KILLIK & CO RESEARCH POLICY FIXED INCOME JANUARY 2014

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1 KILLIK & CO RESEARCH POLICY FIXED INCOME JANUARY 2014 Introduction Killik & Co aims to provide fixed income research which is objective, fair and not misleading to clients. This document outlines the various types of fixed income research and the related policies for managing potential conflicts of interest that may arise in the production of the fixed income research. Types of Fixed Income research Fixed income research comprises the following: Bond Lists Fixed Income Research reports Fixed Income weekly note Confidant Articles Periodic contributions to the Killik & Co Daily Note Killik & Co bond research is produced by analysts within the Fixed Income team. The name(s) of the author(s) is/are identified in fixed income research reports written by members of the Fixed Income team. The research is produced on the basis of publicly available information, internally developed data and other sources believed to be reliable. Records are maintained of information relied upon in writing the note. Fixed Income Research Categories Bond Lists There are two Bond Lists produced by the Fixed Income team; the Covered List and the Preferred List. The Covered List represents a selection of fixed income securities identified as Page 1 of 7

2 potential investment opportunities, depending upon various valuation metrics. The Preferred List comprises those securities which the Fixed Income team believes to be the most attractively valued of the securities on the Covered List. The relative valuation attractions of the fixed income securities on the Preferred List are primarily assessed on the basis that an investor holds the investment until maturity. Fixed Income Research reports The Fixed Income team may produce research reports on bonds that are on the Bond Lists. These reports may cover one or more bonds of a particular issuer or may be on a specific type of fixed income security which could include a number of issuers. From time to time a more thematic note may be produced. Security Specific Risk Ratings All securities on the Bond Lists are issued with a security specific risk rating, represented by a number between 1 and 9. Assessing the relative risk of any security (specific risk) is highly subjective and may change over time. The Killik & Co Risk Rating system uses categories which are intended as guidelines to the specific risks involved, as follows: Restricted Lower Risk (1) Securities in this category are what we believe to be lower risk investments such as cash, cash equivalents and, in terms of Fixed Income securities, short dated gilts. Restricted Medium Risk (2-3) Securities in this category are what we believe to be medium and lower risk investments. For fixed income securities this includes medium and long-dated gilts, senior or unsubordinated corporate bonds from investment grade issuers or from sub-investment grade or unrated issuers which Killik & Co s Fixed Income team, based upon its analysis, believes to represent medium risk. Unrestricted (4-9) Page 2 of 7

3 This category includes securities that we believe to be higher risk. Fixed income securities in this category may include investment grade, sub-investment grade or unrated bonds. This category may include subordinated issues, bonds with conversion features, permanent interest bearing shares (PIBS), preference shares or other fixed income securities which Killik & Co s Fixed Income team, based upon its analysis, believes to be higher risk. Most of the fixed income securities on the Bonds Lists are likely to fall into the restricted/medium risk (2-3) or unrestricted/higher risk category (4-9) above. For further detail on the Killik & Co risk rating system please see the Killik & Co terms and conditions. Publication and distribution of Killik & Co Fixed Income Research Killik & Co fixed income research may be published at any time during the day. This research is available to the Killik & Co broker network. Brokers have the discretion to send research reports to clients either via or in hard-copy form. The Killik & Co Fixed Income team may provide information on new issues to clients based upon the offering documents of the issuer. The Fixed Income team undertakes analysis of potential new issues prior to agreeing to be a distributor of the bonds. Management of potential conflicts of interest The Killik & Co Fixed Income team has procedures in place to ensure the objectivity of its research and to help identify and manage potential conflicts of interest which may arise. Fixed income research notes will make reference to the existence of this policy and the fact that it is accessible via the Killik & Co website, so that clients are aware of the potential conflicts that may exist and the steps taken to manage them. Outside business interests Members of the Killik & Co Fixed Income team must seek prior approval from the Head of Compliance before entering into outside business interests. The Head of Compliance will not permit outside business interests that are deemed to conflict with the team member s provision of unbiased research. Page 3 of 7

