Terms

This page contains information on policies and procedures for Edale UK Management Limited.

Compliance statements from Edale Uk Management including modern slavery policy can be seen at https://edale.co/statements/.

Key Information

Edale Key Information and Disclosure  

This document is issued on behalf of Edale, which is a trading name Edale UK Management of 33 Kings Avenue, Redhill, RH1 6QH whom can be contacted at 0207 99 35 360. Our principal place of business is 15 Bell Street, Reigate, RH1 6QH. This document gives you key information about us, how we work and services we provide.

Authorisation Statement

Edale UK Management Ltd is Authorised and Regulated by the Financial Conduct Authority. The Financial Conduct Authority (FCA) regulates the financial services industry in the UK and their address is 25 The North Colonnade, Canary Wharf, London, E14 5HS. You can check this on the FCA’s Register by visiting the FCA’s website http://www.fca.org.uk/ FCA No. 620437or by contacting the FCA on 0800 111 6768.

Commitment

Edale is satisfied that it has embedded the Treating Customers Fairly (TCF) values and principles into its business. A strong focus on client service and listening to our clients has always been part of our culture and our client-related processes and policies are continually reviewed and re-aligned where required.

Key indicators relating to our TCF policies are monitored regularly throughout the business. All outcomes are reviewed and considered by senior management to ensure that TCF stays firmly on our agenda and that it is part of our business as usual processes.

Client Categorisation

For the purposes of the FCA rules, we will treat you as a Retail Client unless otherwise specifically stated in writing. This classification allows you the maximum level of regulatory protection. On the basis of the information you provide on your Application Form we shall classify you as a retail client, a professional client or an eligible counterparty for the purposes of the FCA rules. We shall confirm this classification in writing to you when we confirm the opening of your account.

Communications

We will communicate with you in English both verbally and written for the sending and reception of orders. To avoid any doubt instructions should be issued in writing.

Scope of Service

We are an independent firm but provide restricted investment services and simplified advice. We provide access to Securities (Equities and Bonds) and Investment Funds (Unit Trusts and Open Ended Investment Companies) from a restricted list of recognised investment markets and product providers. We also promote specific tax-advantaged ‘wrappers’ in which these funds can be held e.g. Individual Savings Accounts (ISAs) and Self Invested Personal Pensions (SIPPs) and offshore investment-linked life policies.

Services to be provided

The services we provide you with will be in accordance with one of the following categories, which will be agreed with you when opening your account and confirmed by your signing of the relevant client agreement.

We offer two levels of service:

  • Execution only
  • Advisory

All the services are designed to provide you with choices for your ongoing advice and service. At the time that you instruct your us to implement any of the recommendations then you will be asked to select the level of ongoing service you require.

Execution only

You will not receive advice or a recommendation from us. We operate an Execution Only service. If you are in any doubt regarding the suitability of an investment you should ask to be referred to an independent financial planner, who are authorised to provide investment advice. Transactions taken out on an execution only basis via Edale will be carried out without advice on their merit or suitability. When buying a contract under these terms, you will not benefit from some of the regulatory protection provided when authorised advice is given and you have no right to redress should the contract turn out to be unsuitable.

To help guide our clients we provide web-based tools and issue product information, independent investment research, market commentary and example portfolios. In providing these we are not giving you personalised advice.

It is important that you read the Product Provider’s Key Features Document carefully and we would particularly draw your attention to the section on Cancellation and Withdrawal Rights. Please note that as you are investing as an Execution Only client your cancellation and withdrawal rights may be affected.

Advisory

With an advisory service, we accept responsibility for advising you as to the merits of any particular investment based on the information supplied by you in the application form pertaining to your individual circumstances, requirements and objectives. We may provide you with investment advice on your request. Information supplied by you, via the application form should be updated as necessary before we give you advice on a particular transaction. If you do not inform us of any investment or types of investments, which you do not wish us to recommend or purchase for you, we may recommend to you any investments provided that we have reasonable grounds for believing that each investment product we do recommend is suitable and appropriate for you, in accordance with FCA rules.

We will advise and make a recommendation for you however under this service we only offer products and services from our chosen product providers. Therefore this is defined as ‘restricted advice’ by the FCA.

Edale does not handle clients’ money. We never handle cash or accept a cheque made out to us, unless the cheque is in settlement of charges or disbursements for which we have sent you an invoice.

