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Palissy Advisors Limited is an appointed representative of Messels Ltd which is authorised and regulated in the conduct of investment business in the United Kingdom by the Financial Conduct Authority. Our services are provided for information purposes only. Under no circumstances is the research content of this website (“the Research”) to be relied upon as constituting personal investment advice or construed as any offer to sell, or any solicitation of any offer to buy investments. While all reasonable care has been taken to ensure that the research published by Palissy Advisors Limited is not untrue or misleading at the time of publication, neither Palissy Advisors Limited nor its officers or employees makes any representation or warranty as to the accuracy or completeness of such materials. No liability is accepted for any loss whether direct or indirect, incidental or consequential, arising out of any of the research not being true and accurate except to the extent caused by the wilful default or gross negligence of Palissy Advisors Limited or its employees or which arises under the United Kingdom Financial Services and Markets Act 2000. All research on the Palissy Advisors Limited websites is believed to be up-to-date at the time it is posted, but is subject to variation without notice.

From time to time Palissy Advisors Limited and any of its officers or employees may, to the extent permitted by law, have a position or otherwise be interested in any transactions in investments (including derivatives) directly or indirectly the subject of our research. Also Palissy Advisors Limited may from time to time provide other services (including acting as adviser) to any company mentioned in our research.

The value of shares and other investments and the income derived from them may go down as well as up, and you may not get back the full amount you originally invested. Derivatives in particular are high risk investment instruments which carry a contingent liability, the value of which may be affected by a greater proportion than the change in the value of the underlying investment or asset. If you make an investment in securities that are denominated in a currency other than your own you are warned that changes in rates of foreign exchange may have an adverse effect on the value, price or income of the investment in your own currency. Any persons in doubt as to whether the investments referred to in our research material may be suitable for them, should consult an independent financial adviser.

The content of this website is protected by copyright and other intellectual property rights or similar rights, which unless indicated otherwise are the property of Palissy Advisors Limited. Except for permission to download a single copy for personal use, the research published by Palissy Advisors Limited may not be reproduced, distributed or published in whole or in part by any recipient for any purpose, without the prior express consent of Palissy Advisors Limited.

Neither Palissy Advisors Limited nor its employees officers or agents accepts any responsibility for the accuracy of any information contained within or otherwise the operation of any sites provided by third parties who at any time have links to or from Palissy Advisors Limited’s website pages. No liability is accepted for any loss, whether direct or indirect, incidental or consequential, arising from any visit or access to such third party site or the downloading from such site of any information, materials or software.

Whilst certain software may be made available to you from time to time at the Palissy Advisors Limited website, you are licensed to use such software on a non-exclusive basis only for the purposes specified. You are not permitted to use such software for any other purposes and may not redistribute, sell, decompile, reverse engineer, disassemble or otherwise deal with such software.

The “Palissy Advisors Limited” name and other trade marks and logos appearing on Palissy Advisors Limited websites are, unless indicated otherwise, the trade marks of Palissy Advisors Limited. All intellectual property rights in and to the same site expressly reserved to XYZ or (as the case may be) the organisation which has licensed Palissy Advisors Limited to reproduce the same and accordingly none of the trade marks may be reproduced by you without the express prior consent of Palissy Advisors Limited.

Palissy Advisors Limited may from time to time send you promotional and other information about its products or services. In addition, Palissy Advisors Limited may pass your name on to carefully selected third parties who may contact you with similar or related information. If you would rather not receive the above information either telephone or email us.

Access to this website is not open to persons who are resident in or nationals of any territory outside the United Kingdom (“overseas persons”) where to allow such access would require any registration, filing or other steps to be taken by Palissy Advisors Limited in order to comply with local laws or other regulatory requirements. It is the responsibility of overseas persons to ensure there will be no breach of any such laws or regulatory requirements by reason of their choosing to access and/or download information from this and other Palissy Advisors Limited websites. This website is hosted in the United Kingdom and compiled in order to comply with English law. All visits to this website are subject to and governed in accordance with English law.

