Research Policy

This policy explains the procedures which FinnCap Ltd. has adopted to manage any conflicts of interest which may arise in relation to the investment research we publish. The policy does not affect any contractual obligations owed by FinnCap Ltd. 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

FinnCap Ltd. does not present its research as objective (i.e. as an impartial assessment of the value or prospects of the investments which are the subject matter of the research).

Any research which is not presented as objective will be marked as such.

All research, whether presented as objective or non-objective, will comply with the relevant FSA 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 Corporate Finance and Investment 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
  • in the case of Corporate Finance, suggesting reference to specific competitors and other relevant quoted companies
  • checking, in the case of corporate clients, whether there is a case for deferring publication under exceptional circumstances
  • senior staff outside Corporate Finance who have been given responsibility for editing and/or checking compliance with FSA regulations
• An analyst will not publish research on a company at a time when he has confidential price-sensitive information relating to the company.
• 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.
• Those who write research do not report to anybody involved in corporate finance activities.
• Analysts’ remuneration is never linked to a specific corporate finance transaction, or 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 and corporate finance clients in deciding what to publish and when. In particular, we may produce or procure the production of research on corporate finance clients. Sometimes this will be done in advance of a particular corporate finance transaction. However, quiet periods, during which new research may not be published, will be used as appropriate to ensure that all primary and secondary offerings by corporate finance clients are conducted properly.
• 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.
• 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 also provide advisory services to investment 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 FinnCap Ltd., or of the content of that research.

Analysts producing objective research are required to produce that research free from any influence from the company to which the research relates and ignoring the interests of FinnCap Ltd. and other areas of our business, such as our corporate finance department.

All analysts may be involved in developing research and other materials which are used by our corporate finance department to help win new business or retain existing business. They may participate in pitches to actual or prospective clients for corporate finance business and endeavour to solicit business for the corporate finance department. They may not lead roadshows, other meetings or telephone calls run by or on behalf of corporate clients, but they may answer questions received from clients who are (prospective) investors or FinnCap Ltd. investment staff.

FinnCap Ltd. is authorised and regulated by the Financial Services Authority.