When we have arranged any investments or policies for which you have given us instructions we will not give you any further information unless specifically agreed.

Advice and Instructions

We prefer our clients to give us instructions in writing, to aid clarification and avoid future misunderstandings. We will, however, accept oral instructions provided they are confirmed in writing. We may, at our discretion, refuse to accept instructions although such discretion shall not be exercised unreasonably. We will record all transactions on our files which, along with copies of relevant documentation, will be retained by us for a period of not less than six years. You have a right to inspect copies of contract notes, vouchers and entries in our books or computerised records relating to your transactions. We reserve the right to withhold copies of these records if information to other parties would be disclosed.

Best execution

In transmitting investment applications on your behalf to third parties, we will take all reasonable steps to ensure that we obtain the best possible result for you. This is referred to as ‘best execution’. A copy of our best execution policy is available on www.edale.co/terms.

Paying for services

Not all firms charge for services in the same way. We will discuss your payment options with you and answer any questions you have. We will not charge you anything until you have agreed how we are to be paid.

We may charge an initial fee as permitted by the Product Provider or agreed directly with you. A Service Charge and or an Advisory Fee which is determined by the value of the funds on which the service is required. These fees are shown below:

Service Charge:

Upto 1.00% per annum Service Charge calculated and paid quarterly using the value of the fund.

Examples of the Standard Service Charge:

Value of funds £20,000 the fee is £16.66 per month / £200 per annum

Advisory Charge:

Upto 1.00% per annum Advisory Fee calculated and paid quarterly using the value of the fund.

Examples of the Standard Advisory Fee:

Value of funds £20,000 the fee is £16.66 per month / £200 per annum

In addition to the Fees above you could have charges to pay from the Funds and/or product provider. Details on the charges will be shared with you along with the Client Agreement.

Payment Options:

Paying via the product & product provider: The client agrees that the Firm can receive the Service Charge or Investment Advice Fee from the Product Provider for the full amount determined above. The amount payable will reduce or increase in line with the value of the investments. The client may be required to complete a provider instruction should the client wish to pay fees in this way.

By agreeing to this method of paying the fee, you authorise the Product provider to sell units/shares from the fund and pay Edale to satisfy the Service Charge or Advisory Fee.

Edale may, from time to time, receive fees from product providers for advertisements in the company brochure, bulletins, website or other material. The existence of an advertisement should not be taken as an endorsement of any particular product by Edale.

At the point the firm receives written confirmation that the Client no longer requires the services of Edale, the Firm will ensure that the Service Charge ceases.

The purpose of the Service Charge is intermediation whereby the Firm acts on behalf of the Client with the provider. This may include but is not limited to: – provide web-based tools and issue product information, independent investment research, market commentary and example portfolios.

Right to Cancel

We will inform you of your statutory right to cancel.

Complaints

If you wish to register a complaint, please write to The Compliance Manager, Edale, 15 Bell Street, Reigate, RH2 7AD or telephone 0207 99 35 360. If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.

Compensation Scheme

We are covered by the Financial Services Compensation scheme (FSCS) if we cannot meet our obligations. This is dependent upon the type of business and the circumstances of the claim. Most types of investment business are covered up to a maxi-mum limit of £50,000. For non-advised investment services an investor may not have access to FSCS, however, they would have access via the product provider, should the product provider default.

Conflict of interests

We will endeavour always to act in the best interests of you our client. However, circumstances can arise where we or one of our other clients may have some form of interest in business being transacted for you. If this happens or we become aware that our interests or those of one of our other clients conflict with your interests, we will write to you and obtain your consent before we carry out your instructions, and detail the steps we will take to ensure fair treatment.

Data Protection

The information you have provided is subject to the Data Protection Act 1998 (the “Act”). By doing business with Edale you con-sent to us or any company associated with us for processing, both manually and by electronic means, your personal data for the purposes of providing administration and management.

“Processing” includes obtaining, recording or holding information or data, transferring it to other companies associated with us, product providers, the Financial Conduct Authority or any other statutory, governmental or regulatory body for legitimate purposes including, where relevant, to solicitors and/or other debt collection agencies for debt collection purposes and carrying out operations on the information or data.

We may also contact you or pass your details to other companies associated with us to contact you (including by telephone and email) with details of any other similar products, promotions, or for related marketing purposes in which we think you may be interested.

