Beaufort Securities Ltd is required by the Markets in Financial Instruments Directive (MiFID), to provide you with a summary of our arrangements to manage our Conflicts of Interest.
Beaufort Securities undertakes a number of business activities which includes advising and dealing in investments for Retail Customers and research. A number of potential conflicts of interest could arise within and between these various activities.
We are therefore required to:
When identifying potential conflicts of interest, Beaufort Securities will take into account whether the firm or an employee:
Beaufort Securities maintains a number of policies and procedures, which includes a documented policy of independence, which applies whenever its employees provide advice to any of our customers or recommends a transaction. This requires employees to disregard any interest in the transaction that they or Beaufort Securities may have, in order to ensure that our clients are given suitable advice. We also maintain physical separation between various departments.
Where it is not practical to effectively manage such conflicts we ensure that they are properly disclosed to customers, and we will decline to act for customers should it be necessary.
These are the arrangements we have in place to restrict access to information held in one part of the business from employees in other departments. Our Chinese Wall Procedures sets out in detail the restrictions that are in place to restrict, control and manage the flow of information between the Analysts, Brokers, Settlements function and Finance.
This includes restrictions on access to the data held within different departments. The procedures dictate that those staff who are required to be involved in any transaction will be privy to information or ‘brought over the Chinese Wall’. All staff are prohibited from disclosing information except as detailed in the procedures.
Personal Account Dealing by Beaufort Securities personnel must be in strict compliance with our policies and procedures to ensure adherence with all relevant regulation and legislation, both for the benefit of clients and the protection of employees. The procedures are to ensure that employees’ interests do not conflict with those of our clients and adherence with these is strictly monitored.
Beaufort Securities’ remuneration policies are designed to reflect employees experience and performance, balanced with the requirement to ensure that their remuneration does not conflict with their obligations to our clients. Where employees’ remuneration reflects an element of commission received for transactions undertaken for clients, procedures are in place to monitor the suitability of their recommendations.
The giving or receiving gifts or other inducements may compromise or conflict with the recipient’s obligations to his clients. Therefore employees are required to comply with our strict policy regarding the reporting and approval of all gifts and hospitality.
Employees are required to notify the firm of any outside interest. Any disclosed outside interests will be reviewed by the Head of Compliance and if necessary reported to the CEO who will consider the potential for conflicts of interest before permitting the continuance of any such outside interest.
All polices and procedures for identification and management of conflicts of interest are, as a minimum, subject to annual review and any significant issues will be reported to the Executive Management Committee and to the Board as necessary.