Conflicts of Interest Disclosure
A conflict of interest arises when a person who owes a fiduciary duty to a client could be influenced to put a personal or professional interest ahead of their duty to that client. A conflict of interest may exist even if the person always does in fact act in the best interests of the client.
James Hambro & Partners and its appointed representative James Hambro & Company (together, “the group”) is committed to taking all appropriate steps to identify and properly manage conflicts of interest between the group and its clients, and between one client and another.
On at least an annual basis we take steps to assess current and identify new conflicts of interest to ensure that our organisational and administrative arrangements are sufficient to prevent or manage each conflict.
While the group arranges its organisation and administration to prevent conflicts of interest from adversely affecting the interests of clients, there are certain areas where a risk, however small, may remain.
This document provides information in relation to those areas where some risk of an actual or potential conflict of interest remains. If you have any questions in relation to this document, please contact your advisor.
Directorships, shareholdings and other interests in collective investment schemes our clients are invested in
A small number of employees, officers and partners of the group have outside roles in firms which manage collective investment schemes (“CIS”)that we may select or recommend for our clients’ portfolios. In order to prevent these individuals influencing the selection of CIS in our client portfolios, we have implemented procedures to restrict the influence that such individuals may have over the purchase or sale of such CIS in client portfolios.
JH&P sponsors and manages the IFSL James Hambro Harrier Funds (“Harrier Funds”). Where suitable, we may select one of these funds for your portfolio as a way of providing access to our investment strategy, ideas and expertise. While there may be other fund managers that offer similar strategies, the day to day management of their funds will not replicate JH&P’s investment process, including our approach to asset allocation, security selection and risk management. Third party funds may outperform or underperform the JH&P funds and past performance is not an indicator of future results.
Employee Personal Dealing
We believe that permitting our staff to transact investments in their personal account reinforces confidence in our investment process by demonstrating that our portfolio managers have conviction in their decisions. We have in place policies and procedures designed to prevent our staff’s personal account dealing impacting the outcomes for clients by affecting the market price of securities. This includes prohibiting dealing at certain times, imposing minimum holding periods, and requiring pre-approval for trades.
As part of their responsibilities, all our investment staff require access to the third party research which is paid for by clients. Our collaborative investment process supported by independent monitoring procedures is designed to ensure that investment opportunities identified as suitable for our clients are taken up for clients before being transacted for personal accounts.
Recommendations for Discretionary Portfolio Management
Our financial planning clients may be recommended a discretionary managed portfolio service delivered by JH&P. Our monitoring processes include checks that such advice is suitable for the client. JH&C does not purport to research or assess the wider market for discretionary managed portfolio services.
Client Money Interest
Cash held in client portfolios is placed on deposit in accordance with the client money rules. Any difference between the rate of interest received by JH&P on client money accounts and the rate notified to you is retained by JH&P and therefore JH&P may benefit from this difference. Any decision to hold cash in a client portfolio would be a result of our collaborative asset allocation process or to meet client liquidity needs.
Aggregation & Allocation
We may combine (“aggregate”) transactions for one client’s portfolio with those of other clients and the clients of our Associates and will allocate such transactions on a fair and reasonable basis. The effect of aggregation may on some occasions operate to our client’s advantage and on other occasions to their disadvantage.
We have relationships with many third parties, including introducers, intermediaries, product providers and other financial services firms. We have processes in place to ensure that any monetary or non-monetary benefits received from or provided to such parties, for example fees, commissions, gifts or entertainment, comply with the relevant rules and do not impair our duty act in the best interests of the client.
Other Fiduciary Duties to Clients
Group staff are permitted to hold outside appointments provided they are fully disclosed to us, however the group does not permit its staff to act as Trustee, Executor, Director or Power of Attorney for its clients, unless this has been approved by Senior Management on the basis that the management of the client portfolios will not be adversely influenced.
If a specific conflict arises relating to a particular client, we may decline to act for that client if the conflict cannot be managed in any other way.