Investment Research Policy (COBS 12)
This Policy is required where investment research (IR) would be considered to be impartial by recipients where there is a conflict of interest to be managed. This policy explains how Wills & Co (W&C) intends to manage those conflicts.
At times W&C may not be able to present its research as impartial in which case the particular research document will be marked as such. However all research will comply with the FSA requirements of being clear fair and not misleading.
All impartial research will be produced in accordance with the following:
Potential conflicts - if the IR is in respect of a company where it is known that Group or an associated company (CF) may have shares or may act or have acted for the Company, or where Wills & Co are considering purchasing shares and acting as principal. There will normally be no conflict where the IR is in respect of a main market share.
Management of conflict above - Chinese walls are in place to ensure the investment analyst (IA) is not aware of any CF information about the company. E.g. Wills & Co working in London offices employs the IA; CF offices are in Horsham; IA's IR will be based on information in the public domain that is verifiable.
IA is not involved in any decision as to whether Wills & Co acts as principal for a particular share and is unaware of any discussions. The directors of Wills & Co make that decision.
This policy will apply to Company Reports and Newsletters. It will also include any other marketing material where an analysis of factors is included. Any material included in the Newsletters in respect of companies where we or an associate may have or has had a material interest will not include any expression of opinion or analysis or if it does include any such expression of opinion or analysis it will clearly state that the research cannot be regarded as objective or impartial.
This policy will not apply to the Morning Briefings which will only contain factual information with no expression of opinion or analysis of company performance. Nor will it apply to research for internal use only. This internal research will not subsequently be published.
IA will report to the directors.
Decisions on subject matter of IR will be agreed by at least 2 directors.
Remuneration of IA will be agreed by the directors and will not be linked to specific transactions or structured to be an incentive although it may be linked to the general profits of the firm.
IA may provide information and advice to firm's investment clients; assist firm to research corporate finance business opportunities; provide ideas to sales or trading staff but must not be involved in any activity that would appear to be inconsistent with providing an impartial assessment of the value or prospects of the relevant investments e.g. used in a marketing capacity to solicit corporate finance business; appear in road shows relating to issuers etc.
IA or other employees must not offer solicit give or accept inducements to provide favourable IR. An annual declaration is required to confirm no inducements have been offered or received.
Only the IA can approve the content of the IR before publication. Someone other than the IA may view IR only for verification of factual information.
The marketing department only may distribute IR after approval from compliance.
A copy of our full Conflicts of Interest Policy is available upon request.