Conflicts of Interest

Purpose

This policy sets out RBIM Investment Management’s approach to identifying, preventing, and managing conflicts of interest to ensure that we consistently act in the best interests of our clients. In accordance with FCA Principle 8, SYSC 10, the MIFIDPRU Remuneration Code, and the Consumer Duty, RBIM is committed to:

Treating all clients fairly and consistently.
Managing conflicts that may arise between: RBIM and its clients; One client and another; RBIM’s employees and clients.
Maintaining a culture of integrity, transparency, and accountability.

Identification of Conflicts

RBIM identifies potential conflicts of interest that may arise where RBIM or a related person:

Could derive a financial gain at the expense of a client.
Holds a competing interest in the outcome of a service provided to a client.
Receives an inducement from a third party (including gifts, fees, or commissions).
Is in a position to favour one client over another.
Participates in both product development and pricing decisions.

We also consider conflicts arising from RBIM’s ownership structure and relationships with other businesses, including Rothesay Bennett Financial Planning.

Key Areas of Conflict

RBIM recognises that conflicts of interest may occur in several core areas of its operations, including but not limited to:

Personal Account Dealing

Employees must obtain prior approval before undertaking personal investments and are strictly prohibited from using confidential client or firm information for personal gain.

Gifts and Inducements

All gifts, hospitality, or inducements must be declared and recorded. RBIM does not permit any benefit that could impair objective decision-making or create undue influence.

Client Orders and Execution

While RBIM provides trading instructions, execution is carried out by authorised platforms. RBIM does not hold client money or act as an execution venue, thereby reducing conflicts relating to trade timing and allocation.

Segregation of Duties

Internal controls ensure that no individual can complete end-to-end functions without appropriate oversight. This supports accuracy and mitigates the risk of misuse or error.

Group Structure and Common Ownership

RBIM operates under common ownership with Rothesay Bennett Financial Planning, a separate entity. Although RBIM maintains its own regulatory permissions, governance, and discretion, shared ownership presents a potential source of conflict. To mitigate this: RBIM retains full autonomy over investment decisions; Any resource-sharing is conducted on arm’s-length commercial terms; Material connections are disclosed to clients where relevant.

Management of Conflicts

RBIM employs a combination of measures to manage conflicts effectively:

Structural Controls: Segregation of functions, hierarchical oversight.
Procedural Controls: Staff declarations, approval processes, and maintenance of registers.
Information Barriers: ‘Chinese Walls’ to restrict the flow of sensitive information.
Disclosure: Where a material conflict remains, RBIM provides clear, written disclosure to the client and seeks informed consent before proceeding.

Where a conflict cannot be adequately managed or mitigated, RBIM reserves the right to decline to act.

Disclosure

If a conflict cannot be avoided or sufficiently mitigated, RBIM will disclose to the client:

The nature and source of the conflict.
The steps taken to manage it.
The potential impact on the client’s interests.
The client’s option to proceed or withdraw.

This disclosure will be provided in writing, and the client’s informed consent will be obtained prior to continuing.

Review and Governance

This policy is reviewed at least annually or following any material changes to RBIM’s business or applicable regulation.
All employees receive annual training on this policy and must confirm their understanding.
RBIM’s senior management is responsible for oversight, review, and ongoing compliance.

Additional Governance Measures

Conflicts of Interest Register: RBIM maintains a comprehensive register documenting all identified conflicts and the actions taken to manage or mitigate them.
Monitoring and Testing: Periodic compliance reviews and audits are conducted to ensure that controls remain effective and up to date.
Escalation Procedures: Any unresolved or significant conflicts are escalated promptly to senior management and the Compliance Officer for resolution.
Client Communication Standards: Disclosures are issued promptly, with clear timelines for obtaining client consent before proceeding.
Whistleblowing Mechanism: RBIM provides a confidential channel for employees to report potential conflicts or breaches without fear of retaliation.

Contact

For further information regarding RBIM’s management of conflicts of interest, please contact:

RBIM Investment Management

287/289 Kenilworth Road, Balsall Common, CV7 7EL

Email: mail@rbim.co.uk