Conflicts Policy

The information in this website has been obtained from sources which are believed to be reliable. However, no representation or warranty either express or implied is made nor is responsibility of any kind accepted either as to the accuracy or completeness of any information stated therein or that material facts have not been omitted, or for any loss or damage consequent on action taken in reliance on the information contained herein. In addition, Allenby Capital is not responsible for the accuracy of information contained within sites provided by third parties, which may have links to or from these web pages.

The information on the web pages is subject to change without notice. These pages do not purport to give investment legal, tax or other advice and are not to be relied on in making an investment or other decision. This site should not be regarded as an offer or solicitation, or recommendation to conduct investment business, as defined by the Financial Services and Markets Act 2000, in any jurisdiction other than the United Kingdom. Investors who are resident in or citizens of countries other than the United Kingdom may be subject to local restrictions.

The investments and investment services referred to on this site may not be suitable for all investors and if in doubt visitors should seek independent financial advice, including the tax consequences in respect of any proposed course of action, before making any investment decision. Visitors should also be aware that the value and income of any securities or investments and the price of shares and the income derived from them, which are mentioned on this site, may fall as well as rise. Past performance is not necessarily a guide to future returns.

Policy:

Allenby Capital’s business model does not enable it to hold out its research as being impartial, and it should not be viewed or relied upon as wholly objective.  However, in accordance with FSA’s Statements of Principle, we endeavour at all times to ensure that our research produced is to a high standard, and is fair, clear and not misleading.

Where potential conflicts are recognised, these are fully disclosed and managed so as to minimize any threat to the objectivity of our research. In this context, Allenby Capital pays particularly close attention to the following of FSA’s Statements of Principle:

Principle 1: A firm must conduct its business with integrity.

Principle 2: A firm must conduct its business with due skill, care and diligence

Principle 3: A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems

Principle 5: A firm must observe proper standards of market conduct

Principle 6: A firm must pay due regard to the interests of its customers and treat them fairly.

Principle 7: A firm must pay due regard to the information needs of its clients, and communicate information to them in a way that is clear, fair and not misleading.

Principle 8: A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.

Application:

Responsibility
The Board of Allenby Capital is responsible for ensuring that its systems, controls and procedures are able to identify, manage and control the potential conflicts of interest that may arise.

Taking into account Allenby Capital’s size, scope of business, client base, the nature of the research produced and its intended audience, the Board is confident that it effectively implements its Conflicts Management Policy, and that the potential conflicts of interest inherent in the publication of its research are properly managed in the manner set out below.

Systems And Controls
Conflicts of interest arise in a variety of ways. For example, between the personal interests of the researcher, the company being written about and between clients of Allenby Capital and Allenby Capital itself. Even where there is no actual conflict of interest, it may appear to third parties that a conflict does exist. In order to identify and properly manage potential conflicts of interest, Allenby Capital has detailed internal controls and procedures, including those summarised below:

• Policy of Independence.
• Policy of full disclosure of material interest.
• Detailed Chinese Walls procedures.
• Policies and procedures regarding Treating Customers Fairly.
• Personal Account dealing polices and procedures.
• Rigorous Compliance Monitoring policies and procedures.

Analysts Role
The primary role of Allenby Capital’s Analysts is to provide investment recommendations on companies which they research. The Analysts may also provide recommendations and tips to Sales staff.

The role of the Corporate Finance and Institutional Sales Analysts is to assist in soliciting for and retaining Corporate Finance or Corporate Broking business by participating in pitches to current or prospective clients, and screening of potential corporate finance clients or potential deals as part of the due diligence process.

Involvement Of Analysts In Other Activities
The Corporate Finance and Institutional Sales Analysts may attend road shows, or meetings between investors, investment clients and corporate finance and broking clients, in order to answer questions or provide advice to corporate clients regarding aspects of a proposed transaction.

Supervision And Management Of Analysts
The Analysts are based in the Institutional Sales and Corporate Finance departments, which are physically segregated from each other and the rest of the company. The Analysts report to their respective heads of department who in turn report directly to the Chief Executive Officer.

Means And Timing Of Publication of Research
Research is published in electronic format and also issued in hardcopy.

Internal procedures are designed to ensure that there is no breach of Chinese Walls prior to commencing trading as principal.

Where Allenby Capital is acting on behalf of a company in a corporate capacity, the Analysts will not publish pre-transaction research within an agreed time frame, or such other period as agreed with Compliance, prior to an IPO or Secondary Issue where an Admission Document, prospectus or Information Memorandum is prepared, except where such research is intended solely for distribution to market counterparties, and is appropriate caveated.

Editorial Control
The departmental heads may initiate or request investment research coverage, but the Analysts are solely responsible for the content and recommendations.

Inducements
Allenby Capital has a strict Gifts and Entertainment policy, which, amongst other things, requires that all gifts and invitations be cleared through Compliance, and specifically prohibits Analysts and employees from soliciting or accepting any inducement to provide favourable research.

Issuer Paid Research
Allenby Capital does not issue paid-for research.