Keith Bayley Rogers & Co. Ltd ("KBR") is authorised and regulated by the Financial Conduct Authority (FRN 197385). The FCA's rules require KBR to identify, prevent or manage conflicts of interest that arise in the course of its business. This is a summary of how KBR does so.

What is a conflict of interest

A conflict of interest can arise where the interests of KBR, its director or consultants differ from those of a client, or where the interests of two or more clients differ. Given the nature of KBR's business, conflicts are most likely to arise between corporate finance and broking work for a company and equity research on that company, between clients involved in the same transaction or sector, and through the outside interests, other engagements or personal dealings of KBR's director and consultants.

How KBR manages conflicts

KBR identifies potential conflicts before taking on any engagement and keeps a record of them. Arrangements to manage them include:

• a requirement that the director and consultants declare any outside interests, directorships, shareholdings and other engagements that may give rise to a conflict, and a register of those declarations;
• rules on personal account dealing, including prior approval of consultants' transactions by the director and a record of all such transactions;
• restrictions on the sharing of confidential and inside information, including between consultants working on different matters;
• research that is clearly identified where KBR acts for, or has a relationship with, the subject company;
• remuneration arrangements that do not reward the director or consultants in a way that conflicts with clients' interests; and
• a policy on gifts and hospitality.

Disclosure and declining to act

Where the arrangements above are not sufficient to manage a conflict, KBR will disclose its general nature and source to the client before acting, so the client can decide whether to proceed. Disclosure is a last resort and is not a substitute for managing the conflict. Where a conflict cannot be managed adequately, KBR will decline to act.

Review

KBR reviews this policy at least annually.

Further information

A copy of the full policy is available on request from Brinsley Holman, Director, at brinsley.holman@kbrl.co.uk.