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 FCA’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 FCA’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 produce company research which provides the analyst’s view on the company’s performance, the company’s prospects and it may also contain valuation analysis.

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.

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.

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 issue paid-for research.

Business Structure

Allenby Capital is a corporate finance firm, AIM Nominated Adviser and broker.
Clients are retail (corporate finance advice only), professional and eligible counterparties.
Allenby Capital seeks to mitigate risk by implementing sound systems & controls and with good corporate governance.

Statement of Risk Appetite

The Company’s Board determines its risk appetite, reviews its risk profile against that appetite and documents this on an annual basis as part of the ICARA process. Furthermore, the Board of Allenby Capital maintains and reviews its risk assessment on an ongoing basis to ensure that risk mitigation protocols are implemented.

The Company’s overall risk appetite can be expressed as low for its ongoing and mature business processes. The majority of the Company’s clients are advisory and as such, its risk appetite in terms of balance sheet is essentially low. Allenby is only prepared to accept low risk in relation to its clients, reputation and capital requirements.

Accordingly Allenby Capital has been assessed as having a low risk profile overall.

Identification of Risks – material harms

The Board’s focus on preparing its ICARA’s is on Allenby Capital’s business model and its activities. The Board’s approach is to ensure that the Company has protocols and processes that are in place to assess the risk of and estimate the potential financial impact of harm:

• to clients;
• to markets; and
• to the financial stability and reputation of Allenby Capital itself, including potential changes in the book value of assets and losses from potential failure of counterparties.

The Board also considers Environmental, Social and Governance related risks

Allenby Capital has assessed, documented and quantified potential risks arising from its business model and activities and has reflected this in the Firm’s ICARA.

Satisfaction of capital requirements
The Company’s approach to assessing the adequacy of its internal capital to support its current and future activities is documented in its ICARA, which includes an assessment of the key risks to which the Company is exposed and details the internal controls which exist to mitigate those risks. This is then stress tested against the various scenarios.

Under the Investment Firm Prudential Regime, the ICARA process has not identified that additional capital is required to be held over and above the Capital Requirement set out above and hence the capital resources denoted above are considered adequate to continue to finance the Company over the next year.

Remuneration policy
Allenby Capital has an established a Remuneration Committee comprising the Chairman and the Non-Executive Director, which meets regularly to consider remuneration policy and human resources issues.

Allenby Capital aims to pay employees bonuses which are in general based on a cautious proportion of profits to ensure that such payments are affordable and that suitable levels of capital resources are maintained by the Company. Allenby Capital is subject to the Financial Conduct Authority’s Remuneration Code and is categorised as an SNI firm for the purposes of that code.

Analysts’ remuneration is determined solely by the directors of Allenby Capital and is not tied to investment banking transactions performed by Allenby Capital.

Aggregate quantitative information on remuneration
Allenby Capital operates as one business unit and hence the disclosures below relate to the company as a whole.
 Total remuneration in respect of the year ended 31st December 2022 – £3.391 million

Number of employees – 31
Fixed Remuneration – £2.475 million

Variable Remuneration – £0.916 million