MiFID - Summary Conflicts of Interest Policy

 

 

APPENDIX B
ALTIUM CAPITAL LIMITED
SUMMARY INFORMATION ON CONFLICTS OF INTEREST POLICY

This document summarises a policy which Altium Capital Limited ("Altium") has put in place under the Markets in Financial Instruments Directive ("MiFID") to meet our obligations to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage conflicts of interest. This document provides key information designed to enable you to understand the measures we may take to safeguard your interests.

Conflicts of Interest Policy
Our Conflicts of Interest Policy sets out how we will:

- identify circumstances which may give rise to conflicts of interest entailing a material risk of damage to your interests;
- establish appropriate mechanisms and systems to manage those conflicts; and
- maintain systems designed to prevent actual damage to your interests through any identified conflicts.

What is a "conflict of interest"?
A conflict of interest under MiFID is a conflict that arises, in any area of our business, in the course of providing you with a service which may benefit us (or another client for whom we are acting) whilst potentially materially damaging your interests where we owe a duty to you. There may be a conflict where we (or anyone connected to us including an affiliate):

- are likely to make a financial gain (or avoid a loss) at your expense;
- are interested in the outcome of the service provided to you where our interests are distinct from your interests;
- have a financial or other incentive to favour the interests of one client over another;
- carry on the same business as you; or
- receive money, goods or services from a third party in relation to services provided to you other than standard fees or commissions.

Identification of conflicts of interest
In accordance with regulatory requirements, we have taken reasonable steps to identify conflicts of interest that exist, or may exist, between Altium Capital Limited and its clients or between one client and another or between Altium Capital Limited and other members of the Arrowclaim Group of which Altium Capital is a part. For the purposes of identifying conflicts of interest clients will include past clients where a fiduciary or other duty remains in place.

The Arrowclaim Group, as well as Altium Capital Limited, consists of a number of corporate finance offices in Europe. Given the nature of business undertaken by Altium Capital and the European offices we do not believe that a conflict should arise, however any issues arising will be discussed at the regular senior management calls.

We have carried out an exercise to identify where potential conflicts of interest may exist in our business and have established measures we consider appropriate to monitor, manage and control the potential impact of those conflicts. The potential conflicts of interest identified include:

- dealing as principal for our or its own account by selling the investment concerned to you or buying it from you;

- matching your transaction with that of another customer by acting on his behalf as well as yours;

- buying investments where we are or a connected company is involved in a new issue, rights issue, takeover or similar transaction concerning the investment or a related investment;

- holding a position in the investment or a related investment; or

- executing or arranging for transactions on behalf of or in the name of any company involved in the transaction.

- We may issue research in relation to the securities in which you are trading however our research reports are made available to all recipients simultaneously and, under no circumstances are Altium�fs internal departments given any priority, for example the sales teams and market-makers.

- Altium Capital may provide corporate finance services to a company in relation to whose securities you are entering into a transaction, however, the flow of such information is restricted by a Chinese Wall which ensures physical separation of departments, undue circulation of confidential information and prevents the use of confidential information in ways that may damage market integrity or client interests.

- Given the size of Altium Capital the Chief Executive Officer of the business work in the corporate finance division and therefore the Head of Securities will report to this individual. However, day-to-day management of securities is left with senior management of the division. 

- In carrying out Altium�fs business, employees may learn confidential or proprietary information about its clients, prospective clients or other third parties. However, our employees are required to comply with a policy of independence and disregard any such interest, relationship or arrangement when dealing for you to ensure that you are dealt with in a fair way regardless of any conflict that may arise. 

Policies and procedures
We have well established internal policies and procedures designed to manage potential conflicts of interest. These policies and procedures, which are designed to ensure the required level of independence, are the subject of ongoing monitoring and review processes and may where relevant, include, but are not limited to the following:

Chinese Walls
Chinese Walls are information barriers operated by Altium that are designed to restrict information flows between different areas likely to generate a conflict of interest. Chinese Walls are there to allow Altium to carry out work on behalf of a client without being influenced by other information held within Altium that may give rise to a conflict of interest.

Information barriers
Altium operates a �gNeed to Know�h approach and complies with all applicable laws in respect of the handling of confidential information that it receives from its clients. Access to confidential information is restricted to those who have a proper requirement for the information consistent with the legitimate interest of the client or Altium.

Disclosure
In certain circumstances, where a conflict of interest remains, we will seek the relevant client�fs consent to allow us to act ensuring that the client has enough information to enable it to make an informed decision.

Declining to Act
Where we consider we are not able to manage the conflict of interest in any other way, we may decline to act for you.

Further information
If you would like further detail regarding our Conflicts of Interest Policy, please contact the Compliance Officer at Altium.