We promise to avoid any conflicts of interest when providing you with the Service.

We provide the Service independently and this includes the following:

  • we will not act for the benefit of other clients against your benefits

  • we treat all the clients on equal circumstances equally

  • we do not hold shares or other interests or have the same managers as the issuer of the financial instruments which we acquire into your Portfolio

  • we do not sell our own financial instruments or act as an agent of both the seller and the buyer of the instruments we acquire into your Portfolio

  • we will transfer any and all monetary inducements received from any third party in connection with clients Portfolio management Service to our relevant clients’ Portfolios proportionally as soon as reasonably possible after receipt of the inducement

  • we shall not retain any inducements received from any third party in relation to your Portfolio management, except minor non-monetary benefits such as:

    • generic or personalised information or documentation relating to an investment service or security;

    • written material from a third party that is commissioned and paid for by an issuer or potential issuer to market a new issuance, or where the third party firm is contractually engaged and paid by the issuer to produce such material on an ongoing basis, provided that the contractual relationship is clearly disclosed in the material and that the material is made available at the same time to any investment firms wishing to receive it or to the general public;

    • participation in conferences, seminars and other training events on the benefits and features of a specific investment service or security;

    • elementary hospitality, such as food and drink offered during a business meeting or a public event (such as conferences, seminars and other training events);

    • other minor non-monetary benefits which are capable of enhancing the quality of service provided to a client and, having regard to the total level of benefits provided by one entity or group of entities of an investment firm, are of a nature and scale that are unlikely to prevent the investment firm from providing services honestly, professionally and in the best interests of the client.

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