Conflicts

Overview

A conflict of interest is a situation in which someone in a position of trust has competing professional or personal interests. Such competing interests can make it difficult to fulfil his or her duties impartially. A conflict of interest may exist even if no unethical or improper act results from it.

Brewin Dolphin is committed to identifying, monitoring and managing all actual and potential conflicts of interest that can arise between us and our clients and between clients of all areas of our Group.

Our core business is our Investment Management Division, which offers investment advice, investment management and dealing services to clients.

The purpose of this document is to provide our clients with appropriate information in relation to the policies we have in place to manage conflicts of interest.

Below you will find a summary of the principal conflicts that exist in our business and the steps we take to mitigate them. If you have any questions on this summary in the first instance please raise them with your usual contact for your account. 

Employee dealing

It is usual for employees of financial institutions such as ours to undertake deals on their own behalf. We recognise that this can create a conflict with the duties owed to our clients. Therefore all of our employees and connected parties are required to comply with our Personal Account Dealing Policy which amongst other matters prohibits:

  • dealing ahead of client orders; and
  • dealing in an investment where they know, or should know, that a written recommendation, or a piece of research or analysis, in respect of that investment or any related investment is due to be published. 

Gifts and hospitality

 We take care through internal policies to ensure that gifts or hospitality our employees receive from clients, companies or other institutions are not extravagant and are designed to enhance the quality of the service we provide to our clients. Brewin Dolphin employees will not accept any gifts and or hospitality other than those considered normal in their line of business. Excessive gifts may result in a conflict of interest, something we are committed to avoiding. We maintain a register of all gifts and or hospitality, whether given or received, which is subject to Senior Manager oversight.

Inducements

We have relationships with many third parties such as product providers. We have processes in place to ensure that any fees or non-monetary benefits provided by third parties do not impair our duty to act in the best interests of you, our client.

To eliminate influence from our research our analysts are prohibited from accepting inducements in return for favourable research. 

Remuneration

The remuneration of all permanent Brewin Dolphin employees usually consists of a salary and a performance related bonus, a portion of which may be withheld and released after 3 years. Through these schemes we strive to ensure our employees remain motivated whilst at the same time ensuring the remuneration schemes do not encourage inappropriate behaviour or excessive trading. We recognise this conflict and through our monitoring mechanisms remain alert to any potential abuse. 

Investment Management Division

Business Interests and Suitability

Where we use our discretion to make investment decisions or provide any advice or recommendations, we are required to ensure that our actions are suitable for our clients.

However, we or some other person connected with us, may have an interest, relationship or arrangement that is material to the service, transaction or investment concerned. This may include matters such as:

  • the retention of commissions which we receive from a third party;
  • recommending that you buy or sell an investment in which one of our other customers has given instructions to buy or sell;
  • Money that we hold on your behalf and placed in the deposit account will earn interest which is paid gross. Any changes in interest rate will be notified on the Brewin Dolphin website;
  • Any difference between the rate of interest received by us on client money accounts and the rate paid to you is retained by us;
  • Brewin Dolphin employees are unable to act as Trustee, Executor, Director or Power of Attorney for our clients. We may allow this in exceptional circumstances subject to senior management approval.

Aggregation and Allocation

We may combine (‘aggregate’) a transaction for you and orders of other clients. Please note that when we operate in this manner, this is purely to assist in the execution of your order. The effect of aggregation may on some occasions work to your disadvantage.

If we make an application on your behalf for a new issue you should be aware that if the allocation is scaled back it will be applied pro rata across all clients. Therefore clients who have, as a result, been allocated a holding with a value of less than £1000 may be removed from the aggregated order and their allocation added back to the pool for redistribution amongst the remaining applicants. We will monitor the effectiveness and fairness of the operation of this mechanism and we reserve the right to alter the £1000 limit. 

Research

Research analysts are forbidden from managing investments on behalf of clients.

Research analysts in the Investment Management Division can manage their own accounts and they may hold stock in the companies they research, however they are prohibited from dealing against their own research recommendations. They may also hold stock in the companies they research as a result of the decisions of the Investment Manager to whom they have delegated the management of their portfolio, or for historical reasons.

Disclosure

If there is no other way of managing a conflict, or where the measures in place do not sufficiently protect your interests as a client, the conflict will be disclosed to allow you to make an informed decision on whether to continue using our service in the situation concerned.

Further information is available on request.

