Risk Warning and Policies

> Risk Warning
> Order Execution Policy
> Conflicts of Interest Policy
> Research Policy
> Treating Customers Fairly Principles

Risk Warning

All investments are speculative and prices may change quickly and can go down as well as up. Past performance will not necessarily be repeated and is no guarantee of future success. There is an extra risk of losing money when shares are bought in some smaller companies including "Penny Shares" and companies listed on Plus Markets & AIM. There can be a big difference between the buying price and the selling price of such shares, and if they are sold immediately you may get back much less than you paid for them. In some circumstances, it may be difficult to sell at any price.

It may also be difficult for you to obtain reliable information about the value of your investment or the extent of the risks to which it is exposed. Do not invest in these types of products unless you have carefully thought about whether you can afford it and whether it is right for you and if necessary consult with a professional adviser in accordance with the Financial Services and Markets Act 2000 particularly if you are on a fixed income or approaching retirement age.

This website should not be regarded as an offer or solicitation to conduct designated investment business. The content of this site has been prepared with all reasonable care and is not knowingly misleading in whole or in part. Any research information is obtained from sources which we consider to be reliable but its accuracy and completeness cannot be guaranteed. Any opinions and conclusions given are those of Bridge Hall Stockbrokers Ltd. and are subject to change without notice.

Bridge Hall Stockbrokers Limited and/or its connected companies and/or directors or employees and/or members of their families may from time to time have a material interest (including options) in relation to an investment in which we deal on your behalf and may add or dispose of such securities from time to time Before you begin to trade, you should obtain details of all commissions and other charges for which you will be liable This service is only available to UK residents who are aged 18 or over.

 

Privacy Policy

All information on every transaction is properly protected. All telephone calls are recorded for your protection. We are registered with the Information Commissioner under the Data Protection Act.

> Back to Top


Order Execution Policy

Our order execution policy has been implemented in order to set out the reasonable steps that we will take in order to obtain the best possible results for our clients.

The factors that we will take into account when determining the best possible result for you include price, costs, dealing size, speed and settlement capabilities. Our priority will primarily be price & costs in normal circumstances.

We will take all reasonable steps to obtain the best possible result, however, we cannot guarantee that on every occasion we will achieve best execution for your orders.

The chosen Execution Venues on which we place significant reliance are:

The London Stock Exchange &
The Plus Market

We may elect to use any other additional Execution Venues should we deem it appropriate or add or remove an Execution Venue from our chosen Execution Venue. Although we will not notify you of these changes you are advised to check with your usual Investment Adviser from time to time.

We undertake to regularly assess our chosen Execution Venues, at least annually to prove consistency of the best possible results when executing orders

You may provide us with a specific instruction that overrides our Best Execution Policy.

We may execute your trade outside of our chosen execution venues ie outside a regulated market, Multilateral Trading Facility or overseas.

A demonstration that your order has been executed in accordance with our Best Execution Policy is available upon receipt of your written request. We shall endeavour to respond to such a request within 20 business days or alternately advise of the reason for the delay.

Under FSA rules, we may arrange the aggregation of orders, which may, or may not, result in a more favourable price being obtained. We will only arrange this aggregation of your orders with other orders where we believe that doing so is in your best interests and only within one 24 hour period.

If an order has been placed with us with a specific limit on the execution price we shall generally treat as ‘good till dealt’ or ‘good for the day’. Should we be unable to execute it immediately, in accordance with the regulatory requirements and unless otherwise specifically instructed, we will publicly disclose details of any unexecuted part of such ‘limit’ order.

We may transmit an order that we receive from you to various third parties for execution. In doing so we still retain our responsibility to take all reasonable steps to provide the best possible results.

MiFID requires that we obtain your consent to our order execution policy as summarised above. We will deem that you have provided such consent where you place an order or effect a transaction on or after 1st November 2007.

