulation)?
Alan Binnington: “The private wealth industry is likely to see an increase in the use of technology and, in particular, artificial intelligence (AI). Banking customers are now accustomed to online banking services, with the ability to monitor their accounts on a real time basis. Customers of investment management firms and trust companies are increasingly expecting their service providers to provide similar facilities. In terms of trust services this can be somewhat problematic as a beneficiary of a trust is in a different position from the holder of a bank account and may not be entitled to the same degree of disclosure. Nevertheless trust companies are likely to make increasing use of technological advances to provide their trust beneficiaries with up to date information. Artificial intelligence is also likely to speed up some of the more routine aspects of trust and company administration, hopefully freeing up staff to provide a more personal service as and when that is required. There is of course significant potential for AI to be used to support the ever-increasing focus on compliance requirements, both in terms of the collection and analysis of all-important KYC and due diligence information.
“Increased regulation will always present a challenge to business. For example GDPR, whilst having obvious benefits in terms of ensuring that data is being used correctly could slow down business processes and add to the cost of doing business. One of the advantages that smaller jurisdictions such as Jersey have over larger jurisdictions is that when new regulation is introduced there is likely to be a more direct dialogue between regulator and industry, hopefully ensuring that regulation is introduced in a proportionate manner. However much regulation, of which GDPR is an example, is in a form decided upon elsewhere and has to be introduced if the Island is to continue marketing its services.”
Tim Childe: “Without a doubt, technology is essential for the future growth and development of the wealth management sector. Millennials, in particular, may be more comfortable adapting to the fast-moving potential of technology as a wealth management tool but, at Quilter Cheviot, we have been building our business and reputation on the basis of personal relationships since 1771. As such, personal relationships are the tried and tested way to provide the service our clients expect. For us, therefore, personal relationships remain the bedrock of our business. Nevertheless, as the demands of regulations and client expectation increase – and as our ways of communicating evolve – technology has become an essential tool that will enable us to achieve the best outcomes for our clients. If our ethos remains unchanged over the years, so does our commitment to ensuring we have all the technology and software necessary to provide our clients with the service they expect.”
Jonathan Giles: “Technology remains both the source of certain issues as well as the solution. Whether it be cyber security, investment risk management tools, anti-money laundering screening, online client reporting or business frameworks to accommodate legislation such as GDPR, substantial financial investment, and where necessary changes in behaviour, will continue to have a significant impact on the private client world. All firms are implementing more stringent practices ensuring data is better stored with adequate processes in place to protect it and investing to improve employee training, work practices, cyber security awareness and client relationship management software.”
Q4. How important will it be for the development of new business segments and future client engagement, to integrate digital tools and capabilities into current processes, with the implementation of new technology and risk management systems providing integrated approaches aligning risk and value, as the global wealth management industry addresses new standards and regulatory changes impacting front-end client experience and increasing costs?
Alan Binnington: “The maintenance of Jersey’s reputation as a responsible finance centre requires private wealth businesses within the Island to ensure they have in place procedures designed to identify and manage the risks in their business. Gone are the days when all that was required was to request a copy of a customer’s passport and two utility bills. Nowadays extensive research has to be carried out into the source of wealth of prospective customers and the source of the funds that they are placing with an institution. In addition, once the business has been taken on, regular checks need to be made in relation to the clients, their activities and the funds that they introduce. Fortunately technology is of increasing assistance in this area. Online search facilities are available to check the background of prospective clients from publicly available information, searching numerous databases at the same time, a task that would previously have taken a significant length of time. In addition systems are now available that will automatically screen an institution’s entire list of clients on a daily basis. Such systems have been utilised by banks for some time but they are increasingly being introduced by other areas of the private wealth industry.
“The Island’s regulatory framework reflects Jersey’s risk appetite and businesses operating within the Island need to ensure that their compliance procedures are aligned. Inevitably there is a cost to compliance and that cost continually rises. It is only by harnessing new technology that such a cost is likely to be contained, ensuring that a reasonable balance is struck between risk, reward and value to clients.”
Tim Childe: “Integrating digital tools and capabilities into our current processes is an essential part of our drive to maintain client satisfaction and to build our business. It is worth noting that in response to the growing regulatory challenges, private banks are increasingly moving upscale by looking for fewer but higher value clients. With Quilter Cheviot’s broader client mix, we are able to deploy digital technologies to ensure our operations are swift and seamless, backed up by the support and security that comes with being a part of Old Mutual Wealth. As an international business, we are particularly aware of the changing nature of regulations affecting the global markets – here too, being able to adopt new rules and adapt to new best practice requirements is made easier by having the necessary technological back-up.”
