Conflicts of Interest

Ravenscroft Limited, Ravenscroft Investment Management Limited and Ravenscroft Cash Management Limited
Conflicts of Interest Policy for Clients

WHAT IS A CONFLICT OF INTEREST

A conflict of interest is a situation where a firm or an individual or firm has an incentive to serve one interest at the expense of another interest. This might mean serving the interest of the firm over that of a client, or serving the interest of one client over other clients.

Conflicts of interest can arise between :

• A firm and its clients (own interest conflict);

• An employee and one of the firm’s clients (own interest conflict); and

• Two or more clients (client conflict).

DISCLOSURE

• We will not recommend a transaction or investment strategy to you or act as a discretionary manager for you unless we have made you aware of the risks involved, including conflicts of interest.

• We will ensure that we provide you with sufficient information to enable you to make an informed decision.

MANAGEMENT AND MITIGATION OF CONFLICTS

• Any potential conflicts must be reported to the Compliance Department.

• The Compliance Department records conflicts on the conflicts of interest register.

• The Compliance Department will ensure that potential conflicts are managed and mitigated in one of the following ways :

o Disclosure;

o Internal rules of confidentiality; or

o Declining to act.

CHINESE WALLS

• The flow of confidential information is restricted by ‘’Chinese Walls’’ which ensures certain physical separation of departments and also computer access to confidential information.

ADDITIONAL INFORMATION

• Scheme Particulars include a statement showing the interests of the various parties to the fund.

• Material conflicts of interest are disclosed to enable you to make an informed decision on the merits of investing in the authorised scheme.

• The Compliance Department also maintains a Gift and Entertainment register.

GIFTS AND INDUCEMENTS

All gifts, entertainment or other non-monetary benefits provided or received and handled in accordance with the Gifts and Entertainment policy. This enables us to ensure that no employee gives or receives a gift or other benefit which will significantly conflict with their duties.

UK RESIDENTS

• Ravenscroft Limited acts as an Appointed Representative of A Vartan Limited, which is regulated by the Financial Conduct Authority.

• Ravenscroft Limited and Ravenscroft Investment Management Limited Financial Advisers are appropriately authorised by the FCA to provide investment advice.

• A Vartan has its own Conflicts of Interest Procedure.