Conflicts Policy

The information in this website has been obtained from sources which are believed to be reliable. However, no representation or warranty either express or implied is made nor is responsibility of any kind accepted either as to the accuracy or completeness of any information stated therein or that material facts have not been omitted, or for any loss or damage consequent on action taken in reliance on the information contained herein. In addition, Allenby Capital is not responsible for the accuracy of information contained within sites provided by third parties, which may have links to or from these web pages.

The information on the web pages is subject to change without notice. These pages do not purport to give investment legal, tax or other advice and are not to be relied on in making an investment or other decision. This site should not be regarded as an offer or solicitation, or recommendation to conduct investment business, as defined by the Financial Services and Markets Act 2000, in any jurisdiction other than the United Kingdom. Investors who are resident in or citizens of countries other than the United Kingdom may be subject to local restrictions.

The investments and investment services referred to on this site may not be suitable for all investors and if in doubt visitors should seek independent financial advice, including the tax consequences in respect of any proposed course of action, before making any investment decision. Visitors should also be aware that the value and income of any securities or investments and the price of shares and the income derived from them, which are mentioned on this site, may fall as well as rise. Past performance is not necessarily a guide to future returns.

Policy:

Allenby Capital’s business model does not enable it to hold out its research as being impartial, and it should not be viewed or relied upon as wholly objective. However, in accordance with FCA’s Statements of Principle, we endeavour at all times to ensure that our research produced is to a high standard, and is fair, clear and not misleading.

Where potential conflicts are recognised, these are fully disclosed and managed so as to minimize any threat to the objectivity of our research. In this context, Allenby Capital pays particularly close attention to the following of FCA’s Statements of Principle:

Principle 1: A firm must conduct its business with integrity.
Principle 2: A firm must conduct its business with due skill, care and diligence.
Principle 3: A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.
Principle 5: A firm must observe proper standards of market conduct.
Principle 6: A firm must pay due regard to the interests of its customers and treat them fairly.
Principle 7: A firm must pay due regard to the information needs of its clients, and communicate information to them in a way that is clear, fair and not misleading.
Principle 8: A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.

Application:

Responsibility
The Board of Allenby Capital is responsible for ensuring that its systems, controls and procedures are able to identify, manage and control the potential conflicts of interest that may arise.
Taking into account Allenby Capital’s size, scope of business, client base, the nature of the research produced and its intended audience, the Board is confident that it effectively implements its Conflicts Management Policy, and that the potential conflicts of interest inherent in the publication of its research are properly managed in the manner set out below.

Systems And Controls
Conflicts of interest arise in a variety of ways. For example, between the personal interests of the researcher, the company being written about and between clients of Allenby Capital and Allenby Capital itself. Even where there is no actual conflict of interest, it may appear to third parties that a conflict does exist. In order to identify and properly manage potential conflicts of interest, Allenby Capital has detailed internal controls and procedures, including those summarised below:

  • Policy of Independence.
  • Policy of full disclosure of material interest.
  • Detailed Chinese Walls procedures.
  • Policies and procedures regarding Treating Customers Fairly.
  • Personal Account dealing polices and procedures.
  • Rigorous Compliance Monitoring policies and procedures.
Analysts Role
The primary role of Allenby Capital’s Analysts is to produce company research which provides the analyst's view on the company’s performance, the company’s prospects and it may also contain valuation analysis.

The role of the Corporate Finance and Institutional Sales Analysts is to assist in soliciting for and retaining Corporate Finance or Corporate Broking business by participating in pitches to current or prospective clients, and screening of potential corporate finance clients or potential deals as part of the due diligence process.

Involvement Of Analysts In Other Activities
The Corporate Finance and Institutional Sales Analysts may attend road shows, or meetings between investors, investment clients and corporate finance and broking clients, in order to answer questions or provide advice to corporate clients regarding aspects of a proposed transaction.

Supervision And Management Of Analysts
The Analysts are based in the Institutional Sales and Corporate Finance departments, which are physically segregated from each other and the rest of the company. The Analysts report to their respective heads of department who in turn report directly to the Chief Executive.

Means And Timing Of Publication of Research
Research is published in electronic format and also issued in hardcopy. Internal procedures are designed to ensure that there is no breach of Chinese Walls.

Where Allenby Capital is acting on behalf of a company in a corporate capacity, the Analysts will not publish pre-transaction research within an agreed time frame, or such other period as agreed with Compliance, prior to an IPO or Secondary Issue where an Admission Document, prospectus or Information Memorandum is prepared, except where such research is intended solely for distribution to market counterparties, and is appropriate caveated.

Editorial Control
The departmental heads may initiate or request investment research coverage, but the Analysts are solely responsible for the content and recommendations.

Inducements
Allenby Capital has a strict Gifts and Entertainment policy, which, amongst other things, requires that all gifts and invitations be cleared through Compliance, and specifically prohibits Analysts and employees from soliciting or accepting any inducement to provide favourable research.

Issuer Paid Research
Allenby Capital does issue paid-for research.
 



Pillar III Disclosure
Allenby Capital Limited (“Allenby” or ‘the Company’) is authorised and regulated by the Financial Conduct Authority (“FCA”). Allenby is a IFPRU 50k limited licence firm. The disclosures in this document relate to the business of Allenby for the purposes of reporting to the FCA. The FCA is responsible for the implementation of the EU Capital Requirements Directive, which sets the regulatory capital framework for the financial services industry in Europe. The CRD framework consists of three pillars:

Pillar 1 specifies the minimum amount of capital that a financial services firm is required to maintain to support its business;

Pillar 2 requires the firm to assess the need to hold additional capital in respect of any risks not adequately covered under Pillar 1;

Pillar 3 specifies the disclosures which the firm is required to make to enable market participants to assess information about its capital, its risk exposures and its risk assessment processes.