Nov 2007

> Back to Top


Bridge Hall Conflicts of Interest Policy

Introduction

All MiFID Firms are required to establish, implement and maintain a written Conflicts of Interest policy. A copy of Bridge Hall’s conflicts of interest policy must be provided to retail or potential retail clients upon request.
Under the FSA's SYSC rules, we are required to take all reasonable steps to identify conflicts of interest between:

 (1) the firm, including its managers, employees and appointed representatives, or any person directly or indirectly linked to them by control, and a client of the firm; or

(2) one client of the firm and another client. We also believe that we should identify any conflicts that may arise in other situations including between the firm and any of its shareholders. Where we owe a duty to such clients, we must maintain and operate arrangements to prevent any conflict from giving rise to a material risk of damage to the interests of our clients.

Bridge Hall provides a range of services to a number of different clients. As a result circumstances may arise whereby the interest of the client may conflict with the interests of the firm or with those of another client. It is of vital importance that any risk of a conflict of interest is identified and managed appropriately, both to comply with FSA Rules and our wider duties to customers, and also to ensure that the integrity of our services is not eroded.

Our conflict of interest policy is deeply ingrained in our policies and procedures; we are committed to treating our customers fairly and we will never knowingly put ourselves in a position whereby our own interests, or our duty to another party, prevent us from discharging our duty to our clients. We fully train our staff in our conflicts policy and if they become aware that Bridge Hall has a material interest in a transaction to be entered into by a customer, or a relationship which gives rise to a conflict of interest in relation to that transaction, the employee must disregard Bridge Hall's interest when advising the customer. We must also disclose the general nature of potential conflicts of interest to clients in a conflicts of interest policy. This is that policy

Definitions

"employee"
Means a permanent or temporary employee of the Company.

"family"
Means a family member or partner of the employee.

"senior management"
Means the senior management of the Company

"personal transaction"
Means any transaction in an instrument included under the Company’s conflict of interest policy,

"personal dealing"
policy or any such other Company policy imposing restrictions over employee trading activity.

"investment research"
Means any form of investment advice, guidance or recommendation issued by the Company in the course of its normal activities.

"conflict of interest"
Means a situation whereby a client may suffer a loss or disadvantage through an action which results in a benefit or advantage to the Company or another client.

Fundamental Principles

In dealing with and for our customers Bridge Hall observe two fundamental principles:

  • that we do not disclose any information which has been given to us by our customers on a confidential basis, and do not use such information for our own benefit or for the benefit of any other customer, without the original customer's consent; and
  • that we act at all times in a way which ensures the fair treatment of all our customers. This means that we need to identify and deal with the potential for any conflicts of interest which may arise either between a customer and the interests of the Company or between two or more customers

FSA Principles

Bridge Hall pays particular attention to the FSA principal based rules and, in respect of conflicts of interest, our responses to the FSA Statement of Principals related to conflicts of interest are as follows:

FSA Principle 1 - A firm must conduct its affairs with integrity.

Bridge Hall's policy is to prevent a deliberate failure to disclose the existence of a conflict of interest in connection with dealings with a client.

FSA Principle 2- A firm must conduct its business with due skill, care and diligence.

Bridge Hall's policy is to prevent a failure, without good reason, to disclose the existence of a conflict of interest in connection with dealings with a client.

FSA Principal 8 - A firm must manage conflicts of interest fairly, both between itself and its customers, and between one customer and another client.

A conflict arises where the firm has an interest in the outcome of a transaction over and above their normal interest. Bridge Hall  have identified many instances where this could arise. One example would be if a firm recommends the use of a sister company in order to generate extra income. Another example would be when a firm recommends to customers that they should buy a share in which the firm has large position. Alternatively a firm could recommend that customers apply for a new issue of shares because the firm is hoping to obtain other lucrative business from that company and therefore wants the issue, and its part in it, to be successful.

Bridge Hall’s policies are designed to prevent such conflicts.

