The Walker Crips Group (WCG) provides diversified financial services to a range of clients from a number of locations within the United Kingdom. These services include stockbroking, investment management, financial planning, custody and settlement services and they are delivered to clients that include individuals, private companies, and trusts. Across WCG, these services are provided by employees, account executives, agents and affiliates (Staff). It is therefore feasible that circumstances may arise whereby the interest of a client may conflict with the interests of the firm, or with those of another client. In particular, conflicts may arise between:

• the firm and a client;
• two or more clients of the firm in the context of the provision of services to those clients; and
• the personal interests of staff and a client.

Examples of conflicts that may arise between the Group, our affiliates and agents, and our clients and counterparties or between our clients are:

• Conflicts between the firms' own proprietary position and those of our clients
• Commission arrangements that may encourage Staff to advise or transact more turnover irrespective of client’s best interests
• Remuneration or incentive schemes that might encourage Staff to advise or undertake transactions irrespective of whether clients are being treated fairly
• Staff’s own dealing in investments on which we are providing advice on or dealing in for clients
• Gifts, entertainment, hospitality and other inducements could influence the staff to do business with one intermediary or one supplier over another, irrespective of clients’ interests

We take all appropriate steps to prevent conflicts of interest arising between you and the Group and its representatives and with any other client, in the course of providing services to you. Our conflicts of interest policy defines the steps that we take to identify, prevent, manage and/or disclose conflicts of interest when providing various investment and other services. These actions include the following:

• Training our employees
• Notifying the Compliance Department of Staff dealing in securities that are potentially exposed to conflicts of interest
• Reviewing transactions in securities where we have access to sensitive information
• Remuneration committee to enforce our remuneration policy and control Staff remuneration
• Requiring the disclosure and, in some cases, pre-approval, for gifts or other inducements received by Staff