Give us a call

020 3201 3900

E: requests@brewin.co.uk

Aberdeen

01224 267 900

23 Rubislaw Terrace, Aberdeen, AB10 1XE

E: aberdeen@brewin.co.uk

Belfast

028 9044 6000

6th Floor, Waterfront Plaza, 8 Laganbank Road, Belfast, BT1 3LY

E: belfast@brewin.co.uk

Birmingham

0121 710 3500

9 Colmore Row, Birmingham, B3 2BJ

E: birmingham@brewin.co.uk

Bournemouth

01202 312 500

Waverley House, 115-119 Holdenhurst Road, Bournemouth BH8 8PW

E: bournemouth@brewin.co.uk

Bristol

0117 968 9500

The Paragon, Counterslip, Bristol, BS1 6BX

E: bristoloffice@brewin.co.uk

Cambridge

07900 748186

Wellington House, East Road, Cambridge, CB1 1BH

E: cambridge@brewin.co.uk

Cardiff

02920 340 100

2nd Floor, 5 Callaghan Square, Cardiff, CF10 5BT

E: cardiff@brewin.co.uk

Cheltenham

01242 577 677

2nd Floor, St James House, St James' Square, Cheltenham, GL50 3PR

E: cheltenhamoffice@brewin.co.uk

Dublin (Tilman Brewin Dolphin)

+353 (0)1 260 0080

3 Richview Office Park, Clonskeagh, Dublin 14, D14 H7R0, Ireland

E: info@tilmanbrewin.ie

Dundee

01382 317 200

31-32 City Quay, Camperdown Street, Dundee, DD1 3JA

E: dundee@brewin.co.uk

Exeter

01392 440 450

Vantage Point, Woodwater Park, Pynes Hill, Exeter EX2 5FD

E: exeter@brewin.co.uk

East Anglia

01473 267200

Fraser House, 23 Museum Street, Ipswich, IP1 1HN

E: eastanglia@brewin.co.uk

Edinburgh

0131 225 2566

Sixth Floor, Atria One, 144 Morrison Street, Edinburgh, EH3 8BR

E: edinburgh@brewin.co.uk

Glasgow

0141 221 7733

48 St. Vincent Street, Glasgow, G2 5TS

E: glasgow@brewin.co.uk

Jersey

01534 703 000

2nd Floor, Kingsgate House, 55 the Esplanade, St Helier, Jersey, JE2 3QB

E: channelisland@brewin.co.uk

Lincoln

01522 503 000

Olympic House, Doddington Road, Lincoln, LN6 3SE

E: lincoln@brewin.co.uk

Leeds

0113 245 9341

10 Wellington Place, Leeds, LS1 4AN

E: leeds.office@brewin.co.uk

London

020 3201 3900

12 Smithfield Street, London, EC1A 9LA

E: london@brewin.co.uk

Leicester

0116 242 0700

Two Colton Square, Leicester LE1 1QF

E: leicester@brewin.co.uk

Manchester

0161 839 4222

1 The Avenue, Spinningfields Square, Manchester, M3 3AP

E: manchester.office@brewin.co.uk

Marlborough

01672 519 600

Woodstock Court, Blenheim Road, Marlborough, Wiltshire, SN8 4AN

E: marlborough@brewin.co.uk

Newcastle

0191 279 7300

Time Central, Gallowgate, Newcastle upon Tyne, NE1 4SR

E: newcastle.office@brewin.co.uk

Nottingham

0115 852 5580

1st Floor, Waterfront House, Waterfront Plaza, 35 Station Street, Nottingham, NG2 3DQ

E: nottingham@brewin.co.uk

Oxford

01865 255 750

4 King Edward Street, Oxford, OX1 4HS

E: oxford@brewin.co.uk

Penrith

01768 861 710

1 Mason Court, Gillan Way, Penrith 40 Business Park, Penrith CA11 9GR

E: penrith@brewin.co.uk

Plymouth

01752 334 650

Ashleigh Court, Ashleigh Way, Langage Business Park, Plymouth, PL7 5JX

E: plymouthoffice@brewin.co.uk

Reigate

01737 223 722

45 London Road, Reigate, Surrey, RH2 9PY

E: reigate@brewin.co.uk

Shrewsbury

01743 399 000

Mutual House, Sitka Drive, Shrewsbury Business Park, Shrewsbury, Shropshire, SY2 6LG

E: shrewsbury@brewin.co.uk