Conflicts Policy Summary
Tilman Brewin Dolphin is committed to operating in the best interests of our clients and to identifying, monitoring and managing all actual and potential conflicts of interest that can arise between us and our clients. We will not knowingly provide a service to you where we are aware of a conflict without taking reasonable steps to ensure fair treatment. Such steps will be in line with the Company’s policy on conflicts of interest, a full version of which is available to you on request.
In performing our duties, we will use all reasonable endeavours to allocate any investment opportunities fairly between our clients. We may, however, recommend investments to other clients which may also be suitable for your portfolio.
You should also note that in executing transactions pursuant to our instructions on your behalf, we, the broker or financial institution who we are dealing with, or other parties connected with us, may have an interest and/or arrangement that is material in relation to the transaction being executed. Whereas the Company is not permitted to trade on its own account, “other connected parties” may include other clients of the Company.
Examples of such an interest / arrangement may be as follows:
(a) receiving fees or commission for placing business with a company with which your order is placed;
(b) being an associated company of the issuer of the investment;
(c) involvement in the sponsoring or underwriting of a new issue concerning an investment that you hold or are buying or selling;
(d) the broker or financial institution dealing as principal for its own account by selling the investment concerned to you or buying it from you or matching that transaction with that of another customer by acting on that customer’s behalf as well as yours.
It is usual for employees of financial institutions such as ours to undertake deals on their own behalf. We recognise that this can create a conflict with the duties owed to our clients. Therefore all of our employees and connected parties are required to comply with our Personal Account Dealing Policy which, amongst other matters, prohibits dealing ahead of client orders, and dealing in an investment where they know, or should know, that a written recommendation, or a piece of research or analysis, in respect of that investment or any related investment is due to be published.
On occasion our employees may give gifts or receive them from clients, companies or other institutions in recognition of services provided. We take care through our Gifts Policy to ensure that these gifts are not excessive and do not create an obligation or debt.
Tilman Brewin Dolphin may receive remuneration from third parties in respect of transactions entered into on your behalf. Details of such remuneration will be included on contract notes or with the periodic valuations sent to you in respect of transactions entered into. We have processes in place to ensure that any fees, commissions or non-monetary benefits provided by third parties do not impair our duty to act in the best interests of our clients.
Brewin Dolphin Holdings Shares
Tilman Brewin Dolphin is a subsidiary company of Brewin Dolphin Holdings plc (“BDH”), which is listed on the London Stock Exchange. Due to the conflict of interest that would exist, employees of the Company are unable to provide investment advice in relation to BDH shares and will not purchase them for a portfolio on a discretionary basis. The investment services we are able to provide in respect of BDH shares are limited to buying or selling them on an execution only basis.