Hargreaves Lansdown Asset Management Limited · DRN-6124587

The complaint Mr G complains that Hargreaves Lansdown Asset Management Limited (‘HL’) failed to deliver an adequate service when transferring his share certificates into his dealing account. Mr G says HL’s actions have impacted him by c£250,000. What happened Mr G holds an investment dealing account with HL. While on holiday, he contacted HL on 11 May 2025 by secure message to ask them to post CREST forms to his home address; Mr G wanted to send in some paper share certificates to add into his dealing account. HL confirmed to Mr G that the forms were sent on 12 May 2025. Within the confirmation were instructions on how to lodge the share certificates. The confirmation also provided the opportunity to download the CREST form. On 20 May 2025, Mr G returned the CREST form and share certificates in the prepaid envelope provided by HL. On 22 May 2025, Mr G got in touch with HL to ask if they had received his CREST form and share certificates. The response to his message was sent before share lodgement at 12:01pm on that day. Mr G sent a second secure message on 22 May 2025 and HL responded saying the share certificates hadn’t arrived and that the prepaid envelope was first class by Royal Mail and generally took three to five days to arrive. At the time of this response, share lodgement had taken place although it’s not clear whether this would have been seen by the help desk, the department that responded to his email. Following share lodgement on 22 May 2025 at 12:01pm, the share certificates were then sent to the CREST counter via courier and received by the CREST counter on 23 May 2025. The certificates were then sent to the Registrar to transfer the shares from Mr G’s name to HL in nominee form. On 23 May 2025, Mr G registered a complaint with HL. He explained that he was unhappy with the time it took for his share certificates and the CREST form to reach HL and that the wording on the envelope was, in his opinion, misleading. He stated that the wording ‘priority service’ on HL’s envelope, suggested that it was a guaranteed next day service. On 27 May 2025, Mr G asked HL for an update on his complaint and shares lodgement. The shares were settled into Mr G’s account on 27 May 2025 at 10:10am and the shares were available to trade that day. Mr G sold his shares on 27 May 2025 and 4 June 2025. HL responded to Mr G’s complaint on 24 June 2025. They said that while the prepaid envelope provided was a first class priority service, it was not a next day service, and that

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they weren’t accountable for any postal delays. HL apologised if the wording on the envelope caused confusion and offered £50 as a gesture of goodwill to resolve the complaint. Mr G entered into correspondence with HL, ultimately concluding Royal Mail was HL’s supplier and chosen carrier for the priority service and therefore responsible for the shares and CREST forms being received two days after they were posted to HL. HL responded, explaining that they didn’t have a commercial agreement with Royal Mail; the envelope provided was a courtesy to assist clients but did not imply any formal service level agreement. Because HL doesn’t have a contract with Royal Mail directly, they were unable to escalate postal delays in the way they could with a contracted supplier. Mr G was unhappy with HL’s response, so he referred his complaint to this service. The complaint was then considered by one of our Investigators. She concluded that HL hadn’t treated Mr G unfairly and she also said, in summary: • The word ‘priority’ printed on the envelope didn’t imply the contents would be delivered the day after it was sent. • She would have expected the envelope to say it was a next day delivery service if the envelope provided a guaranteed next day delivery. And she understood that HL didn’t promise next day delivery prior to when Mr G had sent the envelope. • She wasn’t persuaded that HL are responsible for the service provided by Royal Mail because they don’t have a commercial contract with them. • HL’s Terms and Conditions state that: “… We are not responsible for the loss of any documents, or the cost of replacing them, or for any other loss, cost or expense resulting from delay, or failure of delivery of, any communication we send or receive…”. • She didn’t think HL had provided misleading information about the envelope delivery timeframe and they are not responsible for the time it took the envelope to be delivered. • Following receipt of the envelope on 22 May 2025, share lodgement took place the same day, so she didn’t consider there was a delay here. Mr G, however, disagreed with our Investigator’s findings. In summary, he said: “HL have made a song and dance about terms and conditions etc to avoid any responsibilities! Their representative actually admits that the wording of the envelope may need revising! They make a song and dance about “no contractual agreement with Royal Mail” So what? When standing in the post office, an envelope in my hand with Priority Service emblazoned all over it, am I supposed to be asking myself mmm I wonder if HL have a contract with Royal Mail? What actually did the “Priority Service mean? I am of the opinion that it is just a slogan, without any actual importance. In my opinion they are just waffling to get out of a corner. Their Priority Service didn’t actually mean anything. I think they sold me a pup, and delivered a MESS.”