Jonathan Giles: “Every company in the world wants to be a technology company. Whether the business sells bananas, bank accounts or consumer brands, they all believe they will live or die by their technology. Wealth management is no different and with clients’ total wealth increasing, and becoming more diversified across jurisdiction, currency, custodian and advisor, the search for technology solutions to consolidated advice and reporting continues. Technology does however go much deeper than your front office. The potential for saving money on everyday operations is as staggering as it is attainable. Cutting paperwork and automating basic processes will save the financial industry billions of pounds. It is also necessary if companies are to keep tighter control of information and comply with more stringent reporting regulations. Meanwhile, greater computing power is making high-end investment risk software affordable for ever smaller clients and increasing the market insight of portfolio managers. And all these improvements in technology will help deliver what investors are increasingly demanding: better, more personalised services at an affordable price.”
Q5. Would you outline how your wealth management business is structured and conducted, with an idea of how solutions may be derived from the experience the organisation has gained over the years, rather than perhaps an off-the-shelf approach?
Alan Binnington: “RBC Wealth Management offers an integrated approach to wealth management, providing clients with banking, custody, investment, credit, trust and fiduciary services. Our well-established Wealth Management business in the British Isles (UK and Channel Islands) is underpinned by the strength and expertise of RBC’s global network, enabling us to leverage the bank’s research, technology and reach for the benefit of our clients.
“We’ve had a presence in Jersey for over 50 years now, during which time we have built a highly talented, client-focused team, with a huge amount of expertise. We are committed to truly understanding our clients’ circumstances and needs, so that we can provide them with the best solutions, including – where appropriate – working with our colleagues in Capital Markets, Investor & Treasury Services and Global Asset Management.”
Tim Childe: “Quilter Cheviot has built and refined its business proposition over the years as a provider of bespoke wealth management solutions. It is a strategy that can be traced back to its origins in 1771, when as a stockbroker Quilter managed clients’ money. Over the years, we have grown into one of the largest discretionary fund managers, with a network of offices across the UK, Ireland, Jersey and a representative office in Dubai; we have brought on board new teams and individuals with specific skills and experience, broadening our range and expanding our technical capacity. Despite these changes, staff turnover is remarkably low, indicating that the core of our business and our teams has remained unchanged – namely, the proposition of bespoke wealth management and giving clients direct access to the investment manager handling their investment portfolio.”
Jonathan Giles: “Rathbones in Jersey is the offshore subsidiary of a UK Plc, focused on the delivery of portfolio management for a range of private clients both in Jersey and across the world.
“We provide a bespoke service to each of our clients, managing their affairs according to the merits of their own situation. We gather in-depth knowledge of each client’s financial situation and family affairs which in turn takes us down the path of the most suitable investment service and strategy. International clients are typically invested through fiduciary structures and we have strong working relationships with regulated offshore trust companies and advisors within the main international finance centres.
“Our ethos is simply to deliver the best service possible to clients looking for longer-term returns. We believe this is fundamental to helping our clients to take care of the future. In addition, our commitment to a bespoke approach to investment management is becoming rarer in the wealth management market. With this in mind, we have a framework of a robust and clearly defined investment process within which we give our investment managers a degree of autonomy to apply their own professional judgment and technical expertise in managing a client’s wealth. Our investment managers, supported by dedicated teams, have direct contact with clients and form long and trusted relationships with them. This level of engagement is particularly important when managing a family’s wealth across generations.
Our investment framework has also evolved through personal and corporate experience, with for example our portfolio construction increasingly correlation, risk and real-return focused, an outcome of both the 2008 financial crisis and the growing demands of UHNW investors wanting to preserve their wealth in challenging times, aligning their objectives more towards consistently beating inflation rather than the stock markets.”
Q6. Is your organisation addressing an increasing trend of clients looking to actively manage or be more involved in the management of their financial affairs – being more aware of compliance and risk management following the global financial crisis – and higher expectations vis-à-vis reputation, service and value?