If at any time you wish us or any company associated with us to cease processing your personal data or sensitive personal data, or contacting you for marketing purposes, please contact The Data Protection Officer on 0207 99 35 360 or in writing at 15 Bell Street, Reigate, RH1 6QH.

You may be assured that we and any company associated with us will treat all personal data and sensitive personal data as confidential and will not process it other than for legitimate purposes. Steps will be taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary. Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to the data.

Subject to certain exceptions, you are entitled to have access to your personal and sensitive personal data held by us. You may be charged a fee (subject to the statutory maximum) for supplying you with such data.

Cookie policy

This is the Cookie Policy for Edale UK Management Limited, accessible from https://edale.co/terms

What Are Cookies

As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the sites functionality.

For more general information on cookies see the Wikipedia article on HTTP Cookies.

How We Use Cookies

We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the this site. Therefore it is recommended that you do not disable cookies.

You can learn how to manage cookies on your web browser by following the Browser Cookies Guide.

The Cookies We Set

  • Account related cookiesIf you create an account with us then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out however in some cases they may remain afterwards to remember your site preferences when logged out.
  • Login related cookiesWe use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.
  • Email newsletters related cookiesThis site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
  • Surveys related cookiesFrom time to time we offer user surveys and questionnaires to provide you with interesting insights, helpful tools, or to understand our user base more accurately. These surveys may use cookies to remember who has already taken part in a survey or to provide you with accurate results after you change pages.
  • Forms related cookiesWhen you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
  • Site preferences cookiesIn order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.

Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

  • This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.For more information on Google Analytics cookies, see the official Google Analytics page.
  • The Google AdSense service we use to serve advertising uses a DoubleClick cookie to serve more relevant ads across the web and limit the number of times that a given ad is shown to you.For more information on Google AdSense see the official Google AdSense privacy FAQ.

More Information

Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. This Cookies Policy was created with the help of the Generator of GDPR Cookies Policy.

However if you are still looking for more information then you can contact us through one of our preferred contact methods:

  • Email: hq@edale.co
  • Phone: 02079935360

Privacy policy

Edale UK Management of 33 Kings Avenue, Redhill, RH1 6QH whom can be contacted at 0207 99 35 360 who has our principal place of business is 15 Bell Street, Reigate, RH1 6QH.hereinafter referred to as ‘Edale’ or ‘we’ have created this privacy statement (‘Statement’) in order to demonstrate our firm commitment to the privacy of the details that you provide to us when using Site and the Edale Services. In this Statement, references to ‘you’ and ‘your’ are references to the Edale User who may or may not be a registered Edale Client. When you use the Site, you are consenting to the practices set forth in this Statement.

we know that your privacy is very important to you which makes it very important to us. we aim to be as clear as possible in this Statement in respect of your Data. This Statement applies inter alia to your Data that we collect about you when you use the Site and the Edale Platform, how and when it is used, how we protect it and who has access to it. This Statement incorporates the Cookie Policy, the website Terms of Use and your relevant client agreement.

Your acceptance of the statement

This Statement governs your use of the Site and Edale Services, including any dispute concerning privacy. By using the Site and the Edale Services, you accept this Statement in full. you should read the Statement carefully and ensure that you understand its effect before proceeding to use the Site. we reserve the right to modify this Statement at any time due to a change in the law or otherwise without notice by posting the changes on this page. your continued use of any portion of the Site following the posting of the updated Statement will constitute your acceptance of the changes. If we make any material changes, we will notify you by email.

Collecting your data

As part of the process of using the Site and the Edale Services, we may collect certain data from you including but not limited to

  • your contact details upon registration to become a client including your first and last names, email address and other account details including nationality and tax identification numbers e.g. National Insurance number;
  • Information required to create your client file and login;
  • ‘Customer Due Diligence information, such as identification documents or other verification documents, as well as information in relation to or documents to evidence your source funds or wealth;
  • your visits to the Site, the resources and Edale Content that you download;
  • Information that you provide to us by written communication by post or email;
  • Information that you provide to Edale or Edale employee or affiliate;
  • Information that you provide to us when we speak to you by telephone. we may keep a record of the information that you share with us;
  • Information that you provide to us by completing surveys; and,
  • Details of investments you carry out as a Edale client through the Site and Edale Services and the information we provide to your Representative with your approval.

