Order Execution Policy
Conflicts of Interest Policy
Optiva analysis reports are marketing communications under the rules of the Financial Conduct Authority (“FCA”). They have not been prepared in accordance with legal requirements designed to promote the independence of investment research and are not subject to any prohibition on dealing ahead of the dissemination of investment research.
These analysis reports, which present the Optiva’s research department’s view, cannot be regarded as “investment research” in accordance with the FCA definition. The contents are based upon sources of information believed to be reliable but no warranty or representation, expressed or implied, is given as to their accuracy or completeness. Any opinion reflects Optiva’s judgement at the date of publication and neither Optiva, nor any of its affiliated or associated companies, nor any of their directors or employees accepts any responsibility in respect of the information or recommendations contained therein which, moreover, are subject to change without notice. Optiva accepts no liability whatsoever (in negligence or otherwise) for any loss howsoever arising from any use of these analysis reports or their contents or otherwise arising in connection with these reports (except in respect of wilful default and to the extent that any such liability cannot be excluded by the applicable law).
These analysis reports are confidential and are supplied solely for the recipient’s information. They must not be copied or re-distributed to another person / organisation without Optiva’s prior written consent.
These analysis reports are not a personal recommendation, offer, or a solicitation, to buy or sell any investment referred to in the report. The material is general information intended for recipients who understand the risks associated with investment. They do not take account of whether an investment, course of action, or associated risks are suitable for the recipient.
Optiva manages its conflicts in accordance with its conflict management policy. For example, Optiva may provide services (including corporate finance advice) where the flow of information is restricted by a Chinese Wall. Accordingly, information may be available to Optiva that is not reflected in an analysis report. Optiva and its affiliated or associated companies may have acted upon or used research recommendations before they have been published.
These analysis reports are approved and issued by Optiva for publication only to UK persons who are authorised persons under the Financial Services and Markets Act 2000 and to professional clients, as defined by Directive 2004/39/EC as set out in the rules of the Financial Conduct Authority. Retail clients (as defined by rules of the FCA) must not rely on these reports.
Optiva may act as a broker, joint broker, placing agent or corporate adviser to the Companies the subject of these analysis reports. Optiva’s private and institutional clients may hold shares in these Companies.
These analysis reports are produced by Optiva independently of the Company the subject of the report. Opinions and estimates in these reports are entirely those of Optiva as part of its internal research activity. Optiva has no authority whatsoever to make any representation or warranty on behalf of the Company the subject of the report.
NEITHER THESE ANALYSIS REPORTS NOR ANY COPY OF THEM MAY BE TAKEN OR TRANSMITTED INTO THE UNITED STATES OF AMERICA, OR DISTRIBUTED, DIRECTLY OR INDIRECTLY, IN THE UNITED STATES OF AMERICA OR TO ANY US PERSON AS DEFINED IN REGULATION S UNDER THE UNITED STATES SECURITIES ACT OF 1933. ANY FAILURE TO COMPLY WITH THIS RESTRICTION MAY CONSTITUTE A VIOLATION OF UNITED STATES SECURITIES LAWS.
NEITHER THESE ANALYSIS REPORTS NOR ANY COPY OF THEM MAY BE TAKEN OR TRANSMITTED INTO CANADA OR DISTRIBUTED IN CANADA OR TO ANY INDIVIDUAL OUTSIDE CANADA WHO IS A RESIDENT OF CANADA, EXCEPT IN COMPLIANCE WITH APPLICABLE CANADIAN SECURITIES LAWS.
NEITHER THESE ANALYSIS REPORTS NOR ANY COPY OF THEM MAY BE TAKEN OR TRANSMITTED INTO AUSTRALIA OR DISTRIBUTED IN AUSTRALIA OR TO ANY RESIDENT THEREOF EXCEPT IN COMPLIANCE WITH APPLICABLE AUSTRALIAN SECURITIES LAWS. ANY FAILURE TO COMPLY WITH THIS RESTRICTION MAY CONSTITUTE A VIOLATION OF AUSTRALIAN SECURITIES LAWS.
NEITHER THESE ANALYSIS REPORTS NOR ANY COPY OF THEM MAY BE TAKEN OR TRANSMITTED INTO OR DISTRIBUTED INTO JAPAN OR TO ANY RESIDENT THEREOF FOR THE PURPOSE OF SOLICITATION OR SUBSCRIPTION OR OFFER FOR SALE OF ANY SECURITIES. ANY FAILURE TO COMPLY WITH THIS RESTRICTION MAY CONSTITUTE A VIOLATION OF JAPANESE SECURITIES LAWS.
NEITHER THESE ANALYSIS REPORTS NOR ANY COPY HEREOF MAY BE DISTRIBUTED IN ANY JURISDICTION OUTSIDE THE UK WHERE THEIR DISTRIBUTION MAY BE RESTRICTED BY LAW. PERSONS WHO RECEIVE THIS REPORT SHOULD MAKE THEMSELVES AWARE OF AND ADHERE TO ANY SUCH RESTRICTIONS.