The information in this document has not been independently audited, does not constitute any form of financial statement, and must not be relied upon in making any judgment on the Company.

The Company makes Pillar 3 disclosures at least annually, and these are published on the Company’s website.

Business Structure
Allenby is a corporate finance firm, AIM Nominated Adviser and broker.

Clients are retail (corporate finance advice only), professional and eligible counterparties.

Allenby seeks to mitigate risk by implementing sound systems & controls and with good corporate governance.

Statement of Risk Appetite
The Company’s Board determines its risk appetite, reviews its risk profile against that appetite and documents this at least annually as and when the ICAAP is updated or amended.

The Company’s overall risk appetite can be expressed as low for ongoing and mature business processes and medium low for the business areas that are either subject to significant unanticipated change or the development of new business processes.

The majority of the Company’s clients are advisory and as such, its risk appetite in terms of balance sheet is essentially low,

Risk Management
Allenby has adopted and refined a risk management methodology and process which continues to embed within the Company. Coupled with the Company’s governance arrangements, the risk management procedures are considered appropriate to the size, nature and complexity of Allenby.

Central to the ongoing process of managing risks within the Company is the apportionment of the key risks to senior management. The ongoing monitoring of the risks is carried out through monitoring by members of the Board and senior management and are reported to the Board for consideration and action.
The Board continues to review the most appropriate processes for management information that will support a robust risk and loss reporting process,.
Allenby considers the following risk categories to be the most significant in relation to its business:

Credit Risk
Credit risk is the current or prospective risk to earnings and capital arising from an obligor’s failure to meet the terms of any contract with the institution or its failure to perform as agreed.

Allenby’s exposure to this risk category relates to fees accrued or invoiced but not received.

Operational Risk
Operational risk can be defined as the risk of loss resulting from inadequate or failed internal processes, people and systems or from external events. For operational risk measurements purposes, this definition includes legal/compliance risk/ financial crime risks, which is the risk of loss resulting from a failure to comply with laws, contractual obligations and prudent ethical standards. The definition also includes the exposure to litigation from all aspects of the firm’s activities.

Reputational risk will be treated as a consequential risk arising from the crystallisation of other risks, rather than be treated as an independent risk. As such, reputational risk is also covered under operational risk.

Allenby seeks to mitigate operational risk to acceptable residual levels, in accordance with its risk appetite, by maintaining a strong controls environment.
In assessing operational risk under Pillar 2, consideration was given to each of the areas where risk arises through the development of a Risk Matrix. The Risk Matrix identifies that the major risks Allenby is exposed to are:
 
* Systems failure
* Loss of clients
* Client dissatisfaction
* Non compliance with rules and regulations
* Damage to reputation. 

However the Firm has appropriate mitigants in place to ensure that the impact of these risks are, wherever possible, factored down to an insignificant level. The Firm has assessed the impact of loss of clients and revenues in establishing its Pillar I and II capital requirements.  The Firm benefits from a Board which is attentive to a changing market place and relevant conduct of business compliance issues.
 
Allenby is only prepared to accept low risk in relation to its clients, reputation and capital requirements.
 
Accordingly Allenby has been assessed as having a low risk profile overall.

Assessment of the Adequacy of Capital
Capital Resources

At 31 December 2016 the capital resources of Allenby comprise:

Tier 1 Capital          £1,618k
Deductions             £0
 
Tier 2 Capital         £0
Deductions            £0
 
Tier 3 Capital        £0
Deductions           £0
  
Total Capital resources before and after deductions £1,618k

Capital Requirement
As at 31 December 2016, Allenby Capital's Pillar I and Pillar II capital requirement was £840,000k. This had been determined by reference to the sum of the Company’s three month fixed overhead expenditure, which exceeded the Company’s base capital requirement of €50,000.

Satisfaction of capital requirements
The Company’s approach to assessing the adequacy of its internal capital to support its current and future activities is documented in its ICAAP, which includes an assessment of the key risks to which the Company is exposed and details the internal controls which exist to mitigate those risks. This is then stress tested against the various scenarios.

Since the Individual Capital Guidance, the ICAAP process has not identified additional capital to be held over and above this and hence the capital resources denoted above are considered adequate to continue to finance the Company over the next year.

Remuneration policy
Allenby Capital has an established a Remuneration Committee comprising the Chairman and the Non-Executive Director, which meets regularly to consider remuneration policy and human resources issues.

Allenby Capital aims to pay employees bonuses which are in general based on a cautious proportion of profits to ensure that such payments are affordable and that suitable levels of capital resources are maintained by the Company. Allenby Capital is subject to the Financial Conduct Authority's Remuneration Code and is categorised as a Tier 3 firm for the purposes of that code.

Analysts’ remuneration is determined solely by the directors of the Allenby Capital and is not tied to investment banking transactions performed by Allenby Capital.

Aggregate quantitative information on remuneration
Allenby operates as one business unit and hence the disclosures below relate to the company as a whole.
 
Allenby Capital Limited – Total remuneration in respect of the year ended 31st December 2016 - £2,222,000
Number of staff - 29
Fixed Remuneration - £1,971,000
Variable Remuneration - £251,000