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Conflicts of Interest Management Policy Introduction Evolution Securities China Limited ("ESCL") is authorised and regulated by the Financial Services Authority ("FSA") and is required to manage conflicts of interest fairly (Principle 8). The FSA requires authorised firms that issue investment research to clearly disclose any areas of conflicts that may impact the objectivity of their analysts. The policy below sets out the systems, controls and procedures that ESCL has in place to manage potential conflicts of interest. ESCL is committed to producing high quality, independent research. We have controls in place to ensure that the independence of our analysts is not compromised. We also have systems and controls in place to ensure that access to confidential and price sensitive information is restricted and that the research we produce is a true reflection of the analysts' opinion, based on his/her knowledge of both the sector and the company. Conflicts Disclosures ESCL provides a number of services to a range of companies and as a result we have commercial relationships with several companies that we research. Where a conflict exists we will disclose the nature of the relationship on the published research. We will also disclose whether we make a market in the securities of the covered company. Due to the nature of our business, we do not produce investment research that meets the FSA's definition of "impartial" and this is clearly stated in our standard disclaimer, which appears on each item of published research. For factual accuracy, we usually provide the companies we research an opportunity to review the draft document prior to publication. We disclose on our published research whether the document was reviewed and whether any changes were made following this review. Personal Account Dealing ESCL has a policy that is designed to prevent Analysts from buying and selling stocks that he/she covers. In addition, all staff are prevented from dealing in stocks where ESCL intends to publish a research note within the next 3 business days or at least 1 day after publication. Gifts and Entertainment Policy ESCL has a policy designed to prevent all staff (including analysts) from accepting gifts or entertainments worth more than £250, or its foreign currency equivalent, without prior approval from both the compliance department and the head of their department. Analysts' involvement in other areas of ESCL business ESCL may in some cases use the expertise of our analysts to assist in its corporate finance activities. If an analyst comes into possession of price sensitive information, ESCL policies are designed to prevent the analyst from issuing any research for which that information would be relevant. The analysts are not permitted to disclose the nature of the information to any other departments within ESCL and may only discuss such information with other individuals who are registered with the compliance department as being insiders. Analyst remuneration It is ESCL policy that research analysts' are not compensated on the basis of their involvement in specific ESCL investment banking activities directly. |
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© Copyright 19 February 2007, Evolution Securities China Limited. All rights reserved. |