User Agreement

By accessing this site the User is agreeing to the terms and conditions below. If the User uses the Site in the course of business the User is also agreeing to these terms and conditions on behalf of that business.

If the User does not agree with the terms and conditions (or the User is not authorised to do so) the User should not use the Site.

If the User has any questions they should contact: palissy@palissyadvisors.com

Conflicts of Interest Policy – General

Under FCA’s Principles for Businesses, Principle 8 requires a firm to “manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.” Under the Markets in Financial Instruments Directive (“MiFID”), Palissy Advisors Limited (“Palissy Advisors Limited”) is required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage such conflicts of interest. Palissy Advisors Limited has put in place a policy to meet this obligation and set out below is a summary of that policy and the key information that is needed by clients and counterparties (together “customers”) to understand the measures Palissy Advisors Limited is taking to safeguard the interests of its customers.

Palissy Advisors Limited seeks to:

identify circumstances which may give rise to conflicts of interest entailing a material risk of damage to customers’ interests;
establish appropriate mechanisms and systems to manage those conflicts; and
maintain systems in an effort to prevent actual damage to customers’ interests through the identified conflicts.

What is a Conflict of Interest?

A conflict of interest under MiFID is a conflict that arises in any area o Palissy Advisors Limited’s business in the course of providing its customers with a service which may benefit Palissy Advisors Limited (or another customer for whom Palissy Advisors Limited is acting) whilst potentially materially damaging another customer where Palissy Advisors Limited owes a duty to the customer. There may be a conflict where Palissy Advisors Limited (or anyone connected to Palissy Advisors Limited including another Palissy Advisors Limited affiliate):

is likely to make a financial gain (or avoid a loss) at the expense of its customer;
is interested in the outcome of the service provided to its customer where the interests of Palissy Advisors Limited is distinct from that of the customer;
has a financial or other incentive to favour the interests of one customer over another;
carries on the same business as a customer;
receives money, goods or services from a third party in relation to services provided to a customer other than standard fees or commissions.

Palissy Advisors Limited has sought to identify conflicts of interest that exist in its business and has put in place measures it considers appropriate to the relevant conflict in an effort to monitor, manage and control the potential impact of those conflicts on its customers. The conflicts identified include:

those between customers with competing interests;
those between customers and Palissy Advisors Limited where their respective interests in a particular outcome may be different; and
those between the personal interests of staff of Palissy Advisors Limited and the interests of Palissy Advisors Limited or its customers where those interests may be different.

Conflicts of Interest – Procedures

Palissy Advisors Limited has adopted internal policies and procedures in order to manage recognised conflicts of interests. These policies and procedures will be subject to our normal monitoring and review processes and include:

Integrity and Standards of Conduct

Palissy Advisors Limited insists that in its dealings with customers its staff must use the highest standard of integrity in their actions at all times. The induction programme, training and competency procedures and monitoring programme at Palissy Advisors Limited are designed to ensure that all relevant staff are familiar with and observe, inter alia, the FCA Principles for Businesses, the Statements of Principle and the Code of Practice for Approved Persons.

Personal Account Dealing

Palissy Advisors Limited has a policy on Personal Account Dealing and the rules are signed off as understood by all relevant employees regardless of their position within Palissy Advisors Limited.

Confidentiality and Information Barriers

Palissy Advisors Limited insists on strict customer confidentiality to ensure that information is disclosed only to those entitled to receive it or otherwise with the prior approval of the Compliance Department.

Inducements to Employees from Customers

Staff are not allowed to accept gifts, entertainment or any other inducement from any person which might benefit one customer at the expense of another when conducting investment business. Palissy Advisors Limited has a Gifts and Entertainment Policy which is part of the staff’s Policy Manual and is monitored by management on a regular basis.

