It is important to identify and manage conflicts of interest which arise or may arise in the course of providing a service, as their existence may lead to a material risk of damage to a client’s interests.

Absolute Return Investment Advisers (ARIA) Ltd (“ARIA”), have initiated a Conflicts of Interest policy, to effectively manage the conflicts of interest that may arise where it provides services to clients in the course of carrying on regulated activities.

The policy is designed to fulfil obligations under SYSC 10, COBS 12 and Principle 8 of the FCA Handbook, both of which implement the Markets in Financial Instruments Directive (“MiFID”).

The policy is available on request, and is prepared and published in order to comply with the FCA Handbook Rules and is not intended to create third party rights or duties or form part of any contractual agreement between the firm and any client. The policy may be amended at any time if a material change occurs and will be reviewed in accordance with the FCA Rules at least yearly.

ARIA is a boutique investment management operation which primarily provides services which include:

  • Discretionary investment management: to retail clients (who are represented by their financial advisers), trustees, institutional and mutual collective investment schemes clients and other institutional clients (as appropriate).
  • Investment advisory services: to both regulated and unregulated collective investment schemes in the specific areas of multi asset absolute return strategies, market neutral funds, managed futures and funds of hedge funds.

ARIA may also provide execution only stock-broking, however this is not a primary business avenue and is generally only available to clients who are receiving one of the above services.

In order to achieve and demonstrate long term success in this aim, ARIA acknowledges that its clients’ interests will always take priority during the development of any investment proposition and will continue to be actively monitored during and after the launch of any new product or service.

ARIA or any Associate or any party to whom it may have delegated its functions (a “Delegate”), may without prior reference to a client, effect transactions in which ARIA or an Associate or a Delegate has, directly or indirectly, a material interest or a relationship of any description with another party, which may involve a potential conflict with ARIA’s duty to the client.

In the event of any such transaction, however, ARIA will ensure that:-

  1. such transactions are effected on normal commercial terms negotiated at arm’s length and on terms which are not materially less favourable to the client than if the potential conflict had not existed;
  2. such transactions do not adversely affect the performance of the firm’s duties and responsibilities to the client; and
  3. it takes reasonable steps to ensure fair treatment for the client in accordance with the requirements of the FCA Rules.

Treating Customers Fairly (“TCF”) is central to the core values of ARIA. There is an embedded culture that understands what acceptable and unacceptable behaviour is. As such, conflicts of interest and the identification / management / mitigation thereof are central to this philosophy and culture.

The circumstances giving rise to conflicts of interest includes all cases where there is:

  1. conflict between the interests of ARIA, an employee , certain persons directly or indirectly connected to ARIA; and the duty that ARIA owes to a client;
  2. conflict between the differing interests of two or more clients, as ARIA owes a separate duty to each of them.

ARIA has implemented processes which look to manage conflicts and ensure employees take into account whether any of the persons described at (1) above:

  1. is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
  2. has an interest in the outcome of a service provided to the client, or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;
  3. has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client;
  4. carries on the same business as the client; or
  5. receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monies, goods, services, other than the standard commission or fee for that service.

Specific potential conflicts of interest may arise within ARIA relating to clients, personal account dealing and certain private conflicts of interest. Each of these is explained in more detail within the Conflicts of Interest policy which is available on request.

ARIA Capital Management is a trading name of Absolute Return Investment Advisers (ARIA) Limited. Office: Ground Floor, 2 Bell Court, Leapale Lane, Guildford GU1 4LY. Absolute Return Investment Advisers (ARIA) Ltd is authorised and regulated by the Financial Conduct Authority.
 
The information on this site is issued by ARIA CAPITAL MANAGEMENT. ‘ARIA’ and ‘ARIA CAPITAL MANAGEMENT’ are TRADING NAMES of ABSOLUTE RETURN INVESTMENT ADVISERS (ARIA) Limited, who are authorised and regulated by the Financial Conduct Authority in the UK, with Firm Reference number 527557. A Limited Company registered in England and Wales No: 7091239. Contact Address: Ground Floor, 2 Bell Court, Leapale Lane, Guildford GU1 4LY. Telephone: +44 (0)203 137 3840 The information on this site is directed only at persons or entities in any jurisdiction or country where such access to information contained herein and use thereof is not contrary to local law or regulation. In particular, the information on this site is not directed at any person in the United States and this site is not intended to be used by any person in the United States. Accordingly, all persons who access this site are required to inform themselves of and to comply with any such restrictions. Sales Restrictions United Kingdom: there are funds referred to on this site, which are not recognised collective investment schemes for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the 'Act'). The promotion of such investment funds and the distribution of offering materials in relation to such funds in the United Kingdom are accordingly restricted by law. The information contained on the restricted part of this site (the 'Intermediary Centre') is directed only at persons to whom such investment funds may lawfully be promoted by a person authorised under the Act (an 'authorised person') by virtue of Section 238(5) of the Act and Chapter 4 (part 12) of the FCA New Conduct of Business Sourcebook. Investors in the investment funds referred to in the Restricted Area will not benefit from the rules and regulations made under the Act for the protection of investors, nor from the Financial Services Compensation Scheme. Shares in the investment funds referred to in the Intermediary Centre are not dealt in or on a recognised or designated investment exchange for the purposes of the Act, nor is there a market maker in such shares, and it may therefore be difficult for an investor to dispose of his shares otherwise than by way of redemption. General: it may be illegal to access or download the information contained in this site in certain countries and ARIA disclaims all responsibility if you access or download any information from this site in breach of any law or regulation of the country in which you are residing. Access to the Intermediary Centre requires possession of a valid password and no other person should attempt to gain access to it. An application for shares in the investment funds referred to on this site should only be made having read fully the relevant prospectus and other information contained on this site. 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FRC Stewardship Code The Stewardship Code (“the Code”), which has been published by the Financial Reporting Council, sets out principles for institutional investors in relation to engagement with the companies in which they have invested. The FCA’s regulations oblige any firm which manages investments for institutional clients to publicly disclose the nature of its commitment to the Code, or where it does not commit to the Code its alternative approach. ARIA’s investment strategy, notwithstanding that this may vary depending on the mandate received from the client, is in general such that the firm does not consider it to be appropriate for it to engage directly with companies in which it invests. The scale on which the firm manages investments for institutional clients is such that engagement would not be cost-effective and appropriate for those clients. The firm does not consider that those institutional clients for whom it manages investments expect engagement.
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