Conduct of Business Sourcebook rule 2.2.3R, requires Hilbert Investment Solutions Ltd (“HIS”) to include a disclosure on its website stating the nature of its commitment to the UK Stewardship Code (“the Code”) issued by the Financial Reporting Council. If the firm does not commit to the Code, it must state in general terms its alternative investment strategy. The Code is a voluntary code and sets out various principles relating to the level of engagement by investors with UK equity investors.
Whilst HIS supports the Code’s objectives, it has decided not to commit to the principles of the Code as it does not hold any voting rights in any UK company, where this to change, HIS will reconsider its position and its compliance with the Code.
Conflict of interest
A conflict of interest is a situation in which a person in a position of trust has competing personal or professional interests. Such competing interests can make it difficult to impartially fill the expected duties. A conflict of interest may exist even if no unethical or improper act has resulted from it.
At Hilbert Investment Solutions, we are committed to identifying, monitoring and managing any actual and potential conflicts of interest that may occur between us and our clients and between clients.
The purpose of this policy is to provide clients with the appropriate information regarding the policies Hilbert have in place to manage conflicts of interest.
We have summarised below the principal conflicts that exist in our business, and the steps we continue to take to mitigate them.
At Hilbert, we understand that it is not uncommon for our employees to undertake deals on their own behalf. We acknowledge that this can create a conflict with the duties owed to our clients, therefore all of our employees are required to comply with our Personal Account Dealing Policy.
Gifts and hospitality
Through our internal policies, Hilbert takes great care to ensure that gifts received from clients are not extravagant and are designed to enhance the quality of the service we provide to our clients. Hilbert 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.
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Terms of bussiness for registered intermediaries
Terms of Business for Registered Intermediaries
These Terms of Business are effective from 1st May 2018
These Terms of Business define the basis of the business relationship between Hilbert Investment Solutions (“Hilbert”) and each UK Regulated Advisers or Platform (of whatever legal nature). They also include Conditions for the basis upon which Hilbert may permit online access to information and services to Intermediaries who have been successfully registered.
Within these Terms of Business, the following definitions will apply:
• “We”, “us”, “our(s)” or Hilbert means Hilbert Investment Solutions
• “You” or “your(s)” means the UK Regulated Advisers or Platform (of whatever legal nature) who has applied to become a Registered Intermediary with Hilbert.
If you are a UK regulated Advisers please download our Term of Business >>
If you are a Platform please download our Term of Business >>