This procedure applies to all client money received, held and disbursed by D2 Real Estate across both our Jersey and Guernsey operations. It covers all forms of client money — whether received by cheque, electronic transfer (BACS/bank transfer) or any other means. Cash is not accepted by the Firm.

The procedure has been designed to ensure compliance with the RICS Rules of Conduct for Firms, the RICS professional statement Client Money Handling, 1st Edition, October 2019, the RICS Client Money Protection Scheme Rules, and all applicable anti-money laundering legislation and regulations in Jersey and Guernsey.

Overall responsibility for client money handling rests with the Managing Director, Phil Dawes MRICS. Day-to-day management is carried out by the Finance Department under the supervision of Marta Szelest, Finance Director. All staff who handle or process client money are trained in these procedures and in the relevant RICS requirements.

This procedure is reviewed regularly and no less than every 18 months, in line with our internal review cycle. It was last updated in April 2025. A copy is published on our website and is available free of charge to any person who reasonably requires one, and to RICS upon request.

Client money is money of any currency (whether in the form of cash, cheque, draft or electronic transfer) that the Firm holds or receives on behalf of another person — including money held as stakeholder — and which is not immediately due and payable on demand to the Firm for its own account.

This excludes fees paid in advance for professional (surveying) work agreed to be performed and clearly identifiable as such. However, any advance fees for property agent services are treated as client money in accordance with the RICS Client Money Protection Scheme for Property Agents.

We maintain strict separation between client money and the Firm's own office money at all times. Where we receive mixed payments (containing both client money and office money), the full amount is paid into a client account first. The office money element is then transferred to the Firm's office account promptly. Similarly, where client instructions are to hold only part of a payment, the whole payment is placed into a client money account before the relevant part is transferred out promptly. Office money is never held in a client money account except where mixed monies have been received and the office money element is awaiting transfer.

All client money is held in designated client bank accounts at banks authorised by the relevant banking regulatory body for the jurisdiction — the Jersey Financial Services Commission (JFSC) for our Jersey operations and the Guernsey Financial Services Commission (GFSC) for our Guernsey operations. Client accounts are entirely separate from the Firm's own office accounts.

When we are instructed to hold client money, we provide the following information to clients in writing:

We agree reporting requirements with each client at the point of instruction, as documented in the management agreement. Clients are provided with regular statements and reports on monies held on their behalf, including through service charge demands and year-end service charge accounts. The frequency and format of reporting is agreed with each client individually.

All client money received is paid into a client bank account promptly. We do not accept cash. All sums are processed through our property management accounting system (Tramps) or our office accounting system (QuickBooks), ensuring a complete and accurate record of every transaction.

Each cheque received is allocated to an outstanding demand. The date, amount, method of payment, and cheque number are recorded in the accounting system. Before banking, all cheques are photocopied together with a paying-in slip and saved on file. Cheques are banked on receipt.

Client bank accounts are monitored daily. Any amounts received by electronic transfer are identified and allocated to the relevant outstanding demand promptly, with the date, amount and method of payment recorded in the accounting system.

We take prompt action to identify the owner of any unidentified client money received. Unidentified funds are reviewed as soon as possible and no later than one month from receipt. We maintain a detailed listing of all unidentified funds, including the date of receipt, how the money was received, the bank statement reference and the amount. Our investigation includes checking accounting records for outstanding demands, writing to the last known address of potential clients or tenants, and attempting to repay through the banking system where possible.

Where the owner cannot be identified after three years from receipt and all reasonable avenues of investigation have been exhausted, the funds will be paid from the client account to a registered charity. In such cases, the Firm obtains a receipt and an indemnity from the charity that would reimburse the Firm for payment of the monies if the beneficiary is subsequently identified. The Firm remains responsible for ensuring that client money is repaid should the owner later come forward.

Interest and any other benefits accruing from client money are accounted for to the client, unless otherwise agreed with the client in writing. The arrangements for interest are set out in the management agreement with each client.

Payments from client accounts are made in line with the RICS professional statement on Client Money Handling. Each client's money is used only for that client's matters. Client money is returned to the client immediately as soon as there is no longer any reason to retain those funds, and any further payments received (e.g. by refund) are paid to the client immediately.

All supplier invoices must be authorised in accordance with our Creditor Management procedure before any payment can be processed. Once authorised, payments are uploaded to our online banking platforms (eQ and I-Portal). The Finance Department prepares payments using CSV files generated by Tramps for service charge payments and online banking forms for corporate-related payments.

All online payments from client accounts require approval by two authorised members of staff. The payment inputter submits the payment together with supporting documentation to authorised verifiers, who check the payment details and supporting documents before releasing the payment using registered card readers and online banking cards.

Once payments are authorised and released, the authorisers confirm completion to the Finance Department. All payment records, including supporting documentation, are retained securely on file.

Any bank charges or transactional fees levied in respect of a general client account are not debited to the client account but taken from the office account.

Client money is not held for longer than necessary. Monies are disbursed promptly once the purpose for which they are held has been fulfilled, and funds are not retained in the main client account for more than five working days after clearing where payment is due.

All client bank accounts are reconciled on a monthly basis using a three-way reconciliation between the bank statement balance, the general ledger (cash book) balance, and the individual client ledger balances. This is a mandatory RICS requirement and is fundamental to ensuring that all client money is properly accounted for.

All reconciliations are reviewed and signed off by a Director of the Firm each month. This ensures independent oversight of the reconciliation process and provides assurance that any discrepancies are identified and resolved promptly.

D2 Real Estate is a member of the RICS Client Money Protection Scheme. This scheme exists to provide a level of consumer protection in the event that an RICS-regulated firm is unable to repay client money due to misappropriation or other failure. Membership of the scheme is mandatory for all RICS-regulated firms that hold client money.

We pay the required regulatory review fee and Client Money Protection Scheme levy on an annual basis. The Firm participates in the RICS client money regulatory review visit programme, under which RICS inspectors attend our offices to review and verify our client money handling procedures and controls.

Where the Firm earns any commissions or other pecuniary reward from third parties while managing a client's property (for example, insurance commissions), these are disclosed to the relevant client in accordance with RICS requirements.

The Firm takes its obligations under the RICS professional statement extremely seriously. Any breach of these requirements is investigated and remedied promptly on discovery (within three days), including the replacement of any money improperly withheld or withdrawn from a client account.

Any breach of the mandatory requirements of the RICS professional statement on Client Money Handling is recorded in writing in sufficient detail, including consideration of whether to inform RICS and any client affected by the breach.

In the event that client money is misappropriated by any person, the Firm will inform RICS, the affected client and the Firm's professional indemnity insurers immediately. The matter will also be reported to the police and a record kept of that report and any subsequent advice or action.

All staff are informed about how to report concerns about client money security to a principal. This includes information about whistleblowing to an appropriate outside body (e.g. RICS) if they are concerned about a risk to client money from a principal or if their concerns are not responded to appropriately.