Remuneration Policy

All relevant staff who are open to a conflict of interest are paid a basic salary including those in key support areas such as Compliance, Finance and Back Office. This salary is not dependent on company performance. A bonus scheme does exist which is linked to the company’s performance and the performance of the individual. It is entirely discretionary.

Separate Supervision and Segregation of Function

Where appropriate, Palissy Advisors Limited has arranged for the separate supervision of those carrying out functions for customers whose interests may conflict, or where the interests of customers and Palissy Advisors Limited may conflict and has taken steps to prevent the simultaneous or sequential involvement of a relevant person in separate services or activities where such involvement may impair the proper management of conflicts of interest.

Disclosure

As a last resort, where there is no other means of managing the conflict or where the measures in place do not, in the view of Palissy Advisors Limited, sufficiently protect the interests of customers, the conflict of interest will be disclosed to customers to enable an informed decision to be made by the customer as to whether they wish to continue doing business with Palissy Advisors Limited in that particular situation.

Declining to Act

Finally, where Palissy Advisors Limited considers it is not able to manage the conflict of interest in any other way it may decline to act for a customer.

Policy of Independence

All investment research issued by Palissy Advisors Limited Investment Ltd (“Palissy Advisors Limited”) is independent, impartial and objective. Palissy Advisors Limited does not conduct any investment business with or for its clients, other than the provision of investment research and advice. Palissy Advisors Limited staff have no other responsibilities which could conflict with the interests of our clients. Palissy Advisors Limited does not carry out any corporate finance business; and has no involvement in raising capital for corporate clients. Palissy Advisors Limited has no other regulated or unregulated business activities which conflict with its provision of independent research.

Interests in Securities

Palissy Advisors Limited, its directors or employees may have interests in the securities on which we provide research and may add to or dispose of such securities from time to time. Palissy Advisors Limited may have provided advice, other investment or professional services to the issuer of the securities. Any such interests are reviewed by a director of Palissy Advisors Limited to ensure that they do not represent conflicts of interest with our customers.

Conduct of Our Investment Analysts

All of Palissy Advisors Limited’s investment analysts are supervised by directors of the firm. The remuneration structure for Palissy Advisors Limited’s analysts may be linked in any way to dealing or other activities which our customers carry out as a result of the independent research provided by the firm. In the event of any conflict of interest, Palissy Advisors Limited requires all relevant employees to disregard any material interest or conflict of interest when advising a customer. Our analysts are not permitted to be involved in any activities which could be seen as conflicting with our provision of investment research to our clients. No inducements offered by issuers, or others with a material interest in the subject matter of investment research, may be accepted by our investment analysts or directors of the firm. No employee of Palissy Advisors Limited may carry out any personal account dealing which could create a conflict of interest which might affect the impartiality of Palissy Advisors Limited’ investment research. Any proposed personal account dealing by employees is subject to pre-approval by a director of Palissy Advisors Limited and no dealing which could create a conflict of interest between the employees of Palissy Advisors Limited and its customers is permitted. In addition, a prohibited list of securities is maintained. All outside business activities of employees are subject to prior approval by a director of the firm.

Our Research

The timing and manner of publication and distribution of investment research and of the communication of its substance must be approved in advance by a director or senior analyst of Palissy Advisors Limited. Before being issued, all research documents must be approved and signed-off by a director or senior analyst. No one outside Palissy Advisors Limited may comment on draft investment research before publication, other than, where necessary, to verify factual information. Certain disclaimers may be included in our research where appropriate, for example for legal reasons. Palissy Advisors Limited ‘s policy and procedures require investment research to be distributed in an appropriate manner.

Our investment research is published and distributed either in hard copy or on line. No employee may communicate the substance of any investment research, except in accordance with our policy of independence.

