WH Ireland Conflicts of Interest Policy

Conflicts of Interest Policy Summary

 

WH Ireland is required by the rules of the FSA to maintain a conflicts of interest policy.   This document is a summary of the procedures that we have in place to manage our conflicts of interest. 

 

WH Ireland provides a range of services to a number of different clients. It is therefore feasible to suggest that circumstances might arise whereby the interest of a client may conflict with the interests of the firm or with those of another client.

WH Ireland is committed to treating its clients fairly and the firm will never knowingly put itself in a position whereby its own interests, or its duty to another party, prevent it from discharging its duty to its clients.

If the firm has a relationship that gives rise to a conflict with the interests of any of its clients, it will not knowingly act for that client without taking reasonable steps to ensure the fair treatment of that client.

Similarly, if the firm has an interest in a transaction that gives rise to a conflict with the interests of any of its clients, it will not knowingly advise the client, or exercise discretion on behalf of that client, without taking reasonable steps to ensure the fair treatment of that client.

 

For these reasons, WH Ireland has formulated a Conflicts of Interest Policy which takes a three stage approach to managing any actual or potential conflicts of interest.   

If the above three elements cannot be guaranteed then we will disclose potential or actual conflicts to clients or we may decline to act for a client where we have disclosed the conflict but still feel it could entail a material risk of damage to a client’s interests:

 

These three elements combine with more specific policies for areas of the business where we have identified that potential conflicts are most likely to occur. These policies are summarised below.

 

 

 

WH Ireland has a Corporate Finance division which advises corporate clients on activities including admission to the various exchanges, raising capital and advising on takeovers.  

 

The Firm also has a stockbroking division which provides investment advice and discretionary dealing facilities to clients wishing to invest in securities.

 

Given the nature of the Firm’s corporate finance activities, it is inevitable that employees within this division will become privy to inside or relevant information that has not been made publicly available. It is vital that this type of information is not passed to individuals employed within the stockbroking division as it may impact on the investment advice being given or the discretionary dealing service being provided to clients. In order to prevent this kind of information passing between the different divisions of the firm, a Chinese Wall arrangement has been established. Corporate Finance sits ‘inside’ the Chinese Wall and all other business areas sit ‘outside’ the Chinese Wall.

 

No information held within the Chinese Wall should pass to other areas of the business. However, on occasion, analysts from the Institutional Research division may be brought ‘over the wall’. For example, to prepare research on a corporate client. In these instances the rules of the Chinese Wall apply and the analyst cannot pass inside or relevant information to other areas of the business. WH Ireland operates an Insiders List Policy

 

 

This section of the policy aims to manage and mitigate conflicts of interest which may arise from the research activities of the firm.

 

The firm’s analysts report to the Head of Research who, in turn, reports to the Chief Executive. This reporting line is independent of the corporate finance, sales and trading functions.

 

Decisions on the content of research are to be taken only by the analyst responsible for the research. Issuers that are the subject of investment research can review that research for factual accuracy provided that the draft research does not contain a recommendation or target price.

 

Decisions on the remuneration of analysts are taken by the Chief Executive in conjunction with the Head of Research. Analyst remuneration is not and will not be linked to specific transactions or to recommendations contained in investment research.

 

Financial analysts must not participate in investment banking activities including corporate finance business and underwriting. Analysts are not involved in the preparation of issuer marketing information.

Investment research will always be published or distributed through the Firm’s usual channels i.e. email, website and hard copy.

Analysts must not intimate the timing or content of research so as to enable a sales person or trader to form a reasonable impression expectation as to its timing or content. Employees (whether analysts or not) must not communicate the substance of any investment research prior to publication.

Analysts and other relevant persons involved in the production of research must not deal on their own account in instruments that are the subject of non-independent research both before it is published and before clients have had time to react to it.

If any employee has knowledge of the timing or content of investment research they must not deal in the financial instruments of the subject of that research until after it has been published and any waiting periods have lapsed.

There may be occasions when an analyst becomes aware of unpublished or confidential price-sensitive/relevant information, very often from the company that the analyst is researching. Until the information has been made public, an analyst should not publish an opinion based on the information and not speak to clients, dealers or salesmen to give an opinion based on the information.

Client Orders and Share Allocation