Other data

Other de-personalised data which does not record Personal Data as such, rather information such as the date of the visit to the Site, the path taken, the browser used, the IP address etc is used primarily to aid the technical administration of the Site, to better understand how the Site is functioning for visitors and clients and to draw conclusions upon demographic information.

How is your data used?

you acknowledge that your Data may be used by Edale to contact client by post, phone or by electronic mail when necessary in connection with Edale Services, the Edale advice process and the investment process in general.

From time to time, Edale may contact you by electronic mail by way of sending you periodic marketing emails with the latest ideas, updates, investment news and advice or any other newsletter or information or offers regarding upcoming products, promotions, services, specific events, case studies or customer surveys. we will not e-mail you for marketing purposes unless you have given us your consent to do so or if we have a legitimate interest in doing so (for example, if we already have a relationship with you as a customer and we are letting you know about a similar product to one previously purchased).

If Data has been passed to third parties with your consent, you may need to contact them separately if you change your mind in relation to their use of your Data.

In order to provide the Edale Services we may need to:

  • communicate with a Company’s owners, officers and employees (“Company’s Contacts”) in relation to the services;
  • process identification details of clients and counterparties in order to confirm their identities;
  • check such Personal Data against databases of individuals who are subject to sanctions, classified as “politically exposed persons” or have committed crimes and to follow up any suspicions to ensure that Edale complies with its anti-money laundering and terrorism obligations and to avoid fraud itself;
  • record or monitor communications as set;
  • use such Personal Data to meet the Investment Adviser’s compliance and regulatory duties; and /or
  • transfer such Personal Data outside the European Economic Area and the UK and disclose it to antifraud organisations and law enforcement or regulatory agencies anywhere in the world, and Edale will be acting as a data controller in respect of such processing.

Who has access to your data?

To minimise the risk of unauthorised access to your Data, we use some of your Data to authenticate you when using the Site. For our daily operations, we use the services of third parties to provide some of our business and operational functions. Some of these services are provided by our affliaties or partners. For the avoidance of doubt, your Data is used solely by Edale (and its group companies and the partners) for the sole purpose and to the extent necessary to enable Edale to effectively provide you with all the functionality required by the Edale Platform throughout the life of the investment process) and is not shared with any person or company without your express consent. Any Data that is held with Edale shall be retained in accordance with the Data Protection Act 1998, General Data Protection Regulation (GDPR) and related legislation and/ or our retention and destruction policy culminating in its permanent deletion.

Disclosure of your data in compliance with laws

You should be aware that we may release your Data when we believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which you transacted with Edale or a Edale Partner, or to protect the rights, property or safety of Edale, Edale Clients or third parties. This includes any requirements of the Financial Conduct Authority (“FCA”).

Transfer of your data outside of the EEA

From time to time, we may transfer your Data to a related company, agent or contractor in order to improve our services or to assist our security, credit risk or fraud protection activities. Such companies may be located outside of the EEA and you consent to the transfer of your Data to such companies for the purposes set out here in accordance with this Statement and as permitted by the Data Protection Legislation from time to time.

Transfer of data in the event of the Edale

In the event that Edale is sold or transfers some of its assets to another party, your Data could be one of the transferred assets. If your Data is transferred, its use will remain subject to this Statement. your Data will be passed on to a successor in interest in the event of a liquidation or administration of Edale.

Other sites and their Privacy Policies and Cookie Policies

The Site may contain links to other websites. Edale is not responsible for the privacy practices or the content of such websites or for the privacy policies, cookie policies and practices of other third parties, so you should be careful to read and understand those website policies independently.

Security of your data

we endeavour to take all reasonable steps to protect your Data, including the use of encryption technology. When you enter sensitive information such as bank account information, we encrypt the transmission of that information using secure socket layer technology (SSL). However, we cannot guarantee the security of any Data you disclose online. In using the Site, you accept the inherent security implications of engaging in transactions over the Internet, and you agree that you will not hold Edale responsible for any breach of security unless we have been grossly negligent or in wilful default. If you have any questions about security on our Site, you can contact us at hq@edale.co. you acknowledge that email messages sent over the internet are not encrypted and are not secure. Despite efforts to protect your Data, we cannot ensure or warrant the security of any Data you transmit to us, via, to, or from our Site. you accept that Edale cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. you transmit all such Data at your own risk.

