Punter Southall Financial Management
Conflicts of Interest Policy

What is a conflict of interest?

A conflict of interest may exist, or be perceived to exist, if an employee’s activity is, or may reasonably give the appearance of being, inconsistent with the best interests our client or clients.

If such a situation arises, we pay due regard to the interests of each client and manage any potential conflicts of interests accordingly. 

The underlying principle we follow at all times is that the interests of a client must always be put before the interests of the firm and/or its employees. 

Types of conflicts

1) PSFM (or an employee of PSFM) makes a financial gain, or avoids a financial loss, at the expense of a client;

2) PSFM (or an employee of PSFM) has an interest in the outcome of a service provided to a client, or of a transaction carried out on behalf of a client, which is distinct from our client’s interest in that outcome;

3) PSFM (or an employee of PSFM) has a financial or other incentive to favour the interest of another client or group of clients over the interest of our client;

4) PSFM (or an employee of PSFM) carries on the same business as a client; or

5) PSFM (or an employee of PSFM) receives or will receive from a person other than our client an inducement in relation to a service provided to our client, in the form of monies, goods or services, other than the standard commission or fee for that service.

Recording and responding to conflicts of interest

Our senior management takes seriously any potential conflicts of interest. All identified significant issues concerning conflicts are recorded and reviewed at Board level. We undertake a number of activities and provide a number of procedures where there is a risk that the interests of one or more clients could be compromised.

Recommending Psigma Investment Management Discretionary Management Service or Managed Portfolio Service

Although wholly separate businesses in their own right, Psigma Investment Management and PSFM Ltd reside within in the same wider Group of companies (Punter Southall Group).

Before we would recommend Discretionary Fund Management (DFM) or a Managed Portfolio Service (MPS) to a client, we ensure that it is suitable for their circumstances and fits in with their investment objectives and realistic risk tolerance in accordance with the PSFM Conflicts of Interest procedures. 

Psigma’s DFM and MPS services is only recommended by PSFM where it is the most appropriate provider of either of these services to meet the client’s needs and objectives and where the client’s circumstances deem that DFM/MPS is appropriate. 

We ensure that clients are aware of the relationship between Psigma and PSFM prior to the arrangement of the transaction. We record this procedure in the relevant client files and also confirm this with them in a clear, fair and not misleading manner within the suitability report.

Recommending the PSFM SIPP or PSFM Simple SIPP

Although wholly separate businesses in their own right, PSFM SIPP Limited and PSFM Ltd reside within in the same wider Group of companies (Punter Southall Group).

PSFM SIPP Limited’s SIPP or Simple SIPP is only recommended where it is the most appropriate provider of this service to meet the client’s needs and objectives.

We ensure that clients are aware of the relationship between PSFM SIPP Limited and PSFM prior to the arrangement of the transaction. We record this procedure in the relevant client files and also confirm this with them in a clear, fair and not misleading manner within the suitability report.

Ethics

All employees of PSFM Limited conduct business in an honest and ethical manner and adhere to the Anti- Bribery and Corruption policy at all times. We take a zero tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

Personal Account Dealing

The firm’s ‘Personal Account’ Dealing Rules prohibit any of our employees from dealing in or holding securities, or their derivatives, in any company for whom PSFM acts as an adviser.

Disclosure to the client

If a conflict of interest is found, PSFM would clearly disclose the general nature and source of the conflict of interest to our client before undertaking business for them. The disclosure would be made in writing and include sufficient detail to enable the client to take an informed decision about the service in the context of which the conflict has arisen.

Our firewalls

Information and data held by PSFM is not disclosed to any other businesses within the Group (Punter Southall Group) except with the expressed consent or direction from a client. 

Declining to provide the service

If it is not possible to avoid or manage a conflict of interest, we may have to decline a service that has been requested by a client.

Review

We will review this Conflict of Interest Policy at least annually, and where appropriate, on an ad hoc basis, to ensure it adequately reflects the types of conflicts that may arise and how we manage those conflicts.