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Introduction
YTM Stockbrokers (UK) Ltd is an Appointed Representative of XXXXX who is authorised and regulated by the Financial Services Authority. YTM Stockbrokers must take all reasonable steps to identify actual or potential Conflicts of Interest between the firm and a client of the firm; or between clients of the firm. We believe in treating customers fairly at all times and this policy document sets out those areas that YTM Stockbrokers have identified as having potential for Conflict of Interests and the procedures that we have employed to mitigate such events.
In the event that a conflict of interest should arise that cannot be mitigated by the procedures laid out in this policy or by additional procedures that YTM Stockbrokers may introduce from time to time then YTM Stockbrokers will manage such conflict by disclosing the nature of the interest to you as soon as the matter becomes apparent.
By creating this Conflict of Interest Policy document pursuant to FSA rules, YTM Stockbrokers do not infer or create any contract between a prospective and existing customer and YTM Stockbrokers or any of our associated companies as this document is not intended to create any form of third party rights.
If there are questions to the matters in which this document refers to, please feel free to address these to our Compliance Department.
1. Agent To The Client
YTM Stockbrokers place the client at the heart of our business at all times. We act as the client’s agents at all times, and have a duty to their interests that is un-conflicted with any corporate relationship that may exist. Each client has a personal broker who is responsible for the management of their stockbroking account. They have the right to discuss their account with their broker, or to request that their broker is changed, even when there is no complaint about their broker or their work. The broker concerned will therefore never be responsible for resolving complaints about their work. Instead there is a formal complaints handling procedure that is routed independently through the Compliance Department of the firm.
2. Placings
From time to time, we may become aware of the issuance of new shares (Placings) in a company where we would recommend to our clients the purchase of such shares. Subject to investor demand we may not be able to obtain all the shares we would like, and on occasion fall short of a desired amount. Our policy is then to allocate investments on a pro-rata basis wherever feasible. Where we obtain such a small allocation of shares that we feel it is not suitable to make a distribution across our entire client base, there may arise a conflict between clients, as we choose the most suitable clients to be asked to participate in the Placing. Before allocating investments to clients, we first comply with our regulatory obligations to assess suitability. We then determine which clients have sufficient funds by the commitment date and both understand the investment’s terms and conditions and are willing to be bound by them.
3. Referring Parties
YTM Stockbrokers continually monitors the business of all customers that a Referring Party has introduced to the firm. In the case of a Referring Party with Power of Attorney accounts we monitor for excessive trading that may be disadvantageous to the customer.
4. Personal Account Dealing
Ideally, we request all employees to avoid dealing in instruments or investments which are advised by YTM Stockbrokers to prospective and existing customers. However, all employees of YTM Stockbrokers under the Terms of their Contract of Employment and in accordance with the firm’s Compliance Manual are required to obtain prior approval and promptly provide the firm’s Compliance Officer with hard and electronic copies of any Personal Account Dealing that they may conduct in relation to regulated instruments and investments.
5. Personal Relationships
All employees of YTM Stockbrokers are required, under the Terms of their Contracts of Employment and the firm’s Compliance Manual, to immediately advise the firm’s Compliance Officer of any family members or personal friends who are either customers, employees or service providers to YTM or any of its associated companies.
6. Gifts Policy
It is the policy of the firm that brokers may not accept a gift valued at over £100 without the prior consent of the Compliance Department.
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