Use of Cookies

For information about cookies and how they are used on this Site, please read our Cookie Policy.

Communications between you and Edale

we may intercept, record and/or monitor any communication(s) (including telephone calls or other electronic communications) between you and us. we may do so in order to resolve queries in the future and for the purposes of ensuring security, staff training and complying with our regulatory and legal responsibilities.

Opting out

If you do not wish to be contacted by Edale in respect of future marketing communications (excluding any mandatory communications which are a necessary part of being an Edale client which cannot be opted out of), we will give you the opportunity to unsubscribe to the receipt of such communications in every electronic mail communication that we send you.

No waiver

In the event that either you or we fail to exercise any right or remedy contained in this Statement, that does not mean that you or we (as applicable) have waived that right or remedy and so shall not be construed as a waiver.

Complaints

If you wish to register a complaint, please write to The Compliance Manager, Edale, 15 Bell Street, Reigate, RH2 7AD or telephone 0207 99 35 360. If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.

Choice of Law

This Statement shall be governed by and construed in accordance with the laws of England and Wales.

Jurisdiction

you agree to submit to the exclusive jurisdiction of the courts of England and Wales. This means that if you want to bring a legal action against us, or we want to bring a legal action against you, it must be done in one of these courts.

Best Execution


Overview
The adoption by the UK of the Markets in Financial Instruments Directive (MiFID), a European directive which aims to harmonise the operation of financial markets across Europe, requires that we provide clients with information concerning our execution policies in respect of transactions we undertake on your behalf.
The overriding requirement is that we must take all reasonable steps to
obtain the best possible result, taking into account the following:
• Price
• Cost
• Speed
• Likelihood of execution
• Settlement, size
• Nature
• Any other consideration relevant to the execution of the order

Order Execution
For retail clients price will normally be the most important aspect in obtaining the best possible result. EDALE will therefore assume that the best available price is the most important outcome for your transaction unless you specify at the time of dealing that another factor is of greater importance.
In some circumstances, for some clients, orders, financial instruments or markets, we may determine that other Execution Factors are more important than price in obtaining the best possible execution result.

We will determine the relative importance of the Execution Factors by using our commercial judgement, experience in the context of market conditions and information available to us, and taking into account the Execution Criteria.

EDALE will take all reasonable steps based on those resources available to us to satisfy ourselves that we have processes in place that can reasonably be expected to lead to the delivery of best execution of your orders, we cannot guarantee that we will always be able to provide best execution of every order executed on your behalf.
In executing your order we:
• May use a third party broker to execute your order;
• Will not trade as Principal
• May trade as agent.

Execution Venues
The execution venues we may use will be Regulated Markets including the London Stock Exchange and Plus markets plc, Multilateral Trading Facilities (MTF) and Retail Service Providers (RSP). However we reserve the right to use other venues if the nature of the order requires us to do so.
Generally orders will be executed where possible via the RSP network and our systems will poll for the venue that is providing the best price at that time. If the order falls outside certain size criteria set by the RSPs then the order may need to be dealt over the telephone and will be executed on the venue that provides the best overall result.
All the above orders will be deemed as executed ‘on exchange’ and will be reported as required to a regulated exchange.
To the best of our ability we will not execute transactions in shares that are capable of being executed on a Regulated market or MTF, away from these venues. However you hereby accept that in certain circumstances it may be necessary for us to do so. These transactions are known as Over The Counter (OTC) trades.
Where available we may cross a client’s order with that of another opposing client.

Dealing in Collective Investment Schemes
When we deal in collective investment schemes (Unit Trusts and OEICs) we will deal directly with the fund manager. Unit trust and OEIC providers generally calculate their prices once a day (in accordance with FCA regulations).

Use of Third Parties
Our terms and conditions with our counterparties provide that they will make all reasonable efforts to provide best execution when we instruct transactions through them.

Specific Instructions
If a client provides us with a specific instruction to deal for them it may prevent us from following our Order Execution Policy which is designed to get the best overall result for the execution of orders on a consistent basis.

Limit Orders
Clients will be able to place limit orders in the market only. These orders will either be left with the market to execute and will be ‘good for the day’ or will be placed on an electronic trading facility of the Regulated Market.

Monitoring & Review
Edale regularly reviews its Order Execution Policy and may add to or remove the venues where we execute our trades without reference to you. Full Details of the execution venues currently employed by us will be made available upon request.

