Silo Conflicts of Interest Policy
30/04/2019
This document describes the conflicts and potential conflicts that may arise during the course of our business and how we avoid or manage those conflicts.
Where we do not have conflicts
Proprietary Trading: We do not trade for our own account, so we do not have conflicts which would result from proprietary trading. The only assets that are held on behalf of the firm are within an error account, which is used only to correct any dealing errors that may arise during the course of business for clients.
Corporate Finance: We do not operate a corporate finance function and therefore we do not have any conflicts which would result from offering such services to corporate clients.
Own Funds (Collective Investment Schemes): We do not operate our own funds, therefore all investment recommendations will be free from bias and based upon what is suitable and in the best interests of our clients.
Where we could have conflicts
Conflicts may arise:
- During the production or publication of Investment Research
- When we act for multiple clients
- Where our employees are in receipt of gifts or hospitality from clients, suppliers or business contacts
- Where our employees have outside business interests
- Where our employees trade for their own account
- In how we charge clients
- Where we receive complaints about our service
We seek to manage these in the following ways:
Investment Research
Silo is part of the Killik & Co group and shares business premises and staff with Killik & Co. The research that Silo relies upon is generated from within the Killik & Co Research Department.
The Killik & Co Research Team operates in a manner that seeks to ensure the objectivity and independence of its research. The avoidance of potential conflicts of interest is a key consideration, so operational structures and procedures, password-controlled access to part of our systems and the clear independence of roles and responsibilities of the Research Team from other parts of the business that may receive the research, are all designed to work towards preventing any conflicts arising in the first place. Research analysts do not receive, directly or indirectly, remuneration in exchange for expressing any opinion or recommendations in their reports.
Please refer to the Killik Research Policy for how, as a Group, we mitigate and manage potential conflicts arising out of our Research function.
Multiple clients
There may be times where the actions of one client conflict with the actions of another. We operate a best execution policy which ensures that all orders are dealt with sequentially and without bias.
Gifts and Corporate Hospitality
It is the policy of the firm that staff may not accept a gift that is lavish or disproportionate. Where our staff are offered gifts or hospitality from suppliers or business contacts, there must be a clear benefit to our clients in them accepting the gift or hospitality. If there is no client benefit, the gift/hospitality will be declined.
From time to time within the Killik & Co group we sponsor Barbarians rugby matches and host other events for the purpose of raising brand awareness and strengthening relationships with clients. We do not consider that this gives rise to any conflicts of interest.
All gifts and hospitality received by staff must be notified to and logged by the Compliance Department.
Outside Business Interests
There may be situations where our staff operate their own business in addition to the role they carry out for us. We require all staff to disclose any such interests to us and restrict any that may conflict with their work at Silo.
Personal account dealing
Our staff may operate their own personal dealing account subject to the Killik & Co group policy. This policy includes restrictions for certain staff and post trade review of trades by the Compliance Department to check for any potential conflicts with client orders and to take action to remove any disadvantage to clients where a conflict is identified.
Our staff are able to set up a personal Silo account, and where they do they will be treated exactly the same as any other client. There are no preferential dealing dates or investment selections for staff that could give rise to a conflict.
Charges
At Silo we believe that the way we charge for our services is aligned with the interests of our clients. The more clients save or invest and the better their investments perform, the greater the revenue we generate. We do not charge transaction fees, so there is no incentive for us to ‘churn’ accounts (that is undertake transactions at excessive frequency in order to generate commission). We do not receive any payments from the fund managers of the funds that we invest in or from any other third parties. Our revenue is derived from any interest earned on cash balances saved by our clients and the transparent charges that clients pay for Silo.
Complaints
Complaints made to us that cannot be resolved by the third business day after receipt enter our formal complaints procedure. This procedure is designed to ensure the fair treatment of clients. Complaints are investigated by the Compliance department, which is likely to be distanced from the department/individual/process from which the complaint derives. The Compliance Department aims to treat each case fairly, competently and consistently.
If you would like to talk to us about this policy, our team would be delighted to help. Please contact us at [email protected]
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