Conflicts of Interest Policy
The Walker Crips Group and its subsidiary companies (the Group) 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 the Group 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 the Group, our affiliates and agents, and our clients and counterparties or between our clients are:
- Conflicts between the firms' 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.
We also assess our Conflicts of Interest Policies on a regular basis to ensure that all new conflicts are identified and our policies are updated to address any new instances of conflicts arising across WCG.
Order Execution Policy
"We shall take all reasonable steps to obtain the best possible result on behalf of our clients when executing client orders or receiving and transmitting orders for execution."
The paragraphs below set out in detail how we seek to achieve this result for you.
- Under this Order Execution Policy (OEP), we consider the characteristics of the financial instrument, nature of the order, execution venues, liquidity, client category (retail or professional) and any other relevant criteria, and then route the order accordingly.
- For most orders, it will primarily be a case of achieving the best price, although other features of the order, like cost, size, shape, liquidity, speed of execution and other matters, will be considered where relevant.
- For most orders, the choice of execution venue will involve no extra charges, but if there are extra charges, the best overall outcome for you will be the priority.
- This OEP applies to Retail and Professional Clients, as defined in the FCA Handbook.
Order Execution Policy - Execution Venues
- We use sophisticated dealing systems with links to Regulated Markets, such as the London Stock Exchange (LSE) and PLUS Markets and their Member Firms, which include Market Makers and the Retail Service Provider Network (RSP). The use of these systems by our Dealers and Account Executives means that, for the majority of orders, we are able to achieve best execution extremely quickly and at no additional cost.
- For the more complex transactions or securities, in addition to systems, we also have direct telephone communications with counterparties with whom we can execute your orders.
- For non-UK equities, we will use the most efficient venue which, to the best of our knowledge, will provide you with the best overall outcome.
The Execution Venues we use are:
- The London Stock Exchange and its Member Firms
- PLUS Markets and its Member Firms
- Other Recognised Investment Exchanges (Regulated Markets) and their Member Firms
- Systematic Internalisers
- CoFunds plc and individual Unit Trust Managers
- Other venues we are using now, or may in the future, include Euronext.liffe and its Member Firms, BOAT and Chi-X.
We regularly assess the execution venues available and may add or remove venues in accordance with our obligation to provide you with the best possible execution result on a consistent basis.
The FCA rules require you to give express consent before we can execute your order outside a Regulated Market or Multilateral Trading Facility (MTF), i.e. dealing offexchange. We believe that it is in your best interest that we are able to deal in as many markets and use as many Execution Venues as possible, in order that we may give you the best possible outcome.
By consenting to this OEP, you are expressly consenting to Walker Crips Stockbrokers Limited using Execution Venues which are outside a Regulated Market or MTF. Where your express consent is denied, or not received, you may be limiting our ability to provide you with the best possible outcome for your orders.
Order Execution Policy - Limit Orders
- Limit Orders are orders which you give to us with specific parameters, for example, orders with a specific price or specific size which cannot be immediately executed.
- Limit Orders placed on the LSE Order Book will be automatically executed if the limit price which you have set can be achieved. Limit Orders which cannot be placed on the LSE Order Book will only be accepted for execution on a best endeavours basis. Limit Orders will expire at the end of the business day and must be renewed if required on the following day.
- The FCA rules require your unexecuted Limit Orders to be made public unless you expressly instruct us not to make it public. We believe that it is in your best interest that we do not make your Limit Orders public and by consenting to this OEP, you are expressly instructing Walker Crips Stockbrokers Limited not to make such orders public, unless we feel that it is in your best interest to do so.
- Where your express consent is denied, or not received, we will attempt to make your Limit Order details known to the market and if there are additional costs in doing so, we will notify you and this cost will have to be passed on to you.
Treating Customers Fairly Policy
Walker Crips Group is committed to act in the best interest of our customers at all times. "Giving Customers A Fair Deal" underlies the services we provide.
In our dealings with you, we endeavour to:
- treat you fairly and assure you that fair treatment of our customers is embedded in our corporate culture
- place your interests first
- be open and transparent
- communicate clearly
- notify you of our charges in advance
- handle complaints promptly and fairly
- ensure our staff are adequately trained
Treating Customers Fairly Policy - Supporting Policies
These additional policies bolster our commitment to Treating Customers Fairly (TCF):
- Order Execution: to obtain the best possible result on behalf of our clients when executing orders or receiving and transmitting orders for execution.
- Conflicts of Interest: sets out our practices surrounding investment research.
- Data Protection: the proper custody of sensitive client data.
- Personal Account Dealing: the monitoring of personal dealing by Account Executives and staff to reduce the risk of conflict of interest with clients.
- Gifts and Inducements: the observance of protocol on giving or accepting gifts, ensuring there is no conflict with duties owed by the Company.
- Chinese Walls: adequate segregation of duties and functions between business units where segregation is required.
- Client Complaints: responding and dealing with client complaints promptly and fairly.
Treating Customers Fairly Policy - Compliance Arrangements
- Our Compliance Team is experienced and members are suitably qualified.
- The Team manages a robust Compliance Monitoring Programme.
- Checks are carried out regularly to ensure that all Policies, as listed above, are achieved and are being conformed to.
- The Compliance function reports to the Board of Directors, and its findings and reports are submitted within the Board Management Information Pack.