Chinese Walls

Chinese Walls are a method of restricting the internal flow of information between parts of a firm performing different and possibly conflicting functions.  Their purpose is to allow an entity to conduct particular activities simultaneously that would otherwise, if universally known, create conflicts of interest. For a Chinese walls Policy to be effective, the organisation and arrangements supporting them are made clear to all employees and enforced rigorously. The Company has procedures in place to manage situations where the exchange of information must be controlled in order to prevent or manage conflicts of interest. All employees are required to observe the Company’s insider dealing policy which requires employees to notify Compliance of all situations whereby an employee becomes aware of inside information. Employees are also required to notify Compliance of any situation where information received might constitute inside information.

Compliance will record the circumstances of the situation and take such action as is necessary and appropriate. This may include (but is not limited to):

  • Requiring the employee not to disclose the inside information to any other party
  • Requiring the employee to desist from any activities whereby the knowledge of the inside information will or might create a conflict of interest.

Disclosure of a Material Interest

The Company cannot act for a customer in a transaction if it has a material interest in a security or related transaction, unless we first disclose this fact to him.  The test is an objective one; is the interest such that it could reasonably be assumed to lead to our acting against the customer's interests?  If you discover such a conflict of interest during the course of an assignment, this would immediately be brought to the attention of the Compliance Department.

Conflicts of Interest and Investment Research

Under the FSA’s principles-based approach, firms are responsible for identifying and managing any conflicts of interest arising in their business that might compromise the impartiality of the firm’s outsourced research analysts and their research. The EU Directive on Market Abuse and its implementing measures  require that investment analysis meets specified standards as to content and includes certain disclosures to enable those to whom it is distributed to make an informed judgement as to whether or not it may be biased. The new requirements apply in respect of 'research recommendations', and this term is not synonymous with 'investment research' - the term used by the FSA in its rules and guidance on investment research. The term 'research recommendations' only relates to information concerning financial instruments admitted to trading on a regulated market. The term 'investment research', although narrower in meaning, is not restricted to information about securities traded on regulated markets, and therefore extends to securities traded on unregulated markets.

To ensure, as far as is practicable, those potential conflicts of interest are effectively managed, Bridge Hall has adopted the policy of making the required disclosures where appropriate irrespective of whether the information concerns financial instruments traded on a regulated market or not.  

In addition, Bridge Hall maintains a "restricted list" of companies upon which research is being prepared which is monitored by Compliance Department with respect to employee share dealing.

Corporate Finance Business Issues
We have adopted policies to ensure that we manage any conflicts of interest which may arise during a securities offering in such a way as to ensure that all clients are fairly treated fairly. 

Procedures for Approving New Business
Any obstacles to proceed (with new business) due to potential conflict of interest is checked and clearance noted in the records.

Share Allocation
Client orders must be dealt with sequentially and in accordance with the timing of their reception. They must be accurately recorded and allocated. Bridge Hall and its employees must not misuse information relating to client orders.

If one or more client orders are aggregated, the trades must not be allocated in a manner detrimental to the client. If the aggregated order is only partially executed, the trades must be allocated to the clients on a pro-rata basis. Unfair precedence should not be given to any particular client.

Personal Account Dealing Restrictions and Procedures

Bridge Hall maintains a personal dealing policy which all employees are required to observe. This policy places restrictions on employees to ensure that all personal dealing activity is appropriate and will not create an actual or potential disadvantage or loss to a client.

All personal dealing requires pre-approval unless the investment instrument is not a product or in a market that Bridge Hall's clients currently have exposure to. The pre-approval process requires an assessment as to whether a Bridge Hall client is or may be trading in the instrument for which permission is being sought. In the event that a client is trading or may trade in the same instrument, the employee is not permitted to trade until the client no longer has an interest in trading.

 The Company expects all employees to manage their personal financial arrangements in such a way that their personal exposure is not excessive or hazardous in performing their role as fit and proper person. In any situation where the Company has a reason to question an employee's activities, the Company would consider whether a personal transaction would be permitted purely on a case-by-case basis, and the final decision is that of the Company.

