North Breache Limited ("Nutstuff") is an appointed representative of Messels Ltd. which is authorised and regulated by the Financial Conduct Authority. Our services are provided for information purposes only. Under no circumstances is the research content of this website (“the Research”) to be relied upon as constituting personal investment advice or construed as any offer to sell, or any solicitation of any offer to buy investments. While all reasonable care has been taken to ensure that the research published by Nutstuff is not untrue or misleading at the time of publication, neither Nutstuff nor its officers or employees makes any representation or warranty as to the accuracy or completeness of such materials. No liability is accepted for any loss whether direct or indirect, incidental or consequential, arising out of any of the research not being true and accurate except to the extent caused by the wilful default or gross negligence of Nutstuff or its employees or which arises under the United Kingdom Financial Services and Markets Act 2000.
All research on the Nutstuff websites is believed to be up-to-date at the time it is posted, but is subject to variation without notice.
From time to time Nutstuff and any of its officers or employees may, to the extent permitted by law, have a position or otherwise be interested in any transactions in investments (including derivatives) directly or indirectly the subject of our research. Also Nutstuff may from time to time provide other services (including acting as adviser) to any company mentioned in our research.
The value of shares and other investments and the income derived from them may go down as well as up, and you may not get back the full amount you originally invested. Derivatives in particular are high risk investment instruments which carry a contingent liability, the value of which may be affected by a greater proportion than the change in the value of the underlying investment or asset. If you make an investment in securities that are denominated in a currency other than your own you are warned that changes in rates of foreign exchange may have an adverse effect on the value, price or income of the investment in your own currency. Any persons in doubt as to whether the investments referred to in our research material may be suitable for them, should consult an independent financial adviser.
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CONFLICTS OF INTEREST POLICY - GENERAL
Under FCA’s Principles for Businesses, Principle 8 requires a firm to “manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.” Under the Markets in Financial Instruments Directive (“MiFID”), North Breache Limited (“Nutstuff”) is required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage such conflicts of interest. Nutstuff has put in place a policy to meet this obligation and set out below is a summary of that policy and the key information that is needed by clients and counterparties (together “customers”) to understand the measures Nutstuff is taking to safeguard the interests of its customers.
Nutstuff seeks to:
identify circumstances which may give rise to conflicts of interest entailing a material risk of damage to customers’ interests;
establish appropriate mechanisms and systems to manage those conflicts; and
maintain systems in an effort to prevent actual damage to customers’ interests through the identified conflicts.
WHAT IS A CONFLICT OF INTEREST?
A conflict of interest under MiFID is a conflict that arises in any area of Nutstuff’s business in the course of providing its customers with a service which may benefit Nutstuff (or another customer for whom Nutstuff is acting) whilst potentially materially damaging another customer where Nutstuff owes a duty to the customer. There may be a conflict where Nutstuff (or anyone connected to Nutstuff including another Nutstuff affiliate):
is likely to make a financial gain (or avoid a loss) at the expense of its customer;
is interested in the outcome of the service provided to its customer where the interests of Nutstuff is distinct from that of the customer;
has a financial or other incentive to favour the interests of one customer over another;
carries on the same business as a customer;
receives money, goods or services from a third party in relation to services provided to a customer other than standard fees or commissions.
Nutstuff has sought to identify conflicts of interest that exist in its business and has put in place measures it considers appropriate to the relevant conflict in an effort to monitor, manage and control the potential impact of those conflicts on its customers. The conflicts identified include:
· those between customers with competing interests;
· those between customers and Nutstuff where their respective interests in a particular outcome may be different; and
· those between the personal interests of staff of Nutstuff and the interests of Nutstuff or its customers where those interests may be different.
CONFLICTS OF INTEREST - PROCEDURES
Nutstuff has adopted internal policies and procedures in order to manage recognised conflicts of interests. These policies and procedures will be subject to our normal monitoring and review processes and include:
INTEGRITY AND STANDARDS OF CONDUCT
Nutstuff insists that in its dealings with customers its staff must use the highest standard of integrity in their actions at all times. The induction programme, training and competency procedures and monitoring programme at Nutstuff are designed to ensure that all relevant staff are familiar with and observe, inter alia, the FCA Principles for Businesses, the Statements of Principle and the Code of Practice for Approved Persons.
PERSONAL ACCOUNT DEALING
Nutstuff has a policy on Personal Account Dealing and the rules are signed off as understood by all relevant employees regardless of their position within Nutstuff.
CONFIDENTIALITY AND INFORMATION BARRIERS
Nutsuff insists on strict customer confidentiality to ensure that information is disclosed only to those entitled to receive it or otherwise with the prior approval of the Compliance Department.
INDUCEMENTS TO EMPLOYEES FROM CUSTOMERS
Staff are not allowed to accept gifts, entertainment or any other inducement from any person which might benefit one customer at the expense of another when conducting investment business. Nutstuff has a Gifts and Entertainment Policy which is part of the staff’s Policy Manual and is monitored by management on a regular basis.
All relevant staff who are open to a conflict of interest are paid a basic salary including those in key support areas such as Compliance, Finance and Back Office. This salary is not dependent on company performance. A bonus scheme does exist which is linked to the company’s performance and the performance of the individual. It is entirely discretionary.
SEPARATE SUPERVISION AND SEGREGATION OF FUNCTION
Where appropriate, Nutstuff has arranged for the separate supervision of those carrying out functions for customers whose interests may conflict, or where the interests of customers and Nutstuff may conflict and has taken steps to prevent the simultaneous or sequential involvement of a relevant person in separate services or activities where such involvement may impair the proper management of conflicts of interest.
As a last resort, where there is no other means of managing the conflict or where the measures in place do not, in the view of Nutstuff, sufficiently protect the interests of customers, the conflict of interest will be disclosed to customers to enable an informed decision to be made by the customer as to whether they wish to continue doing business with Nutstuff in that particular situation.
DECLINING TO ACT
Finally, where Nutstuff considers it is not able to manage the conflict of interest in any other way it may decline to act for a customer.
POLICY OF INDEPENDENCE
All investment research issued by North Breache Limited (“Nutstuff”) is independent, impartial and objective. Nutstuff does not conduct any investment business with or for its clients, other than the provision of investment research and advice. Nutstuff staff have no other responsibilities which could conflict with the interests of our clients. Nutstuff does not carry out any corporate finance business; and has no involvement in raising capital for corporate clients. Nutstuff has no other regulated or unregulated business activities which conflict with its provision of independent research.