Global Thematic Investment Insight
Terms, Conditions and Conflict of Interest Policy
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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”), Entext Communications Limited (“Entext Communications”) 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. Entext Communications 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 Entext Communications is taking to safeguard the interests of its customers.
Entext Communications seeks to:
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identify circumstances which may give rise to conflicts of interest entailing a material risk of damage to customers’ interests;
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establish appropriate mechanisms and systems to manage those conflicts; and
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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 Entext Communications’ business in the course of providing its customers with a service which may benefit Entext Communications (or another customer for whom Entext Communications is acting) whilst potentially materially damaging another customer where Entext Communications owes a duty to the customer. There may be a conflict where Entext Communications (or anyone connected to Entext Communications including another Entext Communications affiliate):
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is likely to make a financial gain (or avoid a loss) at the expense of its customer;
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is interested in the outcome of the service provided to its customer where the interests of Entext Communications is distinct from that of the customer;
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has a financial or other incentive to favour the interests of one customer over another;
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carries on the same business as a customer;
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receives money, goods or services from a third party in relation to services provided to a customer other than standard fees or commissions.
Entext Communications 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 Entext Communications where their respective interests in a particular outcome may be different; and
· those between the personal interests of staff of Entext Communications and the interests of Entext Communications or its customers where those interests may be different.
POLICIES AND PROCEDURES
Entext Communications 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
Entext Communications 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 Entext Communications 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
Entext Communications has a policy on Personal Account Dealing and the rules are signed off as understood by all relevant employees regardless of their position within Entext Communications.
CONFIDENTIALITY AND INFORMATION BARRIERS
Entext Communications 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. Entext Communications has a Gifts and Entertainment Policy which is part of the staff’s Policy Manual and is monitored by management on a regular basis.
REMUNERATION POLICY
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, Entext Communications has arranged for the separate supervision of those carrying out functions for customers whose interests may conflict, or where the interests of customers and Entext Communications 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.
DISCLOSURE
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 Entext Communications, 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 Entext Communications in that particular situation.
DECLINING TO ACT
Finally, where Entext Communications considers it is not able to manage the conflict of interest in any other way it may decline to act for a customer.
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POLICY OF INDEPENDENCE
All investment research issued by Entext Communications Investment Ltd (“Entext Communications”) is independent, impartial and objective. Entext Communications does not conduct any investment business with or for its clients, other than the provision of investment research and advice. Entext Communications staff have no other responsibilities which could conflict with the interests of our clients. Entext Communications does not carry out any corporate finance business; and has no involvement in raising capital for corporate clients. Entext Communications has no other regulated or unregulated business activities which conflict with its provision of independent research.
INTERESTS IN SECURITIES
Entext Communications, its directors or employees may have interests in the securities on which we provide research and may add to or dispose of such securities from time to time. Entext Communications may have provided advice, other investment or professional services to the issuer of the securities. Any such interests are reviewed by a director of Entext Communications to ensure that they do not represent conflicts of interest with our customers.
CONDUCT OF OUR INVESTMENT ANALYSTS
All of Entext Communications’ investment analysts are supervised by directors of the firm. The remuneration structure for Entext Communications’ analysts may be linked in any way to dealing or other activities which our customers carry out as a result of the independent research provided by the firm. In the event of any conflict of interest, Entext Communications requires all relevant employees to disregard any material interest or conflict of interest when advising a customer. Our analysts are not permitted to be involved in any activities which could be seen as conflicting with our provision of investment research to our clients. No inducements offered by issuers, or others with a material interest in the subject matter of investment research, may be accepted by our investment analysts or directors of the firm. No employee of Entext Communications may carry out any personal account dealing which could create a conflict of interest which might affect the impartiality of Entext Communications’ investment research. Any proposed personal account dealing by employees is subject to pre-approval by a director of Entext Communications and no dealing which could create a conflict of interest between the employees of Entext Communications and its customers is permitted. In addition, a prohibited list of securities is maintained. All outside business activities of employees are subject to prior approval by a director of the firm.
OUR RESEARCH
The timing and manner of publication and distribution of investment research and of the communication of its substance must be approved in advance by a director or senior analyst of Entext Communications. Before being issued, all research documents must be approved and signed-off by a director or senior analyst. No one outside Entext Communications may comment on draft investment research before publication, other than, where necessary, to verify factual information. Certain disclaimers may be included in our research where appropriate, for example for legal reasons. Entext Communications' policy and procedures require investment research to be distributed in an appropriate manner.
Our investment research is published and distributed either in hard copy or on line. No employee may communicate the substance of any investment research, except in accordance with our policy of independence.
April 2016
Content:
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This commentary in no way constitutes financial, investment, tax or any related forms of advice and is one of many possible sources of information for readers. All information contained herein is believed to be accurate, but mistakes can and do happen. Be sure to consult an investment professional before acting on any information that is contained in this blog. Views and opinions expressed as of the date of publication are exclusively those of the author and are subject to change based on market and other conditions. This publication is provided for informational purposes only and should not be used or construed as a recommendation for any security or sector.