Conflicts Policy

Edale UK Management (Edale)is required  by the Markets in Financial Instruments Directive (MiFID) which has been adopted into UK legislation, to provide you with a summary of our arrangements to manage our Conflicts of Interest, should they arise.

We are therefore required to:

Take all reasonable steps to identify conflicts of interest between (i) EDALE or a linked entity and its clients or (ii) one client and another.

Maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps designed to prevent conflicts of interest from constituting or giving rise to a material risk of damage to the interests of our clients.

Where GHC produces “externally facing” investment research, put in place appropriate information controls.

Disclose the general nature and/or the sources of the conflicts of interest for the client, where the arrangements to manage a conflict of interest are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interests of a client will be prevented.

Identification of Conflicts

When identifying potential conflicts of interest, EDALE will take into account whether the firm or an employee:

  • Is likely to make a financial gain, or avoid a loss, at the expense of the client.
  • 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.
  • Has a financial or other incentive to favour the interests of another client or group of clients over the interests of the client.
  • Carries on the same business as the client.
  • 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 or services, other than the standard commission or fee for that service.

Management of Conflicts

Edale maintains a number of policies and procedures, which includes a documented policy of independence, which applies whenever its employees provide advice to any of our customers or recommends a transaction. This requires employees to disregard any interest in the transaction that they or EDALE may have, in order to ensure that our clients are given suitable advice.

We also maintain physical separation between various group companies.

Where it is not practical to effectively manage such conflicts we ensure that they are properly disclosed to customers, and we will decline to act for customers should it be necessary.

Chinese Walls

These are the arrangements we have in place to restrict access to information held in one part of the business from employees in other departments. Our Chinese Wall Procedures sets out in detail the restrictions that are in place to restrict, control and manage the flow of information between group connected companies.

This includes physical restriction on the staff allowed access to certain parts of the organisation, and includes restrictions on access to the data held within various group companies, divisions or departments. The procedures dictate that those staff who are required to be involved in any transaction will be privy to information or ‘brought over the Chinese Wall’. All staff are prohibited from disclosing information except as detailed in the procedures.

General Issues

Personal Account Dealing

Personal Account Dealing by EDALE personnel must be in strict compliance with our policies and procedures to ensure adherence with all relevant regulation and legislation, both for the benefit of clients and the protection of employees. The procedures are to ensure that employees’ interests do

not conflict with those of our clients and adherence with these is strictly monitored.

Remuneration Policy

EDALE remuneration policies are designed to reflect employees experience and performance, balanced with the requirement to ensure that their remuneration does not conflict with their obligations to our clients. Where employees’ remuneration reflects an element of commission received for transactions undertaken for clients, procedures are in place to monitor the suitability of their recommendations.

Inducements/gifts

The giving or receiving of gifts or other inducements may compromise or conflict with the recipient’s obligations to his clients. Therefore employees are required to comply with our strict policy regarding the reporting and approval of all gifts and hospitality.

Outside Interests

Employees are required to notify the company of any outside interest. Any disclosed outside interests will be reviewed by the Head of Compliance and if necessary reported to the CEO who will consider the potential for conflicts of interest before permitting the continuance of any such outside interest.

Review

All policies and procedures for identification and management of conflicts of interest are, as a minimum, subject to annual review and any significant issues will be reported to the Management Executive Committee and to the Board as necessary.

Risk Statements

The risks listed below are the main risks to your investment, fund or mandate (the “Portfolio”).

Investors should be aware that other risks may also be relevant to this Portfolio from time to time.

General

This section explains some of the risks that apply to the Portfolio. It does not purport to be a complete explanation and other risks may also be relevant from time to time. In particular, the Portfolio’s performance may be affected by changes in market and/or economic and political conditions, and in legal, regulatory and tax requirements. No guarantee or representation is made that the investment program will be successful and there can be no assurance that the Guidelines will be attained. Also, past performance is no guide to future performance, and the value of investments may go down as well as up. Changes in rates of exchange between currencies may cause the value of a Portfolio’s investments to diminish or increase.

Edale or Portfolio’s may be exposed to operational risks, being the risk that operational processes, including those related to the safekeeping of assets, valuation and transaction processing may fail, resulting in losses. Potential causes of failure may arise from human errors, physical and electronic system failures and other business execution risks as well as external events.