Conflicts of Interest Policy
The Firm is committed to maintaining the highest professional standards and principles in providing services to its clients. The interests of clients must always come first, and the Firm always seeks to identify, consider and manage potential conflicts of interest and protect the integrity of its relationships with its clients.
Identification of Conflicts
The Firm seeks to ensure it can appropriately and effectively identify and manage potential conflicts through avoidance, establishing Chinese Walls (information barriers), or acting with an appropriate level of independence and/or by providing appropriate disclosure of the conflict to affected clients.
In determining whether there is or may be a conflict of interest, the Firm considers whether there is a material risk of damage to the client, considering whether it or an employee:
- is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
- has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;
- has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client;
- carries on the same business as the client; or
- 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 monies, goods or services, other than the standard commission or fee for that service.
In accordance with FCA rules, the Firm has in place arrangements to manage conflicts of interest that arise between it and its clients and between its different clients. Where the Firm does not consider that the arrangements are sufficient to manage a particular conflict, it will inform the client of the nature of the conflict so that the client can decide how to proceed.
Such potential conflicting interests or duties may arise because:
- either the Firm or an associate undertakes business for other clients;
- any of the Firm’s officers or employees, or those of an associate, is a director of, holds or deals in securities of, or is otherwise interested in any company whose securities are held or dealt in on the client’s behalf;
- the transaction is in securities issued by an associate or the client of an associate;
- the transaction is in relation to an investment in respect of which the Firm or an associate may benefit from a commission, fee or mark-up payable otherwise than by the client, and/or the Firm or an associate may also be remunerated by the counterparty to any such transaction;
- the Firm may act as a client’s agent in relation to transactions in which it is also acting as agent for the account of other clients and associates;
- the transaction is in units or shares of in-house funds or any company of which the Firm or any associate is the manager, operator, adviser or trustee;
- the Firm may effect transactions involving placings and/or new issues with an associate who may be acting as principal or receiving agent’s commission. Associates may retain any agent’s commission or discount or other benefit (including directors’ fees) that accrues to them; or
- the transaction is in securities in respect of which the Firm or an associate, or an officer or employee of ours, or an associate, is contemporaneously trading or has traded on its own account or has either a long or short position.
However, the Firm does not engage in proprietary trading; corporate finance; acting as a principal in market making activities; or investment research for third parties, so the potential for conflicts of interest prevalent in many financial organisations does not apply here.