Alan Binnington: “Clients seeking investment management services are certainly more aware of the need for active risk management. Whether this is a result of the financial crisis and various financial scandals that were precipitated by it or whether it is merely a reflection of increased knowledge of the investment world is debatable. No longer is the wealthy individual prepared to place assets with his or her stockbroker and catch up on their performance from time to time over lunch. Investment clients now expect to have regular updates on performance and are inevitably more involved in the investment process, even where the portfolio is managed on a discretionary basis, given the need for the manager to ensure that the asset allocation is in line with the client’s objectives and risk tolerance.
“In the trust world, beneficiaries have a similar desire to be updated on performance but are inevitably less involved in the process given that the trustee is the client of the investment manager rather than the beneficiaries. Nevertheless the trustee still needs to ensure that the portfolio is structured in a manner consistent with the family’s objectives and risk tolerance. In terms of trust formation there is an increasing desire on the part of settlors to have a greater degree of influence over the running of the trust. This is particularly the case in respect of business from new markets such as South East Asia where the trust is a less familiar concept. Jersey is well able to accommodate this through the use of settlor reserved powers or protector provisions.”
Tim Childe: “It is our experience that clients are increasingly likely to outsource the active management of their portfolios. Some clients like to take charge of their investments because they either enjoy it or they feel up to the job. Typically, however, our clients do not have the time, the inclination or the experience required to actively manage their portfolios. Increasingly, our clients have come to understand that since the global financial crisis, investment management has become a much more complex business, with serious regulatory consequences if not done properly. For the sake of speed and simplicity, too, they are less likely nowadays to opt for the more ‘creative’ tax arrangements. When looking at the overall burden of responsibility of managing investments today, clients are much more likely to see the benefits of outsourcing to the experts, who can manage their investments with speed and efficiency, and so leave them to get on with their interests, whether managing a business, a charity, travelling or other projects.”
Jonathan Giles: “We launched our Rathbone Private Office to serve larger clients who required objective advice on how to manage their significant wealth often across a range of liquid, illiquid and non-bankable assets. Classically and for example; property, investments, commercial enterprise such as the family business, other collectibles including wine, cars and art and specialist lending. A significant part of this service is the ability to view client assets on a consolidated basis allowing the client and their advisors an easy to understand insight across the entirety of their portfolios and wider assets promoting where required active dialogue and management. This significantly reduces the administrative burden of managing complex wealth across a variety of different asset classes, banks and custodians. Simply by combining our strengths with the expertise of trusted external partners, we work closely with clients and their advisers to help control all aspects of wealth. Our approach cuts through the complexity and jargon to give guidance that is refreshingly clear. We provide a clear and consolidated view of assets and independent advice that draws on long-standing expertise in wealth management.”
Q7. Following the recent appointment of a Charity Commissioner and a rise in registrations of Jersey foundations – popular for philanthropic purposes and in civil law jurisdictions in Asia and MENA (particularly for Shariah-compliant financing and family businesses where trusts may be unsuitable) – are you seeing increasing client interest in these vehicles?
Alan Binnington: “Although the Jersey foundation is unlikely to overtake the trust in terms of the vehicle of choice for wealth structuring, they are becoming increasingly popular. Although they have obvious attractions for clients who come from civil law countries where the trust is an unfamiliar concept, the historical association of the foundation with charity makes them popular for philanthropic vehicles. In addition they are of use where one wishes to create a holding structure, for example to hold the shares in a private trust company where previously a non-charitable purpose trust would have been used. They can also be used as an alternative to a private trust company, simplifying the structure by removing the additional layer of ownership that would have been required had a company acted as trustee. For families who wish to have greater involvement in the decision making process, a foundation can be a useful alternative to a trust given that family members can sit on its council, alongside a Jersey regulated service provider.”
Tim Childe: “The recent appointment of the Charity Commissioner is another welcome initiative that will help cement Jersey as a centre of excellence in this sector. At Quilter Cheviot, we are well set up to meet the more tailored investment management needs of charities and foundations. As we solely focus on investment management, we work externally with a wide range of structuring specialists who specialise in this area. Internally, we have a specialist division dedicated to the charities sector, well versed in the regulatory obligations and the investment options that this important sector faces. For example, charities typically require that their assets are invested according to ethical guidelines and we have a wide range of solutions to meet these differing needs, such as the award-winning Climate Assets Fund. We also hear anecdotally of a growing demand from clients around the world seeking more sophisticated solutions which are more culturally and societally acceptable. For example, clients in regions such as Asia, the Middle East and Africa can be very reluctant to give up control and a foundation can be a preferable alternative to a trust.”
