Conflicts Policy

Summary of Conflicts of interest policy

In accordance with MiFID requirements, SVS Securities plc is required to provide you with a summary of our Conflicts of Interest policy.

According to Principle 8 of the FCA Principles for Business “A firm must manage conflicts of interests fairly, both between itself and its customers and between a customer and another client”. Also, SVS must ensure that all communications with our customers, including our investment research, are clear, fair and not misleading.

Where we do not consider that these arrangements are sufficient to manage a particular conflict, we will inform you of the nature of the conflict so that you may decide how to proceed.

SVS Securities Plc is particularly active in the AIM and smaller companies markets, dealing as principal as well as agent for retail clients and providing corporate finance and broking services to companies in this market.

Chinese walls

Our investment research is produced by in house analysts. Each research recommendation clearly identifies the analyst who prepared it. Our analysts could be subject to pressures that could compromise their ability to offer unbiased opinions on investments, or the timing of publication of research, thus the policies and procedures set out below are designed to identify, minimise, manage and monitor such potential conflicts.

Our corporate finance and corporate broking staff are separated from the rest of the firm by formal Chinese-Wall arrangements which prevent the flow of confidential information to the rest of the firm. Whilst Chinese Walls and other internal procedures have been implemented to prevent persons gaining improper access to, or influencing the content or recommendations of our investment research, investors should nevertheless be aware that SVS Securities may have actual or potential conflicts of interest that could affect the objectivity, independence and impartiality of our research. Generally, confidential information about a company is held by corporate finance or corporate broking staff behind the Chinese Wall and our investment analysts will be entirely unaware of this information and may continue to publish research recommendations without taking this information into account.

However, from time-to-time our investment analysts may be brought over the Chinese Wall to advise the Corporate Finance or Corporate Broking departments; this is a controlled and fully documented process requiring the prior approval of Management and Compliance.

To ensure that the firm and its associates do not deal ahead of publication of research and until our clients have had a reasonable opportunity to act on the research, the research department is physically separated from the broking department and the broking department cannot know the contents of planned research, nor of the intention to publish research, until the research has been formally issued to clients.

Inducements

SVS Securities does not offer or agree to provide favourable investment research on any company or security, nor to make or change any particular recommendation, in order to obtain corporate finance business. Our analysts are prohibited from soliciting or accepting any inducement to publish or change any opinion or recommendation. He is not permitted to accept nominal gifts and ordinary business entertainment in accordance with the firm's formal policies on the receipt of gifts and entertainment. A company covered by an analyst may offer to pay reasonable expenses for a visit to its business premises and offer reasonable hospitality during such a visit; this will not be regarded as an inducement.

Editorial control

Responsibility for the content of research recommendations rests primarily with the investment analyst named as having produced it. All valuations and forecasts included in research material are derived independently of the company concerned and are reviewed by a director in charge of the research before being published, Research recommendations relating to corporate clients, or published in advance of the flotation of a company, are also reviewed by our Compliance department.

From time to time the company which is the subject of research may be given sight of draft research before publication to check the facts within it. No forecasts or recommendations may be included in draft research shown to a company in this way. If comments on draft research are received from the company they are reviewed by a director in charge of the research department who will decide if SVS Securities are to make the suggested amendments.

Timing and manner of distribution

The timing of publication of research is controlled by our Analysts except when it is necessary to delay publication for specific Compliance reasons, such as withholding publication of research during the period of an offering of new securities. If an analyst has been taken over the Chinese Wall and become privy to unpublished price-sensitive information he will be unable to comment on the matter in question until such time as the information is either time-expired or has been made public.

To resolve the potential conflicts involved in selective disclosure of research, when an analyst has formed an intention to write a piece of research and has started to form ideas about the content of the research he must not discuss this intention nor the potential content of the research with anyone outside the research department except for the purpose of checking factual accuracy as set out above, until such time as either the research has been distributed; or the "Research” has been made available on the SVS Securities plc website.

Personal account dealing

Our investment analysts are not permitted to invest on their own account in AIM or ISDX securities.

Monitoring

The effectiveness of these policies and procedures is monitored by the Compliance department as part of the firm's regular compliance monitoring programme

Recommendations

Conflicts of interest that cannot be managed

Before publishing a research recommendation, We or Our Associates may have acted upon it or made use of information on which it is based. Recommendations and comment in Our research publications may be affected by subsequent changes in market conditions, particularly share prices. Unless expressly acknowledged by Us in writing, these publications are not personalised or tailored in any way to Your individual circumstances. Any recommendations made will not necessarily be suitable for You and should not be treated as a recommendation to You to engage in a particular strategy or course of action.