Salonica Capital is authorised and regulated in the UK by the Financial Conduct Authority (“FCA”) with registration number (“reg. no.”) 720217. Registered office address: Level 3, 57 Grosvenor Street, Mayfair, London, W1K 3JA. We only deal with professional clients and eligible counterparties. All clients of Salonica Capital must meet the criteria of a Professional Client as per FCA rules.
We are obliged to manage fairly conflicts of interest, both those that arise between ourselves and any of our clients and those that arise between two or more of our clients.
Consequently, we maintain and operate effective organisational and administrative arrangements to take all reasonable steps to identify conflicts of interest and to prevent such conflicts from constituting or giving rise to a material risk of damage to the interests of our clients. We also maintain a written conflicts of interest policy appropriate to the size of our firm and the nature, scale and complexity of our business.
This is a summary of our conflicts of interest policy.
These are potential conflicts of interest that arise in the course of our business and for which we have established procedures to manage the conflict:
- Confidential information: we may from time to time hold commercially sensitive information, for example obtained in the course of our corporate finance activities, which would be relevant to the interests of other clients. We will always treat this information as confidential and will act in accordance with our legal and regulatory responsibilities concerning market conduct.
- Acting for more than one client: we provide execution-only and advisory services to a large number of clients, who may have similar investment profiles and objectives. None of our services are exclusive to any of our clients and, on occasion, advice given or transactions made for one client may conflict with services provide to another.
- Best Execution Policy: on occasions, for example on an allocation of new shares, a number of our clients may wish to invest in a particular financial instrument, for which demand outstrips the supply. We have established an allocation policy and procedures to ensure that this conflict between our clients is handled fairly.
Where there is the potential for a conflict of interest, the relevant Salonica employee must clear all prospective transactions with the Compliance Officer prior to taking any action. We will always seek to ensure that any transactions executed in circumstances where a potential conflict of interest exists are effected on terms which are not materially less favourable to the client than if the potential conflict had not arisen.
Please note that information on these potential conflicts does not amount to formal disclosure of those conflicts as a means to manage them. We will only formally disclose conflicts to you in the circumstances set out in the Disclosure of Conflicts section below.
As part of our conflicts of interest policy, we maintain a number of internal policies which our employees are obliged to comply with. These currently include:
- Confidentiality: all of our employees, as well as external consultants and contractors, must sign up to confidentiality provisions prior to commencing work for us.
- Personal account dealing policy: under our personal account dealing policy, our employees must obtain the consent of our Compliance Officer when carrying out investment transactions on their own account. The intention is ensure that any such transactions are free from business and ethical conflicts of interest.
- Gifts and entertainment policy: our employees are not permitted to accept or give gifts in relation to their employment with the firm except in accordance with our gifts and entertainment policy. All gifts must be reported to our Compliance Officer. All gifts must satisfy specific guidelines before they can be given or accepted: the gift must not be an inducement, in cash (or readily convertible to cash) or excessive (as a general rule greater than £100). Any gift that does not satisfy these guidelines must be formally approved by the Compliance Officer.
Disclosure of Conflicts
On occasion we may need to disclose specific conflicts of interest where we feel our internal arrangements are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of one of our clients will be prevented. We will clearly disclose the general nature and/or sources of conflicts of interest to a client before undertaking the relevant business for that client.
We will, however, always seek to manage conflicts internally in accordance with our conflicts of interest policy and shall only disclose specific conflicts to our clients as a last resort.
Review of our Conflicts of Interest Policy
We will monitor the effectiveness of our conflicts of interest policy to identify and, where appropriate, correct any deficiencies. Furthermore, we will conduct a full review of our policy at least annually.
We shall notify you of any material changes to our conflicts of interest policy.
All investments carry risks. The price of shares and other financial investments, and the income derived from them, may fall as well as rise and the amount realised may be less than the original capital invested. There is an extra risk of losing money when shares are bought in a period of high volatility.
Complaints procedure is available on request from compliance.
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