Jonathan Giles: “As an investment manager we do not advise charities on legal structure; but we are able to use our sector experience to help discuss leadership and governance alongside their investment management requirements. We are for example seeing significant engagement with charities and philanthropists through ‘impact investment’ and how their investments are focused in-line with their overall objectives. Supporting charities through such targeted programmes ensures that the donation actually becomes a sustainable investment for change.”
Q8. Jersey continues to maintain its high standards and levels of expertise, reviewing its Trust Law, continuing to attract and retain top wealth management professionals, whilst training future professionals within the Island to avoid skills shortages which could constrain future growth, so are there any areas that you feel may require any additional attention to ensure it adequately accommodates the development and availability of comprehensive wealth solutions?
Alan Binnington: “Locally based training for finance industry professionals is vitally important. Jersey is fortunate in having a significant pool of experienced and skilled finance professionals and has been successful in attracting skilled individuals to the Island where the necessary skills cannot be found locally. However there is a need to manage population growth and accordingly developing the necessary skills within the Island should be a priority. A significant amount is already being done, whether through professional bodies such as STEP or by educational establishments such as the Jersey International Business School, The Institute of Law and University College Jersey. Although Jersey may not be of a sufficient size to accommodate a university offering a full range of subjects, there is a case for the existing educational establishments to work even more closely together to offer courses that focus on the Island’s niche areas of expertise. The advent of Digital Jersey is also to be welcomed given that as digital technology will be of increasing importance for the finance industry the development of the Island as a centre of excellence in this area can only be of benefit.”
Tim Childe: “Despite being such a fantastic place to live and work, due to its small population, the challenges of recruiting for the financial services sector on Jersey are well-known. With this in mind, it makes sense to both maintain the high professional standards of our staff that our clients around the world have come to expect and to seek recruits from local people, introducing them to the sector through a system of internships and trainee roles. At Quilter Cheviot’s Jersey office, we have two trainee investment managers, who are working towards the professional qualifications that will enable them to develop their careers. We also help the wider community by doing workshops on portfolio management at the Jersey International Business School, whose students range from school-leavers seeking industry qualifications to non-executive directors requiring advanced courses and networking opportunities.”
Jonathan Giles: “Jersey is fortunate to retain the highest reputation for financial services. This attracts great talent to work with the jurisdiction or indeed move to Jersey. We have significant STEP and CISI professional bodies, which afford Jersey a significant advantage in educating, retaining and attracting talent across a broad range of financial services. Plus our highly skilled lawyers and accountants. I mentioned the more collective decision making in an earlier comment and so I’d continue to ask industry and politicians to ensure there is a range of educational opportunities, through schools and perhaps government supported Jersey universities, to ensure flexible learning and more industry employment direct from school for those that do not want to go into tertiary education. As a school governor and adjunct lecturer at the Jersey International Business School, I feel we need to ensure the balance of science and mathematics is managed alongside a creative and technology based curriculum. Technology will continue to be a significant factor in the evolution of the private wealth management industry and we need to increasingly embed these skills.”
Q9. As it builds on its reputation as one of the world’s leading jurisdictions for wealth management services, how does Jersey’s mature finance industry work with global networks of specialists offering international and local expertise, to ensure understanding of clients’ future financial requirements and develop structures in its arsenal that underpin effective bespoke plans for individuals, families and institutional clients, such as ‘virtual’ family offices for ultra-high net worth families and structures for corporate staff reward and retirement schemes?
Alan Binnington: “Preserving Jersey’s position as one of the world’s leading international finance centres is not an easy task. There are a number of ways in which Jersey maintains that position. First, through the work of Jersey Finance, a body that is supported by both government and industry, in keeping international advisers aware of our range of services and, importantly, listening to those advisers to ensure that the Island continues to innovate in respond to the changing needs of ultra-high net worth families. Both industry and government are aligned in respect of the need to ensure the legislative process facilitates innovative solutions to those changing needs and that existing legislation is continually reviewed and kept up to date. Second, Jersey engages with international bodies such as the OECD in order to ensure that the Island complies fully with international regulatory standards, which themselves are continually changing.”
