This policy explains the procedures which JM Finn & Co has adopted to manage any conflicts of interest which may arise in relation to the research we publish. The policy does not affect any contractual obligations owed by JM Finn & Co to its clients or give rights to any third party. Nor does the policy apply to any personal recommendation which is tailored to a client’s particular circumstances.
JM Finn & Co will not normally be able to present its research as independent (i.e. as an objective or independent explanation of the matters contained in the recommendation).
All research which cannot be presented as independent will be marked as such, clearly identifying it as a marketing communication and containing a statement that it has not been prepared in accordance with the legal requirements designed to promote the independence of investment research and is not subject to the regulatory prohibition on dealing ahead of the dissemination of investment research.
However, all research, whether presented as independent or non-independent, will comply with FCA requirements, in particular to be clear, fair and not misleading, and will comply with the following policy:
- Draft research will only be reviewed prior to publication by the company to which the research relates in order to verify factual accuracy
- Analysts are free to express their own views in research reports free from pressure and control by staff in any other business area (specifically Investment Management/Advice). Staff in other areas are prohibited from reviewing or approving the content of draft research reports before publication other than:
- for the purposes of verifying the factual accuracy
- senior staff who have been given responsibility for editing and/or checking compliance with FCA regulations
- An analyst will not publish research on a company at a time when he has confidential price-sensitive information relating to the company.
- All research will be signed off by the Compliance Department
- Favourable research coverage, specific investment conclusions, or specific recommendations will not be offered as consideration or inducement for the receipt of any business or compensation from any source.
- Analysts’ remuneration is never linked to recommendations contained in their research. Remuneration decisions are made by a remuneration committee, of which the Managing Director is a member.
- Decisions on the subject matter and timing of research are normally taken by the analysts themselves, but the senior staff responsible for sign-off are also ultimately responsible for the timing of publication. We will take account of the needs of our investment clients in deciding what to publish and when.
- Research will be distributed to clients in a manner which we consider to be appropriate having regard to each client’s requirements and the service we provide. Not all clients will receive all research. Research will not necessarily be sent to all clients at the same time. In certain circumstances, some clients or groups of clients will be sent research after it has previously been sent to other clients – this will be normal practice where research is principally intended for institutional clients, but may afterwards be made available to other clients.
- Analysts may provide services and information on an ongoing basis to dealing and investment staff, for example in daily meetings. Analysts will not, however, disclose the content or timing of research which is to be published ahead of its publication.
- Analysts may not provide investment management or advisory services to individual clients, nor may they take investment instructions from clients – all such services must be provided by Investment Managers rather than Research, and the Research Department must not carry out any of the functions that are normally carried out by Investment Managers in respect of Investment Managers’ clients.
- Restrictions on personal account dealing are placed on analysts and other staff. Analysts may not in general trade in a manner contrary to their published recommendation or deal ahead of the publication of any research report.
- All staff are subject to rules which prohibit them from taking advantage, for the benefit of clients or any other person, of knowledge that research is to be published by JM Finn & Co or of the content of that research.
Analysts producing research are required to produce that research free from any influence from the company to which the research relates and ignoring the interests of JM Finn & Co and other areas of our business.