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Investment Research Conflicts of Interest Policy

We adopt a disciplined approach to investment. The process is managed by three distinct groups:

Background

The following statement sets out Rensburg Sheppards' policy aimed at ensuring that users of Rensburg Sheppards research can rely upon its objectivity and independence. It has been produced to comply with the Financial Services Authority's Policy Statement 04/06 and Consultation Paper 205.

The main business of Rensburg Sheppards Investment Management is to manage the investments of and to advise private investors, trusts, charities and small pension funds. It does not have a corporate finance department and is not a market maker and therefore does not have the potential conflicts of interest which come from such operations.

Rensburg Sheppards' Research

Rensburg Sheppards carry out objective research into quoted companies in order to construct key lists of equities from which clients' portfolios are constructed.

All the research will be objective and impartial and, whilst not highly detailed in its written form, will be based upon our own analysis of the company and also research from third parties.

The Analyst's Work

This research into UK stocks and shares is carried out by people who also work as fund managers in the various fund management teams around our offices; they are remunerated principally as fund managers rather than as investment analysts.

There is a disciplined process by which they report on their specialist companies. The analyst cannot make a recommendation or change in recommendation without the approval of the Stock/Sector Group which is drawn from senior directors in fund management teams from around the group. Such recommendations are then communicated to our investment managers by email either as part of a Morning Meeting note or as a special note. Each investment manager will then decide whether that recommendation is appropriate for each of his clients.

Personal Dealings

Personal dealing may only take place after client orders have been completed in full and such dealings are closely monitored by our Compliance Department. Analysts are not permitted to receive any remuneration from companies they follow.

Other Research

Research into externally-managed fund investment and unit trusts and other collective vehicles is also carried out by specialists who report to the Asset Allocation Group, or, where appropriate, to the Alternative Investment Group. Here again recommendations and changes in recommendations are communicated to investment managers by email and the investment manager decides which vehicle is appropriate depending upon the client's particular circumstances.