Conflicts Policy

Keydata Investment Services Limited provide services to a wide range of clients. It is possible that one of our regulated companies, or a company with which we have an association, may from time to time have interests which conflict with clients' interests or with the duties owed to clients. These include conflicts arising between Keydata Investment Services Limited, its associates and employees on the one hand and the interests of clients on the other and also conflicts between clients themselves.

Keydata Investment Services Limited has established procedures which are designed to identify and manage such conflicts. These include organisational and administrative arrangements to safeguard the interests of clients. All personnel are aware of the Conflicts Policy and are able to refer any potential conflict to Senior Management.

Where necessary, Keydata Investment Services Limited maintains arrangements which restrict the flow of information to certain employees in order to protect clients' interests. Employees are subject to controls on their personal dealing intended to ensure that the interests of clients always have priority.

Should our procedures and controls not be sufficient to ensure that a potential conflict of interest does not damage a client's interests we may consider it appropriate to disclose the potential conflict to the client and obtain the client's formal consent to proceed. We may also decline to act in circumstances where there is risk of damage to the interests of any client.

Best Execution Policy

Keydata Investment Services Ltd determines the best possible result for its clients in terms of total consideration of the order. Keydata Investment Services Ltd only allows any other factors (e.g. speed and likelihood of execution) precedence over price and cost considerations in as far as these are instrumental in delivering the best result in terms of total consideration.