4 Gifts/Inducements Killik & Co does not produce research paid for by issuers of investments nor does it act as corporate broker to any companies. Any gifts received by members of the Killik & Co Fixed Income team from clients or companies must be disclosed to the Head of Compliance. Any hospitality extended to members of the Fixed Income team, where the value is likely to exceed 200 per person, should also be notified to the Head of Compliance. Distributor Fees Killik & Co may at times be an Authorised Distributor or Sub-Distributor on new retail bond issues. As such, Killik & Co may receive a distributor fee from the issuer on the aggregate principal amount of the notes allotted to us under the offer. However, neither the availability nor the size of the distributor fee forms part of the selection process for fixed income investments. Killik & Co will only agree to be a distributor on new retail bond issues if the Fixed Income team, through its analysis, determines that the bonds have merit from an investment perspective. Certain discretionary client portfolios are managed within the Fixed Income team. Any decision to invest in new issues within discretionary accounts is not influenced by the existence of a distributor fee and only takes place where it is suitable for a particular portfolio or group of portfolios. The management of this potential area of conflict is supported by Compliance monitoring. Personal Account holdings disclosure If one of the named analysts on a Killik & Co fixed income research note has an interest in an investment covered by the note at the time of publication of the research, this fact will be explicitly disclosed in the relevant research note. Personal Account dealing Members of the Killik & Co Fixed Income team are permitted to invest in securities which are the subject of Killik & Co fixed income research and other securities, subject to the Killik & Co personal account dealing policy and procedures. Members of the Fixed Income team must seek Page 4 of 7

5 prior approval from the Compliance department for their personal account transactions in fixed income securities. Members of the Fixed Income team must notify the Compliance department of personal account transactions in the shares of companies whose bonds are on the Fixed Income Covered List. Fixed Income team-managed discretionary portfolios Certain discretionary client portfolios are managed within the Fixed Income team. The Fixed Income team considers it reasonable to deal on these portfolios once research has been disseminated to the Killik & Co broker network or the bond has been added to the Fixed Income team s Preferred List therefore enabling the Killik & Co brokers to deal for their discretionary clients. In certain circumstances, Fixed Income team-managed portfolios may include securities on which the Fixed Income team does not have current research in issuance or does not appear on the Preferred List. If it is decided at a future date that the security is to become the subject of a Fixed Income team-issued research report, or will be added to the Preferred List then no further transactions in that security will take place from the point the decision is made until the research is disseminated to the Killik & Co broker network. It should be noted that the nature of a discretionary service means that discretionary accounts may be transacted upon sooner than advisory accounts. The Fixed Income team may sometimes retain cash on discretionary portfolios in anticipation of investing in upcoming new bond issues. Although the Fixed Income team may be aware of potential new bond issues from time to time, decisions to invest are only made once full terms of a new bond issue are announced, and are based on a thorough assessment of the merits of that particular bond over other available investment opportunities. Members of the Fixed Income team are permitted to conduct personal account transactions in investments which are held in Fixed Income team-managed client portfolios, subject to the aforementioned personal account dealing and research disclosure policies. Non-public information From time to time, the Fixed Income team may be informed about upcoming new bond issues prior to the Issuer making an official announcement. Where the name of the Issuer is disclosed to the Fixed Income team, this can be inside information. Whilst in possession of inside information (which is typically for less than one week), the Fixed Income team will not publish Page 5 of 7

6 any research connected with that Issuer or a competitor. Nor are the Fixed Income team permitted to conduct personal account transactions or deal on Fixed Income team-managed portfolios in the Issuer s securities during this period. Information barriers The Killik & Co Fixed Income team is situated on the same floor as some Killik & Co broking teams. However, the interaction between the Fixed Income team and the broking teams is managed such that clients are not disadvantaged. Members of the Fixed Income team are not permitted to disclose forthcoming research publications or information on pending new issues outside the Fixed Income team. Remuneration structure for Fixed Income Analysts The remuneration of the Killik & Co Fixed Income team is not linked to specific views or recommendations provided in any fixed income research publication. Variable compensation is not capped but is linked to profitability and not to top line revenue generated. Supervision and management of Fixed Income Analysts The Killik & Co Fixed Income analysts are managed by the Senior Investment Strategist and Head of Fixed Income, who reports to the Executive Director of the Branch Network. Page 6 of 7

7 Killik & Co is a trading name of Killik & Co LLP, a limited liability partnership authorised and regulated by the Financial Conduct Authority and a member of the London Stock Exchange. Registered in England and Wales No. OC Registered office: 46 Grosvenor Street, London W1K 3HN. A list of Partners is available upon request. Page 7 of 7