CONFLICTS OF INTEREST

The Walker Crips Group (WCG) provides diversified financial services to a broad range of clients from a number of locations within the United Kingdom. These services include stockbroking, fund management, corporate finance, IFA services, custody and research and they are delivered to clients that include individuals, private companies, and trusts. Across the group, these services are provided by employees, account executives, agents and affiliates. Given the range of services and the circumstances in which they are delivered, the aims and interests of our clients and the parties within WCG may create the possibility of conflicts of interests that cannot be avoided.

However, our employees and Account Executives are required to comply with a policy of independence and disregard any such interest when making recommendations to you.

Examples of conflicts that may arise between WCG, our affiliates and agents, and our clients and counterparties or between our clients are:

• Conflicts between the firm’s own proprietary position and those of our clients
• Remuneration based upon dealing volumes and/or portfolio performance
• Dealing in the shares of an issuer to whom we provided corporate finance services in the previous twelve months
• Dealing in the shares of a collective investment scheme e.g. a unit trust, to which we are an adviser or manager

We take all reasonable steps to identify conflicts of interest between you and WCG and its representatives and with any other client, in the course of providing services to you. Our conflicts of interest policy defines the steps that we take to identify, prevent, manage and/or disclose conflicts of interest when providing various investment and other services. These actions include the following:

• Training our employees
• Notifying the Compliance Department of employees dealing in securities who are potentially exposed to conflicts of interest
• Imposing restrictions on dealing in securities of a company for whom we are providing Corporate Finance advice
• Reviewing transactions in securities where we have access to sensitive information
• Requiring the disclosure to Compliance of any gifts or other inducements received by employees and Account Executives
We also assess our conflicts of interest policy on a regular basis to ensure that all new conflicts are identified and our policies updated to address any new instances of conflicts arising across WCG.