RJIS Conflicts of Interest Policy

RJIS recognises that, in the course of its business, there are circumstances which may give rise to a conflict of interest entailing material damage to its clients.

This document identifies those circumstances and sets out the specific measures that RJIS employs to manage these actual or potential conflicts of interest.

1. Dealing as principal

RJIS does not hold principal positions in securities, or deal on its own account. However, we are associated with Raymond James & Associates (“RJ&A”) in the United States of America, which does.

The supervision and remuneration of RJIS advisers is not connected to RJ&A’s activity as a market maker. Moreover, orders placed by RJIS advisers with RJ&A are subject to RJ&A’s own execution policy (based on the rules of the National Association of Securities Dealers), which ensures that a client’s order may not be traded on RJ&A’s own book if it is not in the best interest of the client. Contract notes clearly indicate where the counterparty was RJ&A.

2. Investment Research

RJIS does not procure or produce its own investment research, however RJ&A does. RJ&A operates an independence policy that creates information barriers to control exchanges of information relating to investment research undertaken by RJ&A.

These information barriers prevent RJIS advisers from accessing price-sensitive investment research undertaken by RJ&A before it is made public. Moreover, the supervision and remuneration of RJIS advisers is not connected in any way with RJ&A’s activities in this area.

3. Personal dealing by officers and associates of RJIS

RJIS advisers may hold positions in securities that they are recommending to their clients. RJIS has a policy that controls personal account transactions undertaken by RJIS advisers and their employees, and head office staff. This policy ensures that personal account transactions do not disadvantage, or conflict with the interests of, RJIS’s clients. For example, RJIS ensures that any trades undertaken by an adviser in the same security as his/her clients on the same day are placed at the ‘back of the queue’ in terms of price and execution.

RJIS also makes clear in its marketing communications the circumstances in which an adviser may be holding personal positions in any securities mentioned.

4. Gifts and inducements

RJIS operates a policy that obliges advisers to declare any gifts or inducements that they have received over the value of £100. RJIS maintains a register of these gifts.

5. Conflicts between clients

There are circumstances in which a number of RJIS’s clients may be wishing to deal in the same security at the same time. RJIS’ dealing procedures ensure that orders are either passed though our dealing desk, which is independent of RJIS’ advisers, or they are entered onto an automated trading platform, which will ensure that the most advantageous outcome is obtained, regardless of the identity of the client.

Effective 1 November 2007