The Market in Financial Instruments Directive requires firms to identify those conflicts of interest that may materially affect the interests of their clients and to have arrangements to manage, control or avoid such conflicts. Firms are required, as a key part of these arrangements, to put into place a conflict of interest management policy. Firms are also required to provide information to their clients about their conflict of interest management policy. This information is provided by Westhouse Securities Limited (the Firm) to meet this obligation.

Senior management are required by the FSA Handbook to ensure that a firm's systems, controls and procedures are robust and adequate to identify and manage the conflicts of interest which arise in relation to research and research recommendations, and to ensure, as far as practical, that the arrangements operate effectively. We have identified the main conflicts of interest in relation to research and research recommendations, and controls and procedures have been implemented to manage these conflicts. These procedures have been included in the firm's internal documentation including a Conflicts of Interest Management Policy, with which our staff are required to comply as part of their contract of employment.