Tim Childe: “Jersey has a well-established finance industry with an enviable reputation for the provision of professional services of the highest standard. Jersey is also known for being a jurisdiction that is proactive in finding business opportunities globally, in the process building a network of contacts that is invaluable to the future growth of Jersey’s economy. The wealth management sector in particular owes its continued growth to an unwavering focus on the needs of the client, well proven over time as the best way to understand their current and future needs. It is only with this understanding in place that the wealth management sector can provide the bespoke solutions most suitable to clients, be they individuals, families or institutions. We are seeing a trend towards more sophisticated financial planning tools, both locally and globally, which are also useful as a way to stay abreast of regulatory trends around the world. Nevertheless, a critical part of our bespoke wealth management service is the face-to-face meeting, which remains the best way to fully understand the client and their needs.”
Jonathan Giles: “Simply understanding that clients want a combination of capabilities and values is a starting point. The resilience and flexibility in Jersey’s trust legislation, the ongoing evolution of Jersey’s corporate services and for example the recent emergence of our leading edge foundation structures, speaks volumes for how the jurisdiction continues to tailor solutions to specific needs. With innovative technology solutions increasingly embedded into industry we are now seeing a broader ability to offer traditional face-to-face advice alongside ‘on-line’ relationships and reporting. As mentioned previously our Private Office service consolidates disparate assets with a report that allows effective dialogue and planning to be facilitated. Whilst currently focused on high to ultra-high net worth investors, the same principles apply to corporate relationships and ultimately retail clients. Technology will continue to scale this service. Warren Buffett once said: “the difference between successful people and very successful people is that the very successful say ‘no’ to almost everything.” In a world where you continually feel you must try to be all things to your client I feel Jersey will bring to bear the best available advice or expertise to address requirements. Jersey Finance – and its ability to develop new markets and deepen existing relationships – will continue to have a crucial role to play in this development.”
Q10. With increasing demand for sophisticated financial solutions being driven by an increase in the number of affluent investors over recent years, what do you see as key areas of opportunity within wealth management, perhaps identifying regions with the greatest potential from which future business is expected to develop in the foreseeable future?
Alan Binnington: “There has been a gradual shift in recent years in respect of the areas of the world that are generating new wealth with the focus moving from Europe and North America to the Middle East and more recently to South East Asia. In addition political uncertainty in some jurisdictions has seen the wealthy seeking more stable jurisdictions in which to manage their wealth. New markets bring new challenges. For example some of these jurisdictions are unfamiliar with the trust concept, hence the need to consider alternative structures such as foundations. Different languages and time zones may cause problems although many institutions have been able to deal with this by employing multilingual staff and introducing flexible working hours to suit the needs of clients based in other time zones. In some of the emerging markets, regulatory regimes may be below international standards which require institutions to carry out enhanced due diligence. There may be cultural differences such as, for example, the desire of trust clients from South East Asia to demand a higher degree of control over a structure than might otherwise be the case. Jersey has proved itself well able to meet these challenges, ensuing that it continues to service the ever-changing needs of international wealth management clients. At the heart of the finance industry lies considerable experience in administration, whether that be in relation to trusts, companies, employee benefit schemes, pensions or funds. Looking to the future, Jersey needs to ensure that those administrative skills are adapted and promoted as the needs of the world’s wealthy change.”
Tim Childe: “At Quilter Cheviot, a major development in our international growth strategy has been our new representative office in Dubai. Already, the representative Dubai office has proved a great success, now firmly established as a business model that could be replicated further afield. One of the key advantages of Dubai is that it offers greater access to international regions that have a huge potential for growth thanks to a real appetite for services that we tend to take for granted – for example, direct access to a dedicated investment manager, lower fees and direct purchasing of highly researched individual securities such as stocks and bonds. Thanks to the increasingly international outlook of our Jersey office, we can spread wider our core message of bespoke, tailored discretionary fund management.”
Jonathan Giles: “Whilst we will see Asia, Africa and the Gulf, alongside other fast growing economies, continuing to generate newer wealth, we can’t forget the existing developed country clients. Companies and jurisdictions best able to address both – and the increasing demographic shift to the next generation – will be set to continue or accelerate their growth. The sophistication and growth of this wealth, whether young, old or new, is now also demanding greater clarity and certainty. Private and Investment Office services will become more prevalent, built upon experienced professionals, smart technology and a ‘whole of wealth’ approach.”