Rumuneration, Commission and Bonus Structures

Remuneration, commission and bonus structures are designed so as not to create any incentive for an employee to act contrary to a client’s interests.

Gifts and Inducements

Employees, their families and any personally connected individuals are not allowed under any circumstances to offer or give, solicit or accept any inducement which causes, is likely to cause, or is perceived as likely to cause conflict with any duties owed by themselves or the Company to clients.

Cash gifts are not permitted and must be not offered or accepted.

The definition of a gift includes (but is not limited to) physical presents, club memberships, discounts, holidays, accommodation, and entertainment. Entertainment may not be offered whereby the client is not accompanied by a Company employee. Entertainment may not be received whereby the employee is not accompanied by the donor.

Generally, other entertainment need not be reported as a gift but the entertainment policy requires employees to notify Compliance in advance of any entertainment which might give the impression of influencing the employee's judgement or behaviour in the continuation of their duties to the Company and its clients.

Invitations to attend certain events must be refused if they could be construed to be unusual, to appear to create a sense of obligation to the host or bias in their favour. This must be assessed in the context of the nature of the invitation, including cost or rarity value or any other relevant factor.

Entertainment given or received in the normal course of business e.g. lunches, does not require notification to the Compliance Department. However, employees must exercise their judgement in order not to give grounds for suggestions of undue influence, e.g. where the business lunches become frequent.

All gifts to be given or received, in the course of the Company's business, with a value of £100 or more must be entered onto the gifts register held by the Compliance Department and complete an Annual Inducement report. Where a series of gifts, from the same individual or different individuals representing the same organisation and in succession such that the gifts represent a single inducement, represents a value of £100 or greater, no further gifts are allowed. The register is reviewed regularly by the Compliance Department in order to ensure that there is no evidence of any undue influence being created by any gifts or series of gifts.

Where a gift arrives unexpectedly and its value is considered excessive, but it would be impractical or offensive to return it, employees should declare it in writing to the Head of Compliance and surrender it to one of the compliance officers, who will make suitable arrangements for its use within the Company or for charitable purposes or disposal.

Regardless of value, employees must ensure that no gift or series of gifts can be accepted which may appear to create a conflict of interest.

The gifts policy also applies to all suppliers and service providers as well as potential suppliers and service providers.

In considering whether a gift or form of entertainment is excessive or inappropriate, the Compliance Department will consider the nature of the business relationship and whether it could be regarded as an improper inducement by the employer of the recipient or donor or by any other relevant party.

When in doubt whether a gift or entertainment is appropriate, all employees are required to consult the Compliance Department.

3rd party business interests

Bridge Hall employees are expected to devote the whole of their working time, attention and abilities to their duties for the Company. They may not, whether directly or indirectly, undertake any other business activities without the prior written approval of the Company.

Employees may not without the prior written consent of the Company accept any appointment which may conflict with the interests of the Company or which may in any way affect their abilities to carry out their duties for the Company. In the event that the 3rd party interest would represent a clear conflict of interest, permission to act for the 3rd party business would not be granted.

Prior written consent must be made to the Compliance department and requires authorisation by senior management. Employees must provide relevant information as required about the respective appointment or duties to be undertaken and no approval will be granted in the absence of all necessary information required to make a decision.

As part of the Company's employment terms and conditions, employees must disclose on demand to the Compliance Department any external business interests they have, including any directorships, business arrangements or any other relevant information.

The Compliance Department will review all business interests disclosed in order to ensure that there is no evidence of any undue influence or conflict due to employees' 3rd party business interests

Senior management control

The Compliance Director is responsible for the identification and management of conflicts of interest on a daily basis.

Where there is an identified significant conflict of interest, the Board Members will be informed immediately.

The Compliance Director provides the Board with regular reports of all conflict of interest situations that have arisen. This includes details of the situation, the assessment and escalation activities undertaken and measures taken to mitigate them.