Content

Palissy Advisors Ltd. DOES NOT endorse or recommend any securities or other investments and all analysis/commentary is presented for informational purposes only. All information on this Site, as well as reference materials or links to other sites, has been compiled from publicly available sources believed to be reliable and are for general informational purposes only. Accuracy or completeness of the information contained herein is NOT guaranteed and is NOT intended to be relied upon for transactional purposes. Neither Palissy Advisors Limited or its publishers, owners, investors, nor any of its data or content providers shall be liable for any errors or delays in the content, or for any actions, losses or damages, monetary or otherwise, taken in reliance of such information, judgments and opinions thereon. All such information is subject to change at any time without notice. “Hypertext links” and /or “hyperlinks” to or from other Internet sites may be introduced at times as a convenience to the user. We assume no responsibility for the content of any linked site. The fact that such links may exist does not indicate approval or endorsement of any material contained on any linked site. We also cannot be held liable for any harm caused by the transmission, through accessing the services or information on this site, of a computer virus, or other computer code or programming device that might be used to access, delete, damage, disable, disrupt or otherwise impede in any manner, the operation of the site or of any user’s software, hardware, data or property.

This commentary in no way constitutes financial, investment, tax or any related forms of advice and is one of many possible sources of information for readers. All information contained herein is believed to be accurate, but mistakes can and do happen. Be sure to consult an investment professional before acting on any information that is contained in this website. Views and opinions expressed as of the date of publication are exclusively those of the author and are subject to change based on market and other conditions. This publication is provided for informational purposes only and should not be used or construed as a recommendation for any security or sector.

The User must make their own decisions on whether or not to rely on any information posted on the Site. The Siteowner reserves the right to modify information displayed on this Site but it does not make any commitment to update the information displayed on this Site. From time to time the Siteowner will make available to the User links from the site to third party sites. These sites are not in any way approved, checked, edited, vetted or endorsed by the Siteowner and the User agrees that the Siteowner shall not be responsible or liable in any way for the content, advertising or products available from such sites, the quality, functionality, suitability or legality of such sites or for any dealings that the User may have, or the consequences of such dealings, with such third party site operators. Any arrangements made between the User and any third party named on the Siteowner’s Site are at the User’s sole risk and responsibility and the Siteowner expressly disclaims any liability for third party information or opinions posted on this Site or any linked Sites that arises under criminal or civil laws relating to defamation, intellectual property, infringement, privacy, obscenity, or any other area of law. Indemnity The User agrees to indemnify, keep indemnified, defend and hold the Siteowner and its parent companies, subsidiaries, affiliates and their respective officers, directors, employees, owners, agents, information providers and licensors, (collectively the “Indemnified Parties”) harmless from and against any and all claims, damages, liability, losses, costs and expenses (including legal fees) (whether or not foreseeable or avoidable) incurred or suffered by any Indemnified Party and any claims or legal proceedings which are brought or threatened arising from the User’s use of, connection with or conduct on the Site or any breach by the User of these terms. The Siteowner reserves the right, at its own expense, to assume the exclusive defence and control of any matter otherwise subject to indemnification by the User, and in such case, the User agrees to co-operate with the defence of such claim. Consequences of Breach of these Terms In the event that the Siteowner considers or determines, in their complete discretion, that the User has breached, violated or contravened the Agreement or has otherwise demonstrated inappropriate conduct in the use of the Site or the content or services they reserve the absolute right to: (a) warn the User that they have violated the Agreement and ask the User to discontinue such conduct; (b) discontinue the User’s membership of the site and/or any other related services, including Paid-for Content; and (c) take measures (including terminating, suspending or restricting the User’s use of the Site) to prevent the User from using the Site or linking to the Site. Third Parties The provisions of the Contracts (Rights of Third Parties) Act 1999 shall not apply to this Agreement, Proper Law and Jurisdiction This Agreement and all matters arising from it shall be governed by and construed according to the laws of England and Wales and shall be subject to the [exclusive] jurisdiction of the courts of England and Wales.

Entire Agreement

This Agreement supersedes all prior agreements, arrangements and undertakings and constitutes the entire agreement relating to the subject matter of this Agreement. The User confirms that they have not entered into this Agreement on the basis of any representation that is not expressly incorporated into this Agreement.