Conflicts of Interest Policy Disclosure Statement

Conflicts of Interest Policy Disclosure Statement November 2020

1 Purpose

Under the FCA’s Rules we are required to take all reasonable steps to identify and manage conflicts of interest between:

  1. us (including for these purposes our directors, managers, employees, or any person directly or indirectly linked to us by control) (together “Staff”) and a client; or
  2. one client and another client.

The FCA ‘s Rules require us to put in place a conflicts of interest policy (“Policy”) which sets out the organisational and administrative arrangements we will maintain and operate with a view to taking reasonable steps to prevent conflicts of interest from constituting or giving rise to a material risk of damage to the interests of our clients. This Conflicts of Interest Policy Disclosure Statement (“Disclosure Statement”) is intended to provide you with information about the Policy. 

2 Scope of Application

Our duty is to identify and manage conflicts of interest applies with respect to all clients carrying out regulated activities or ancillary services for clients.

3 Identification of Conflicts

We have identified and documented the key actual or potential conflicts of interest we face in our day to day business and how these are controlled. These are reviewed periodically and updated when a new actual or potential conflict of interest is identified. Our Policy is made available to all Staff to ensure that they are aware of how we deal with relevant actual or potential conflicts of interest.

For the purposes of identifying actual or potential conflicts of interest we consider whether we or a relevant member of Staff:

  1. is likely to make a financial gain, or avoid a financial loss, at the expense of a client;
  2. has an interest in the outcome of a service provided to the client or transaction carried out on behalf of a client, which is distinct from the client’s interest in that outcome;
  3. has an incentive to favour the interest of another client or group of clients over the interests of a client;
  4. carries on the same business as a client; or
  5. receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of remuneration, goods or services, that is not the standard commission or fee for that service;
  6. personal account dealing

4 Conflict Avoidance

Where an actual or potential conflict of interest is identified, we will seek to organise our business activities in a manner which avoids such a conflict. This may include considering the appropriateness of external relationships.

5 Conflict Management

Where an actual or potential conflict of interest is unavoidable, we seek to identify them in advance and provide for their mitigation and management.  These management arrangements will be designed to ensure we or its Staff are not advantaged, and that no client is disadvantaged.

6 Conflicts Disclosure

Where we are not reasonably confident that we are able to manage an actual or potential conflict of interest to adequately protect the interest of a client, we must clearly disclose the general nature and/or sources of the actual or potential conflict of interest to the client before undertaking any business.

The disclosure will be in a durable medium and provide sufficient details, taking into account the nature of the client, to enable that client to make an informed decision with respect to the service in the context of which the conflict of interest arises.

7 Conflict Monitoring

We have procedures and controls to detect actual or potential conflict of interest situations as they arise, and the Compliance Officer will update the Policy accordingly.  Once actual or potential conflicts of interest have been identified, we have further procedures and controls to monitor our management arrangements of such conflicts.

In addition, our compliance monitoring programme incorporates tests aimed at reviewing our performance in the management of conflicts we have identified. 

8 Education and Awareness

All Staff receive a copy of the Policy and the firm’s compliance manual.  In addition, all Staff are required to adhere to the firm’s compliance procedures, including procedures for personal account dealing and receipt of gifts and inducements.

In addition, all Staff receive both formal and informal training in respect of conflicts of interest generally, and on specific or potential conflicts relating to the firm or the individual personally.

9 Summary of Policy

High Level Procedures and Policies: All Staff are trained in the requirements set out in our Policy and are required to report any actual or potential conflicts of interests which are not already referred to in the Policy they identify to the Compliance Officer.  Conflicts of interest are managed by the Compliance Officer on an on-going basis. 

The Compliance officer maintains a Conflict register which is regularly updated.  

Recruitment of personnel: We undertake pre-employment screening exercises to ensure that Staff are fit and proper and appropriately qualified. Our Staff are required to disclose any outside business interests they may have both before and during their employment.

Supervision of personnel: All Staff are appropriately supervised and responsibility for supervision ultimately rests with the Senior Management.

We have in place measures designed to prevent or limit any person exercising inappropriate influence over the way in which our representatives carry out services or activities.

Personal Account Dealing: Staff are required to adhere to our Personal Dealing Policy for Shares

Gifts and Entertainment: The firm’s gifts and entertainment policy is for Staff to declare all gifts and entertainment received to the Compliance Officer and ensure that our staff act with integrity and pay due regard to customers’ interests when giving or accepting gifts or entertainment.

Confidentiality: We have a strict client confidentiality policy to ensure that all information relating to clients is retained with the firm and treated as confidential information.  Confidential information is only disclosed to those entitled to receive it.  Staff are prohibited from using any such confidential information for their own interests.

Disclosure of conflicts to you: As a last resort, where there is no other means of managing the conflict or where the measures in place do not, in our view, sufficiently protect your interests, the conflict of interest will be disclosed to you or we will decline to act for you. Such disclosure:

    • will be made in writing; and
    • will contain sufficient detail to allow you to make an informed decision with respect to the service to be performed and in the context of which the conflict of interest arises.

10 Status of this disclosure

This Disclosure Statement is provided to you for information only and is not intended to be contractually binding or impose or seek to impose any obligations on us which we would not otherwise have under the FCA Rules or any client terms of business or agreement.

11 Further information

If you require further information about our Conflicts of Interest Policy, please contact the Compliance Officer.