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Our Investigator was not persuaded to change her view as she didn’t believe Mr G had presented any new arguments she’d not already considered or responded to. Unhappy with that outcome, Mr G then asked the Investigator to pass the case to an Ombudsman for a decision. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. I have summarised this complaint in less detail than Mr G has done and I’ve done so using my own words. The purpose of my decision isn’t to address every single point raised by all of the parties involved. If there’s something I’ve not mentioned, it isn’t because I’ve ignored it - I haven’t. I’m satisfied that I don’t need to comment on every individual argument to be able to reach what I think is the right outcome. No discourtesy is intended by this; our rules allow me to do this and it simply reflects the informal nature of our service as a free alternative to the courts. My role is to consider the evidence presented by Mr G and HL in order to reach what I think is an independent, fair and reasonable decision based on the facts of the case. In deciding what’s fair and reasonable, I must consider the relevant law, regulation and best industry practice. Where there’s conflicting information about what happened and gaps in what we know, my role is to weigh up the evidence we do have, but it is for me to decide, based on the available information that I've been given, what's more likely than not to have happened. And, having done so, I’m not upholding Mr G’s complaint - I’ll explain why below. I want to start by acknowledging to Mr G that I very much gained a sense of how upset he is about this issue. He says that HL’s “Priority Service” envelope is misleading and had he known the service wasn’t a next day offering, he would’ve used Royal Mail’s guaranteed next day delivery. HL have explained that the use of the words ‘Priority Service’ on the envelope means that it’s a faster, often cheaper alternative to standard 1st Class for businesses, aiming for next- day delivery but at a slightly lower rate than full 1st Class. Whilst this will likely come as a disappointment to Mr G, I don’t agree that HL’s envelope is misleading or that it provides any guarantees of a next day delivery service. I say that because if HL were offering a next day service, I’m of the view the envelope would say that, but it doesn’t. In the absence of such wording, I don’t think it was reasonable for Mr G to assume next day delivery was assured. Whereas Royal Mail’s next day guaranteed delivery service is explicit in what it offers. Mr G says that there’s been a financial impact on him of around £250,000 as a consequence of the day’s delay. I think in light of the amounts involved here, if Mr G needed his share certificates to arrive at HL by the following day, he should have elected to purchase Royal Mail’s Guaranteed next day offering rather than relying on a pre-paid envelope. While I do not doubt that Mr G made investment decisions he believes were influenced by when the shares became available to sell, the firm is only responsible for losses that arise as a reasonably foreseeable consequence of their actions. Here, HL did not guarantee next day delivery, nor did they take any action that made such a guarantee likely. In these circumstances, I cannot reasonably conclude that HL should be held responsible for

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investment outcomes that depended on guaranteed next day receipt of documents they had not promised to deliver within that timeframe. A cursory look online suggests that Royal Mail’s regulator, OFCOM, requires that 90% of first class mail is delivered by the next working day. Whilst I’m not privy to what volume of mail is actually delivered within that expectation, I think it’s fair to say that not all post for a variety of reasons can be delivered the following day, so whilst it’s not an unreasonable expectation, it’s not a certainty that post will arrive the next day. And in any event, I’ve not seen any evidence that any of HL’s team provided Mr G with any guarantees that their envelope would definitely arrive by the next day; that’s a conclusion that Mr G arrived at himself. I’ve looked closely at the timeline on this case and from the point that Mr G posted the CREST form and share certificates to the point of the shares being sold, was only five working days. Importantly, from the point HL received Mr G’s share certificates and CREST form to when the shares were available for him to sell, was only three working days, and some of that time was a consequence of the CREST counter and Registrar undertaking their respective tasks. So, I can’t conclude that HL didn’t act in a timely manner upon receipt of Mr G’s paperwork but in any event, I’ve not seen any guarantees setting out that those tasks could be completed any sooner. I think it is also important to highlight that the overall timeline I’ve explained above, from posting to the shares becoming available for trading was relatively short in the context of paper share certificate processing. The steps undertaken by HL, the CREST counter and the Registrar were completed within timescales I would generally expect for this type of transaction. There is nothing in the evidence to suggest that HL introduced any unnecessary delay into the process. So, taking all of this into account, I’m satisfied that HL acted within the scope of their obligations, accurately described the service being provided and processed Mr G’s documents without avoidable delay once they were received. While I appreciate how disappointed Mr G feels about the situation and the financial impact on him, the evidence doesn’t show that HL failed to provide their service with reasonable care and skill or created any misleading expectation that would make it fair for me to uphold the complaint. HL have offered Mr G £50 as a gesture of goodwill rather than as any admittance of wrongdoing. As I’ve not been able to conclude that HL have done anything wrong, I won’t be making an award in this instance but if Mr G does wish to accept HL’s offer, he should contact them directly. My final decision I’m not upholding Mr G’s complaint and it therefore follows that I won’t be instructing Hargreaves Lansdown Asset Management Limited to take any further action. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr G to accept or reject my decision before 26 April 2026. Simon Fox Ombudsman

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