Conflicts of Interest Policy

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Raymond James 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 page identifies those circumstances and sets out the specific measures that Raymond James employs to manage these actual or potential conflicts of interest.

Dealing as principal

Raymond James 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 Raymond James Wealth Managers is not connected to RJ&A’s activity as a market maker. Moreover, orders placed by Raymond James Wealth Managers with RJ&A are subject to RJ&A’s own execution policy (based on the rules of the Financial Industry Regulatory Authority ‘FINRA’), 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.

Investment Research

Raymond James 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 Raymond James Wealth Managers from accessing price-sensitive investment research undertaken by RJ&A before it is made public. Moreover, the supervision and remuneration of Raymond James Wealth Managers is not connected in any way with RJ&A’s activities in this area.

Personal dealing by officers and associates of Raymond James

Raymond James Wealth Managers may hold positions in securities that they are recommending to their clients. Raymond James has a policy that controls personal account transactions undertaken by Raymond James Wealth Managers and their employees, and head office staff. This policy ensures that personal account transactions do not disadvantage, or conflict with the interests of, Raymond James’s clients. For example, Raymond James ensures that any trades undertaken by a Wealth Manager 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.

Raymond James also makes clear in its marketing communications the circumstances in which a Wealth Manager may be holding personal positions in any securities mentioned.

Gifts and inducements

Raymond James operates a policy that obliges Wealth Managers to declare any gifts or inducements that they have received over the value of £100. Wealth Managers maintain a register of these gifts and these are reviewed by Raymond James on a quarterly basis.

Conflicts between clients

There are circumstances in which a number of Raymond James’s clients may be wishing to deal in the same security at the same time. Raymond James’ dealing procedures ensure that orders are either passed through our dealing desk, which is independent of Raymond James’ Wealth Managers, 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.