ARIA is an organisation specialising in the provision of predominantly wealth management technology, investment advice and discretionary investment management services. As such, we or a company with which we have an association, may from time to time have interests which conflict with those of our clients or with the duties we owe to our clients.

Regulations require the firm to take all reasonable steps to identify any such conflicts of interest that may exist within the firm (including its managers, employees, appointed representatives, or where applicable branches, or any person directly or indirectly linked to the firm by control), between the firm and our clients, and between one client and another.

To prevent the risk of damage to clients’ interests as a result of any such conflict, we have in place various organisational and administrative arrangements to deal with potential conflicts of the type, disclosed in our Terms of Business agreement with our clients, and further detailed below.

  • We may hold positions and/or provide transactional related services for more than one client and such clients may have competing objectives in relation to a position or transaction.
  • We may combine orders received from one client with those received for the accounts of other clients (and exceptionally may combine with our own orders). Such aggregation may operate on some occasions to a client’s advantage and on some occasions to their disadvantage. In any event where orders have been aggregated, they will be allocated to clients on the basis of a preexisting formal and fair allocation policy.
  • We could pass orders to an affiliated company for execution. This will, however, be done in accordance with our Execution Policy at the time.
  • Where we exercise a right to vote in relation to a corporate action, we will do so in accordance with clients’ instructions and these may reflect competing interests.
  • We may place (or ask a custodian to place) money held on behalf of clients with a bank (in accordance with the relevant regulatory requirements) and earn and retain interest payments from such a bank.
  • We or one or more of our partners or employees may have other business relationships with a company in relation to whose securities you are entering into a transaction e.g. as a client, director, employee, supplier, custodian or banker.
  • In carrying out our business, employees may learn confidential or proprietary information about its clients, their underlying clients, prospective clients and their underlying clients or other third parties. Employees are required to maintain the confidentiality of all such information entrusted to them, except where disclosure is otherwise authorised or legally mandated. Further, employees are not permitted to use such information for their personal gain.
  • Our employees are not permitted to trade in the shares of our clients unless the client’s shares are widely traded on a regulated market and where the service provided by us represents a very small fraction of the client’s total business.
  • Our employees are required to disclose and in most cases must obtain approval for any outside business interest or employment.
  • Where necessary, we maintain arrangements which restrict the flow of information to certain employees in order to protect its clients’ interests and to prevent improper access to client information.
  • We could theoretically also deal as Principal for our own investment account and we may match transactions with another client. Procedures are in place in order to protect the clients’ interest in this instance.
  • Model portfolios provided by ARIA might be composed of the funds that ARIA advises and/or manages.
  • All investments are assessed to ensure that by including them in a portfolio they will help to meet the objectives of the portfolio. Where a discretionary client is invested in a fund that ARIA advises or manages, the annual management charge due from such investments will generally be taken into account for the purpose of calculating the annual management fees that will be retained by ARIA to avoid the possibility of double charging.
  • All employees of ARIA are subject to the ARIA Personal Account Dealing Policy. This policy ensures that all dealing on behalf of client portfolios or ARIA advised or managed funds takes precedence over personal account dealing and that no personal account dealing would be to the detriment of a client. The policy requires all members of staff to obtain prior approval from senior management and Compliance before they are allowed to transact any deals on personal accounts for all investments other than those that are related to indices or exchange traded futures.
  • ARIA has an ‘Anti-Bribery Policy’ & a ‘Gifts & Inducements Policy’ which in general prohibits management and employees from accepting gifts, hospitality or other benefits which have the potential to cause a conflict of interest with ARIA’s regulated business. Prior approval from Compliance is required before any benefit is accepted above a de-minimus level. A register is kept by the Compliance department.
  • Remuneration and bonus structures are designed so as not to create any incentive for a manager or employee to act contrary to a client’s interests. Remuneration, including any discretionary bonus payments, are overseen by the Board. Any discretionary bonus made to the senior manager’s must be agreed by the Board. An annual Remuneration Code disclosure is made.