Periodically (no less than annually) senior management will analyse the cases of conflicts of interest that have arisen as well as potential conflicts of interests and review the systems and controls put in place for the prevention and mitigation of the conflicts of interests in order to ensure that these remain effective and relevant.

Record Keeping
Records of actual and potential conflicts and the procedures in place to manage them are kept for a minimum of 5 years.

> Back to Top

Research Policy

In accordance with FSA's principles-based approach to regulation, Bridge Hall is responsible for identifying and managing any conflicts of interest arising in our business that might compromise the impartiality of our research. Bridge Hall has issued this policy in which it intends to set out the potential conflicts of interest which may affect the impartiality of our research and the systems, controls and procedures in place to ensure, as far as is practicable, those conflicts are managed effectively.

The EU Directive on Market Abuse adds to these provisions by requiring that our analysis meets specified standards as to content, and includes certain disclosures to assist recipients in making an informed decision as to whether or not it is biased.

The requirements apply in respect of 'research recommendations', and this term does not only refer to investment research – the term used by the FSA in its rules and guidance on investment research. The term 'research recommendations' only relates to information concerning financial instruments admitted to trade on a regulated market. The term 'investment research', although narrower in meaning, is not restricted to information about securities traded on regulated markets, and therefore extends to securities traded on unregulated markets.

Bridge Hall has adopted the policy of making the required disclosures where appropriate irrespective of whether the information concerns financial instruments traded on a regulated market or not.

In addition, Bridge Hall does not permit any employee share dealing in companies upon which a research note is being prepared.

The FSA has distinguished between "Investment Research" and "Non-Independent Research".

Investment Research can only be produced by persons who do not have responsibilities that might conflict with the interests of the clients who may rely upon that piece of research. It must be labelled or described as investment research or in similar terms, or is otherwise presented as objective, impartial or an independent explanation of the matters contained in the recommendation.

Non-Independent Research is categorised as such because it has been prepared by persons who may be exposed to such conflicts of interest and is considered non-objective or non-impartial. It is also referred to as a "Marketing Communication".

All Bridge Hall’s research is conducted by various Independent Analysts under a contract of business for each research article published in accordance with the FSA's definition of "Investment Research" above. These Independent Analysts are required to comply with the Bridge Hall personal account dealing rules, are required to disclose to Bridge Hall any interest which they or a member of their household has in a security that is the subject of any research that Bridge Hall may contract. Should an interest exist affecting impartiality, a disclosure to that effect will be included on the investment research. 
 
Bridge Hall’s contracted analysis on Plus Market or Aim listed smaller companies may be gathered through our independent analyst's discussions with the company management and/or by their own independent sector research and analysis.

Should Bridge Hall have cause to produce non-independent research, it will be clearly identified with the following disclaimer "This research is classified as being a marketing communication" in accordance with the FSA Handbook COBS 12.3, it will also contain a clear and prominent statement that it has not been prepared in accordance with legal requirements designed to promote the independence of investment research and is not subject to any prohibition on dealing ahead of the dissemination of investment research.

A marketing communication is a form of financial promotion and is therefore subject to FSA's financial promotion rules in COB 4, including the requirement for it to be fair, clear and not misleading.
   
Whenever Bridge Hall distributes research material, including emails, it will be accompanied by a disclaimer which will clearly identify the research as being impartial or non-impartial.

Investment research is subject to oversight and approval by the Compliance Department prior to distribution.

This policy is subject to regular review by Bridge Hall's senior management.

> Back to Top

Treating Customers Fairly Principles

1. Strategy and Behaviours

2. Product & Service Design

3. Customer Communication

4. Customer Expectations

5. Intermediaries

Bridge Hall has supporting policies and procedures to ensure that the information and investment needs of our customers are adequately supported. For example;

For further information about Bridge Hall’s ‘Treating Customers Fairly’ principles, initiatives or further support please contact your usual Bridge Hall adviser

> Back to Top