Conflicts of Interest

In relation to

Ravenscroft (CI) Limited, Ravenscroft Investment Management Limited and Ravenscroft Cash Management Limited

WHAT IS A CONFLICT OF INTEREST

A conflict of interest is a situation which could arise where Ravenscroft has an incentive to serve one interest at the expense of another interest. This might result in serving the interest of the firm or one of its employees over that of a client or serving the interest of one client over another client.

Conflicts of interest can arise between:

  • Ravenscroft and its clients (own interest conflict);

  • a Ravenscroft employee and its clients (own interest conflict); and

  • two clients (client conflict).

IDENTIFYING CONFLICTS OF INTEREST

Ravenscroft maintains various policies and procedures, including this policy, to identify and mitigate conflicts of interest. We take all appropriate steps to identify conflicts of interest between our firm, including staff, and our clients, and between one client and another client, which arise or may arise in the course of providing our services.

Our employees are required to act in the best interests of each individual client and not to have regard to the interests of one client over the interests of any other. We expect our employees to recognise and escalate any actual or potential conflicts of interest that they come across. Equally, employees must not put themselves in a position in which their personal interests, financial or otherwise, might influence or give the appearance of influencing any action taken, judgement made, or advice given on behalf of Ravenscroft.

All employees are made aware of Ravenscroft’s escalation procedure for ensuring senior management consideration of material conflicts issues; this includes a Whistleblowing Policy.

MANAGEMENT AND MITIGATION OF CONFLICTS

Employees are required to report potential conflicts to the Compliance team. If Ravenscroft is unable to avoid a conflict of interest arising, we will ensure clients are treated fairly using the controls set out below.

Independence Policy

Where the firm and/or its employees are carrying on business activities, Ravenscroft must disregard any material interest which it or any of its subsidiaries or affiliates may have when making recommendations or arranging transactions with or for its clients. This ensures that in providing services to clients, our employees act independently of any interest that may conflict with the duties owed to different clients or between Ravenscroft and its clients.

Though not exhaustive, all employees must disregard any of the following interests and must not allow the existence of such interests to influence them when dealing with clients or potential clients:

  1. any personal interests which they or members of their family or any connected persons may have. Where appropriate, a client should be advised of such an interest, notwithstanding this policy;

  2. any existing, proposed or prospective business relationship between Ravenscroft or another member of the Group and any third party;

  3. any agreement or transaction which has been, will or may be, entered into by Ravenscroft or another member of the Group; or

  4. the holding by way of interest or other position of Ravenscroft or another member of the Group in any securities issued by the client or any third party.

Ravenscroft and its employees are required at all times to consider the need to act independently of any conflict.

Information Barriers

Often referred to as ‘ethical walls’, information barriers are a system (including rules, procedures, physical segregation and organisational arrangements) designed to ensure that certain information produced or acquired by employees in one part of Ravenscroft’s business is not shared with employees in another part of the Ravenscroft Group.

Ravenscroft operates an information barrier between its Corporate Finance team and the rest of the Group, so as to mitigate the risk of conflicting interests and control the flow of confidential information.

Personal Account Dealing

Ravenscroft employees who trade on their own or connected person accounts may have a conflict with their obligations to clients, such as having a material interest in respect of discretionary transactions or investment advice provided. We operate a Personal Account Dealing Policy and Procedure to review and monitor employee personal dealing.

Outside Business Interests

Employees must not engage in any practice or pursue any private interests that may conflict with the interests of Ravenscroft or its clients. Employees are required to disclose their outside interests to the Compliance team, who will determine whether there is a conflict of interest and, where necessary, provide approval of an appointment.

Inducements/Gifts and Entertainment

Ravenscroft and its employees are not permitted to solicit or accept gifts, entertainment or other inducement which could conflict with our obligations to its clients, nor offer or give inducements which are likely to conflict significantly with any duties of the recipient (or the recipient’s employer) owed to a client in connection with investment business.

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

Reporting Lines and Remuneration

Ravenscroft has in place separate supervision, functional or physical segregation arrangements designed to prevent the simultaneous involvement of an employee in separate services or activities where such involvement may impair the proper management of conflicts. Remuneration, commission and bonus structures are designed so as not to create an incentive for an employee to act contrary to a client’s best interests.

Personal Relationships

Ravenscroft’s employees must ensure personal relationships do not give rise to any additional conflicts within the business. Personal relationships include relationships between employees, as well as family members of employees who are client of the firm.

Suitability of investments

Ravenscroft will not recommend a transaction or investment strategy to or act as a discretionary manager for clients unless we have disclosed the risks involved, including conflicts of interest.

We will ensure that we provide sufficient information to enable clients to make informed decisions.

DISCLOSURE AND DECLINING TO ACT

Where Ravenscroft’s organisational and administrative arrangements are unable to prevent or manage conflicts sufficiently to ensure, with reasonable confidence, that risks of damage to client interests will be prevented, the general nature and sources of any conflict of interest will be clearly disclosed to the client before undertaking business on their behalf. We may decide to decline to act where there is a residual risk of damage to the interests of any client.

UK RESIDENTS

Ravenscroft (CI) Limited acts as an Appointed Representative of Ravenscroft Investments (UK) Limited, which is regulated and authorised by the Financial Conduct Authority.

Ravenscroft (CI) Limited and Ravenscroft Investment Management Limited have a select number of Financial Advisers who are appropriately authorised by the FCA to provide investment advice.

Ravenscroft Investments (UK) Limited has its own Conflicts of Interest Policy.