This policy explains the procedures that Intellisys Intelligent Analysis Limited ('Intellisys) has adopted to manage any conflicts of interest that may arise in relation to the investment research we publish. The policy does not affect any contractual obligations owed by Intellisys to its clients or give rights to any third party. Nor does the policy apply to any personal recommendation that is tailored to a client’s particular circumstances.

 

Intellisys aims to present its research as objective (i.e. as an impartial assessment of the value or prospects of the investments which are the subject matter of the research). Any research that is not presented as objective will be marked as such. All research, whether presented as objective or non-objective, will comply with the relevant Financial Conduct Authority ('FCA') requirements, in particular to be clear, fair, and not misleading, and will comply with the following policy:

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• Intellisys provides professional independent research services and the companies' researched pay a set fee in order for this research ("contracted company research") to be made available. While the information is believed to be correct, this cannot be guaranteed. There are no other conflicts of interest.

 

• Intellisys outsources the majority of its research work to experienced investment analysts, who are assessed prior to engagement as competent to do so and retained by Intellisys Intelligent Analysis Limited on a contract basis.

 

• The conclusions and opinions expressed in the contracted company research accurately reflect the views of the named analyst.

 

• Draft contracted research will only be reviewed prior to publication by the company to which the research relates in order to verify factual accuracy.

 

• Analysts are free to express their own views in research reports free from pressure and control by staff in any other business area. Staff in other areas are prohibited from reviewing or approving the content of draft research reports before publication other than:

​​- for the purposes of verifying the factual accuracy

- suggesting reference to specific competitors and other relevant quoted companies

- checking whether there is a case for deferring publication under exceptional circumstances

- senior staff who have been given responsibility for editing and/or checking compliance with FCA regulations.



• An analyst will not publish research on a company at a time when he/she has confidential price-sensitive information relating to the company.

• Favourable research coverage, specific investment conclusions, or specific recommendations will not be offered as consideration or inducement for the receipt of any business or compensation from any source.

• Analysts’ remuneration is never linked to a specific transaction, or to recommendations contained in their research. Remuneration decisions are made by the Board of Directors.

• Analysts are remunerated solely by way of fees specifically related to coverage of individual client companies.

• Decisions on the subject matter and timing of research are normally taken by the analysts themselves, but the senior staff member responsible for sign-off is also ultimately responsible for the timing of publication. Intellisys will take account of the needs of our clients in deciding what to publish and when.

• Research will be distributed to clients in a manner which we consider to be appropriate having regard to each client’s requirements and the service we provide. Not all clients will receive all research, e.g., where it is only available on a subscriber basis.

• Analysts will not disclose the content or timing of research that is to be published ahead of its publication.

• Analysts will not provide advisory services.

• Analysts may only answer client specific questions from Financial Conduct Authority regulated investors.

• Restrictions on personal account dealing are placed on analysts and other staff. Analysts may not in general trade in a manner contrary to their published recommendation or deal ahead of the publication of any research report.

• All staff are subject to rules that prohibit them from taking advantage, for the benefit of clients or any other person, of knowledge that research is to be published by Intellisys Intelligent Analysis Limited, or of the content of that research.

Analysts producing objective research are required to produce that research free from any influence from the company to which the research relates and ignoring the interests of Intellisys Intelligent Analysis Limited.All analysts may be involved in developing research and other materials that are used to help win new business or retain existing business. They may participate in pitches to actual or prospective clients and endeavour to solicit business.

 

Intellisys Intelligent Analysis Limited is not required to be authorised and regulated by the Financial Conduct Authority, however, for the purpose of good business practise, maintains high business standards in line with the rules and regulations of the Financial Conduct Authority.​