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The following processes regarding relationships with clients are strictly observed:
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New Client Acceptance:
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To be signed off by the Executive Director, following investigation.
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Conflicts of Interest:
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Acceptance of a new client operating in the same industry sector as an existing client to be withheld without the express written permission of the existing client. No new project to be accepted that could conflict with any outstanding project.
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Client Resignation:
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On receipt of evidence of a client not abiding by a proper code of conduct, to be signed off by the Executive Director.
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Funds Handling:
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No funds, other than the receipt of fees against invoice, to be accepted at any time.
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Money Laundering:
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At no time will employees give advice on, or in any way be involved in, schemes aimed at effecting money laundering. Any client soliciting such advice is to be reported to the FSA and the assignment resigned forthwith.
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Securities Transactions:
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- No execution of securities for the benefit of a third party to be handled at any time.
- No execution of securities representing a cumulative position of more that 5% of any company’s stock; or for any percentage of a company if for a value in excess of £25,000; or for any amount if for a stock on a Restricted List to be executed without the prior express written permission of the Executive Director.
- No shorting of a client’s stock to be undertaken at any time.
- All executions of clients’ securities to be undertaken as if the employee were a director of the client - i.e. prior written permission from the client company’s Secretary; no dealings in closed periods, etc
Clients, for this purpose, are all clients listed on the quarterly report to the FSA, and any new clients acquired by the employee in the period since then.
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Confidentiality:
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Best efforts must be taken to keep confidential client information confidential so as to eliminate any risk of insider trading by a third party.
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