In accordance with regulatory requirements, we have taken
reasonable steps to identify conflicts of interest that exist, or
may exist, between Cenkos Securities Plc ("Cenkos") and its clients
or between the services Cenkos provides to one client and
We have also reviewed the organisational and administrative
arrangements in place to manage such conflicts and are of the view
that, save for the matters outlined below, they are sufficient to
ensure with reasonable confidence, that risk of damage to clients'
interests will be prevented.
From our Conflicts of Interest Policy, we have identified the
following areas where we are not certain that we can manage the
conflict (or potential conflicts) fully and thus we hereby advise
our clients of this fact.
The general nature and/or source of these conflicts are:
- dealing as principal for our or its own account by selling the
investment concerned to you or buying it from you;
- matching your transaction with that of another customer by
acting on his behalf as well as yours;
- buying investments where we are or a connected company is
involved in a new issue, rights issue, takeover or similar
transaction concerning the investment or a related investment;
- holding a position in the investment or a related investment;
- executing or arranging for transactions on behalf of or in the
name of any company involved in the transaction.
- Cenkos produces research which is non-independent and is
clearly labelled as a marketing communication. It is not
prepared in accordance with the legal requirements to promote
the independence of research. In particular Cenkos' analysts
may participate in pitches for corporate finance business, be
involved in road shows or issuer marketing and publish research and
other information to its institutional buy-side clients in relation
to companies where Cenkos has, or seeks to have, a corporate
- Cenkos'research is not subject to any prohibition on dealing
ahead of its dissemination. However, Cenkos takes steps
designed to ensure its research is disseminated simultaneously to
its clients and internally.
- In carrying out Cenkos's business, employees may learn
confidential or proprietary information about its clients, their
underlying clients, prospective clients and underlying clients or
other third parties. However, our employees are required to comply
with a policy of independence and disregard any such interest,
relationship or arrangement when dealing for you to ensure that you
are dealt with in a fair way regardless of any conflict that may
This conflicts disclosure is not intended to, and does not,
create rights or duties that would not exist if the disclosure had
not been made available, nor does it form part of any contract
between Cenkos Securities Plc and any Client.