The effectiveness of the above controls is monitored on an on-going basis by the Compliance Manager. ARIA’s Compliance team considers all reportable personal account dealing and gifts received or given by ARIA’s management or employees.

Records of actual and potential conflicts and the procedures in place to manage them are regularly reviewed by ARIA’s Compliance team and kept on file.

In some cases, our procedures and controls may not be sufficient to ensure that a potential conflict of interest does not damage a client’s interests.

In these circumstances, we may consider it appropriate to disclose the potential conflict to the client and obtain the client’s formal consent to proceed. However, we may decline to act in any circumstances where there is residual risk of damage to the interests of any client.

This conflicts disclosure is not intended to, and does not, create rights or duties that would not exist if the disclosure had not been made available, nor does it form part of any contract between ARIA’s entities and any Client.

ARIA Capital Management is a trading name of Absolute Return Investment Advisers (ARIA) Limited. Office: Ground Floor, 2 Bell Court, Leapale Lane, Guildford GU1 4LY. Absolute Return Investment Advisers (ARIA) Ltd is authorised and regulated by the Financial Conduct Authority.
The information on this site is issued by ARIA CAPITAL MANAGEMENT. ‘ARIA’ and ‘ARIA CAPITAL MANAGEMENT’ are TRADING NAMES of ABSOLUTE RETURN INVESTMENT ADVISERS (ARIA) Limited, who are authorised and regulated by the Financial Conduct Authority in the UK, with Firm Reference number 527557. A Limited Company registered in England and Wales No: 7091239. Contact Address: Ground Floor, 2 Bell Court, Leapale Lane, Guildford GU1 4LY. Telephone: +44 (0)203 137 3840 The information on this site is directed only at persons or entities in any jurisdiction or country where such access to information contained herein and use thereof is not contrary to local law or regulation. In particular, the information on this site is not directed at any person in the United States and this site is not intended to be used by any person in the United States. Accordingly, all persons who access this site are required to inform themselves of and to comply with any such restrictions. Sales Restrictions United Kingdom: there are funds referred to on this site, which are not recognised collective investment schemes for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the 'Act'). The promotion of such investment funds and the distribution of offering materials in relation to such funds in the United Kingdom are accordingly restricted by law. The information contained on the restricted part of this site (the 'Intermediary Centre') is directed only at persons to whom such investment funds may lawfully be promoted by a person authorised under the Act (an 'authorised person') by virtue of Section 238(5) of the Act and Chapter 4 (part 12) of the FCA New Conduct of Business Sourcebook. Investors in the investment funds referred to in the Restricted Area will not benefit from the rules and regulations made under the Act for the protection of investors, nor from the Financial Services Compensation Scheme. Shares in the investment funds referred to in the Intermediary Centre are not dealt in or on a recognised or designated investment exchange for the purposes of the Act, nor is there a market maker in such shares, and it may therefore be difficult for an investor to dispose of his shares otherwise than by way of redemption. General: it may be illegal to access or download the information contained in this site in certain countries and ARIA disclaims all responsibility if you access or download any information from this site in breach of any law or regulation of the country in which you are residing. Access to the Intermediary Centre requires possession of a valid password and no other person should attempt to gain access to it. An application for shares in the investment funds referred to on this site should only be made having read fully the relevant prospectus and other information contained on this site. It is your responsibility to use such documentation and by making an application you will be deemed to represent that you have read such applicable documentation and agree to be bound by its contents. No Advice The information on this site is provided solely on the basis that you make your own investment decisions and does not constitute a personal recommendation or investment advice. Should you have any queries about the investment funds or services referred to on this site, you should contact your financial adviser. Taxation will depend on an individual financial circumstances and the country of residence. Please seek professional advice in relation to any taxation issues which may arise from your interest in investment funds or services referred to on this site. Risk Factors Past performance may not be repeated and should not be seen as a guide to future performance. The value of investments and the income from them may go down as well as up and investors may not get back the amount originally invested. Because of this, you are not certain to make a profit on your investments and you may lose money. Exchange rates may cause the value of overseas investments and the income arising from them to rise or fall. The levels and bases of and reliefs from taxation may change. Any tax reliefs referred to are those currently available and their value depends on the circumstances of the individual investor. Investors should consult their own tax adviser in order