Conflicts of Interest Policy

Raymond James Investment Services Limited (RJIS) recognises that, in the course of its business, there are circumstances which may give rise to a conflict of interest and result in material damage to our clients. RJIS is required to manage those conflicts of interest wherever they arise.

This page identifies those circumstances and sets out the specific measures that RJIS employs to manage these actual or potential conflicts of interest.

Material interests and potential conflicts

1. Where any firm acts for more than one client, there is the possibility of a conflict of interest. Conflicts may also exist between the interests of a firm, including Persons connected with it, and the interests of clients. Investment firms are required by the Rules of the FCA to establish, implement and maintain an effective conflicts of interest policy appropriate to the size and organisation of the firm and the nature, scale and complexity of its business, in line with the FCA Principles for Business and in particular Principle 8: “A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client”.
2. Our firm maintains a Conflicts Management Policy (the Policy) that identifies, with reference to our services, the circumstances that constitute or may give rise to a conflict of interest entailing a risk of damage to the interests of one or more clients. We take all appropriate steps to identify conflicts of interest between our firm, including managers and staff, and our clients, and between one client and another client, which arise or may arise in the course of providing our services.
3. Our staff are required to act in the best interests of each individual client and not to have regard to the interests of one client over the interests of any other. They are required to comply with a policy of independence and disregard any interest other than your own when making recommendations to you or carrying out transactions on your behalf. We maintain and operate effective organisational and administrative arrangements in order to take all appropriate steps to prevent or manage such conflicts from adversely affecting the interest of clients. In respect of the business that we conduct with you, the procedures we follow and measures we adopt include at least those items in the following list that are necessary for us to ensure the requisite degree of independence:a. effective procedures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients;
   b. the separate supervision of persons whose principal functions involve carrying out activities, or providing services to, clients whose interests may conflict, or whose interests may conflict with the interests of our firm;
   c. measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out services and activities, and to prevent or control the simultaneous or sequential involvement of relevant persons in separate services or activities where such involvement may impair the proper management of conflicts of interest; and
   d. a policy of the removal of any direct link between the remuneration of persons principally engaged in one activity and the remuneration of, or revenues generated by, different persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities.
4. Where conflicts of interest are so great that they cannot appropriately be prevented or managed by a combination of these and/or other steps in such a way as to ensure fair treatment for a client and to ensure that client interests will not be damaged, we would be required to disclose the general nature and/or source of the conflict. However, disclosure to clients is a measure of last resort and is not a form of managing that conflict of interest. We are required to take appropriate steps to prevent or manage conflicts of interest beforehand and rely on disclosure of a conflict only when our administrative and organisational arrangements have failed in this regard.

As a result of our organisational and administrative arrangements, we have no general conflicts of interest that are not appropriately prevented or managed, and that we would be obliged to disclose in accordance with the FCA Rules. However, for your information, we set out below the details of certain specific areas of conflict and controls

Staff personal dealing

Staff personal interests in holdings of securities, or in dealing in securities, may conflict with their obligations to clients. The firm has detailed policies, procedures and monitoring arrangements in place to review staff personal account dealing and to restrict it in certain circumstances. Staff are required to treat all clients fairly and undertake investment activity in an appropriate fashion.

RJIS’ wealth managers may hold positions in securities that they are recommending to their clients. RJIS has a policy that controls personal account transactions undertaken by wealth managers and their employees, and head office staff. This policy ensures that personal account transactions do not disadvantage, or conflict with the interests of, RJIS’ clients.

Gifts and inducements

As a matter of policy, RJIS and its staff do not solicit or accept inducements that could conflict with the firm’s obligations to its clients, nor offer nor give inducements that could conflict with the recipient’s obligations to its own clients.

Gifts, corporate hospitality, and similar benefits could fall within this category and the firm has a Policy detailing the requirements around the giving and receiving of gifts and we maintain a Gifts & Entertainment Policy and Procedure detailing the requirements around the giving and receiving of gifts and hospitality.

Client Categorisation

A potential conflict exists in that it may be to our benefit to categorise clients as Professional rather than Retail Clients, thereby reducing the level of investor protection enjoyed by clients. Policies and procedures are in place to ensure that clients are only categorised as Professional when this is fully justified in all the circumstances and permitted by the FCA Rules on client categorisation. Otherwise, clients are categorised as Retail Clients.

Client Orders

When we recommend a transaction to you or enter into a transaction for you, conflicts may exist where:

a. we carry out your Order by matching it with that of another client;
b. we carry out comparable Orders given simultaneously by different clients;
c. we allocate Investments, where you are a discretionary managed client or your Orders are aggregated with those of other clients but full allocations are not possible; or
d. a Person connected with us is dealing as principal for their own account by selling the Investment concerned to you or buying it from you. In making any recommendation or in carrying out any transaction for you, we are not required to disclose that the other party to the transaction may be ourselves, a company connected with us, or another client of ours or of another company. Our firm maintains Client Order Handling procedures that are designed to ensure the fair treatment of clients in such instances.

RJIS’ dealing procedures ensure that orders are either passed through our dealing desk, which is independent of RJIS’ wealth managers, or they are entered onto an automated trading platform, which will ensure that the most advantageous outcome is obtained, regardless of the identity of the client.

RJIS maintains Execution and Client Order Handling policies that are designed to ensure the clients obtain the best outcomes. RJIS does not hold principal positions in securities, or deal on its own account.

External Business Interests

Staff may not accept any employment or business interest outside the group without prior approval from management.

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