Conflicts of interest policy
The Thesis group of firms includes two regulated entities, namely:
Thesis Asset Management plc (TAM), and
Thesis Unit Trust Management Limited (Tutman)
The FSA’s rules require that Thesis Asset Management plc (The firm) must be in a position to identify conflicts of interest arising in any of the following situations where the firm is carrying out regulated activities where:
a) it stands to profit or avoid a loss to the detriment of one or more of its clients
b) it has a financial or other incentive to favour the interests of one of its clients over those of another
c) it has a financial or other incentive to favour its own interest over that of one or more of its clients.
Where such conflicts arise, they will be reported to the Compliance Officer, who will record them.
In all such cases, the Compliance Officer will decide what the appropriate action to take is. In no case will the firm or any given client be favoured to the detriment of another client and in all instances the conflict of interest will be managed fairly. The appropriate action will consist in taking one or more of the following steps:
a) disclosing the interest to the client(s) affected
b) relying on a policy of independence (this policy should be recorded and made known to the relevant staff member and client(s)
c) declining to act for the client(s).
The material and relevant potential conflicts of interest identified by the firms are set out in the table below.
| Identified Potential Material Conflicts | Procedures and Measures |
|---|---|
| TAM or Tutman may be the manager of, or adviser to, a collective investment scheme, units or shares in which we may buy or sell on your behalf. This may increase revenues within the Thesis group. | Thesis funds are purchased only on their investment merits and in accordance with the client’s investment management agreement. No double charging takes place where such funds are purchased. |
| TAM may receive a commission from the manager of a collective investment scheme in which we may invest on your behalf. | Investment in a third party fund is made strictly on its investment merits and independently of any consequential revenue benefit. |
| Staff of TAM or Tutman may purchase or sell for their personal account securities which we may buy or sell on your behalf. | Rigorous personal account dealing policies and procedures apply to all Thesis directors and staff; these are detailed in the firm’s compliance manual. |
| Staff of TAM or Tutman may receive inducements from the issuer of a security or the manager of a collective investment scheme in which we may invest on your behalf. | Procedures are in place concerning the acceptance of inducements which apply to all Thesis staff. These procedures include the maintenance of a comprehensive gifts and entertainment record. |
| Fund managers may undertake excessive turnover of holdings in clients’ portfolios in order to generate higher levels of commission for TAM. | Portfolio activity levels are independently monitored. Thesis operates a comprehensive inducements policy as outlined above. |