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Our policies

Management of conflicts of interest

What are conflicts of interest?

Legally, a conflict of interest is where a firm puts itself in a position where its own interests conflict with the duty owed to its clients. However, the FSA uses the term to cover all conflicts inherent in and arising from performance of fiduciary duties. Our policy therefore covers:

  • Conflicts of interest – where our interests conflict with our clients’
  • Conflicts of duty – where our duties to one client conflict with our duty to another
  • Duty of confidentiality – which we owe to our clients

FSA Requirements

FSA Principle 8 – ‘A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another customer’. The SYSC Rules also require us to have adequate systems and controls to manage risks. The new MiFI D Rules require us to formally document this. It is not sufficient that we rely solely on disclosure of conflicts in customer agreements etc.

Conflicts of Interest Policy

In accordance with our regulatory requirements it is our policy to identify all potential material conflicts inherent in our business and have adequate systems and controls to avoid or mitigate their impact on customers, including disclosure to customers as appropriate.

It is incumbent on our Board to consider and all our staff to escalate any matter that they consider may conflict with our policy. The Risk Management Committee regularly reviews any issues raised in this manner or by virtue of any other business development.

Conflicts Inventory

Potential Conflicts

Management Arrangements

Dealing with customers

1. Promotional material
That financial promotions including non-independent investment research promotions, are unfair, unclear and/or misleading

All such material is approved by individuals assessed as competent and formally apportioned responsibility and is independently signed off by a qualified person other than the preparer

2. Third party marketers
That inappropriately licensed or disreputable firms with undisclosed remuneration arrangements are involved in attracting new clients

Rowan Dartington has no third party marketers

3. Preferential arrangements
That arrangements are established providing advantages for certain investors that disadvantage others

Rowan Dartington has not entered into any arrangements with particular clients that could disadvantage any other clients and ensures all research issued is distributed to clients fairly

4. Interests in issuers
That recommendations are made to clients where we have a material or other commercial interests and the objectivity of the recommendation is compromised

Rowan Dartington does not make research recommendations on the securities of issuers where it has had material or other commercial interests in the previous 12 months. Where it does, it will disclose such information to clients on a case-by-case basis. Materials issued to promote the shares of issuers with whom we have a relationship are clearly marked as promotional material

5. Portfolios
May be managed on behalf of persons who in turn introduce other clients.

All portfolios are managed on a commercial arms-length basis. Our relationships with introducers are documented and transparent.

Execution of Transactions

1. Suitability
That suitability requirements are not adhered to and that excessive transactions are undertaken

Rowan Dartington establishes its clients’ understanding of risk, their ability to withstand losses and their investment objectives prior to commencement of business and on an ongoing basis. Rowan Dartington’s internal procedures outline how these factors should be taken into account and are independently monitored

2. Confidentiality
That commercial or private information is not sufficiently protected

The standards relating to the imperative of client and commercial confidentiality are clearly laid out in our internal procedures

3. Appropriateness
That the appropriateness of relevant transactions is not established and our interests as a firm are put before those of clients

During the client classification process Rowan Dartington establishes clients’ understanding of risk and endeavours to highlight where clients’ instructions appear uncorrelated to this understanding

4. Activity Levels
That client transaction activity levels are either less or more than the level appropriate to meet its investment objectives

Activity levels are reviewed by business and risk management on a regular basis to identify patterns of activity outside normal parameters

5. Transaction Order Handling
That customer orders are not handled fairly in relation to other customers or the firm

Transactions are either handled in accordance with customers specific instructions or in accordance with procedures requiring fair treatment for all customers and are independently monitored

6. Best Execution
That transaction quality or counterpart relationships are negligently managed

Rowan Dartington has established a Best Execution Policy which is communicated to all staff and clients

7. Affiliates
That business is routed through affiliates in inordinate amounts or on unfair terms

Rowan Dartington only executes transactions through affiliates where it considers this to be in the clients best interests

8. Bundling
That services are provided to clients in exchange for transaction commission that constitute an inducement i.e. they do not comprise either best execution or research

Commissions are only charged for achieving best execution and for research. Rowan Dartington reports to all its clients the split between these services.

Other services provided to clients by Rowan Dartington are charged discretely

9. Market Abuse
That we undertake activities that constitute market abuse, including market timing, that compromise the integrity of our investment process or product

Rowan Dartington has in place practices and policies to ensure awareness amongst all staff of its, and their, obligations and actively trains its staff to reinforce and administer its Market Abuse prevention regime

10. Trade Errors
That the costs of client trading errors are inappropriately picked up

Rowan Dartington’s trade error resolution policy is to make good any errors arising from its own errors. Rowan Dartington does not pick up the costs of errors made by clients

11. Principal Trading
That the interests of the firm are put before those of clients e.g. front running

Rowan Dartington makes clear where it, or an affiliate, may have an interest in certain securities and its internal procedures are designed to ensure customers’ interests are given the highest priority

12. PA Dealing
That the interests of staff are put before those of clients e.g. front running

The standards expected of staff in relation to their PA deals are clearly laid out and communicated via internal procedures. All deals must be independently approved prior to execution and retrospectively reviewed

Infrastructural Arrangements

1. Firm remuneration
That the firms remuneration arrangements are undisclosed

Rowan Dartington’s client agreements set out the basis of our remuneration in full

2. Staff remuneration
That staff are remunerated to act in a manner that conflicts with clients objectives

The long-term interests of our staff are designed to correlate with the interests and financial wellbeing of our clients and their activities are overseen and monitored

3. Recruitment and development
That inappropriate staff are hired or that staff are not adequately developed

Rowan Dartington aims to hire experienced professionals and has in place a rigorous referencing and recruitment process. This is complemented with a formal appraisal and personal development programme

4. Key Man Risk
That reasonable arrangements to minimise the likelihood of losing key staff are not established

Key individuals are identified on an ongoing basis and succession plans and development arrangements are adopted as appropriate

5. Insufficient Resources
That insufficient financial or human resources are in place to ensure delivery of contractual obligations and that sufficient segregation of duties is maintained to manage risk

Rowan Dartington carries excess capital in accordance with its regulatory requirements. During its annual budgeting processes it has full regard to the need to maintain adequate resources to fulfil its contractual obligations and the maintenance of segregation of duties in key areas

6. Gifts and entertainment (Inducements)
That the integrity of either staff or suppliers is compromised by excessive largess

The standards expected and the internal approval and disclosure requirements with regard to inducements are clearly set out in our internal procedures

7. Business Continuity
That inadequate arrangements are established to ensure continuance of the business in the event of a disaster

Rowan Dartington regularly tests the adequacy of key components of its plans