to understand any applicable tax consequences. ARIA has taken every step to ensure the accuracy of the information and statistics on this site and within its literature but cannot accept any liability for errors or any direct or consequential loss arising from the use of this document or its contents. Before taking any action you should consult your financial adviser as to the suitability to you of any investments or services mentioned on this site or within any literature available on this site. Accuracy of Information The information contained on this site (including any expression of opinion or forecast) has been obtained from, or is based on, sources believed by ARIA to be reliable, but is not guaranteed as to its accuracy or completeness. Such information is provided without obligation on the part of ARIA and its associated companies and on the understanding that any person who acts upon it or changes his investment position in reliance on it does so entirely at his own risk. The information contained on this site does not constitute an offer to buy or sell or an invitation to make an offer to buy or sell shares in any investment funds referred to herein. Information posted on this site is current only as at the date it is first posted and may no longer be true or complete when viewed by you. All information contained on this site may be changed or amended without prior notice although ARIA does not guarantee to update this site regularly. No Liability No representation, warranty or undertaking is given as to the accuracy or completeness of the information contained on this site by ARIA or any of its associated companies and no liability is accepted by such persons for the accuracy or completeness of such information. In no event will ARIA or any of its associated companies be liable to any person for any direct, indirect, special or consequential damages arising out of any use of the information contained on this site, or on any other hyper-linked site, including, without limitation, any lost profits, business interruption, loss of programs or data on your equipment, or otherwise, even if ARIA is expressly advised of the possibility or likelihood of such damages. This does not exclude or restrict any duty or liability that ARIA has to its customers under the regulatory system in the United Kingdom. You should be aware that the Internet is not a completely reliable transmission medium. ARIA does not accept any liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to any direct, indirect or consequential damage, arising out of the use of the products or services referred to herein. This does not exclude or restrict any duty or liability that ARIA has to its customers under the regulatory system in the United Kingdom. Indemnity You agree to indemnify, defend, and hold harmless ARIA, its affiliates and licensors, and the officers, partners, employees, and agents of ARIA and its affiliates and licensors, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of this site or any literature available on this site. Material Interest ARIA and its partners, officers and/or employees may have holdings in the investment funds referred to on this site and may otherwise be interested in transactions that you effect in those funds. Linked Websites This site may be linked to third party websites or contain information provided by third parties. ARIA does not make any representation as to the accuracy or completeness of such websites or information, has not and will not review or update such websites or information, and cautions browsers that any use made of such websites or information is at their own risk. ARIA does not accept any liability arising out of the information contained on any linked website or information on this site provided by a third party and the use of such sites and information is at your own risk. This does not exclude or restrict any duty or liability that ARIA has to its customers under the regulatory system in the United Kingdom. Copyright, Trademarks and Other Rights Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by ARIA, its licensors or relevant third party content providers. You may use the information on this site and reproduce it in hard copy for your personal reference only. Such information may not otherwise be reproduced, distributed or transmitted to any other person or incorporated in any way into another database, document or other materials. Nothing on this site should be considered as granting any licence or right under any trademark of ARIA or any third party. Privacy and Cookies Please refer to ARIA’s Privacy Policy for full details. FRC Stewardship Code The Stewardship Code (“the Code”), which has been published by the Financial Reporting Council, sets out principles for institutional investors in relation to engagement with the companies in which they have invested. The FCA’s regulations oblige any firm which manages investments for institutional clients to publicly disclose the nature of its commitment to the Code, or where it does not commit to the Code its alternative approach. ARIA’s investment strategy, notwithstanding that this may vary depending on the mandate received from the client, is in general such that the firm does not consider it to be appropriate for it to engage directly with companies in which it invests. The scale on which the firm manages investments for institutional clients is such that engagement would not be cost-effective and appropriate for those clients. The firm does not consider that those institutional clients for whom it manages investments expect engagement.