Legal & Compliance
Conflicts of Interest Policy
DB Investment Partners Limited conducts its business according to the principle that it must manage conflicts of interest fairly, both between itself and its clients and between one client and another.
The Conflicts of Interest Policy, which you can download from this website, explains the fundamentals of how DB Investment Partners Limited identifies and manages conflicts of interest.
Order Execution Policy
This page sets out DB Investment Partners Limited Order Execution Policy, which accounts for the implementation of the second Markets in Financial Instruments Directive (Directive 2014/65/EU ”MiFID II”) and applicable rules of the UK Financial Conduct Authority relating to Best Execution.
DB Investment Partners Limited may from time to time receive acceptable minor non-monetary benefits permitted under applicable law and regulation as set out in COBS 2.3A.19 of the FCA Handbook, including;
- information or documentation relating to financial instruments or investment services;
- issuer-commissioned research coverage;
- participation in conferences, seminars or training events on the benefits and features of specific financial instruments or investment services;
- hospitality of a de minimis value during meetings or those events specified;
- connected research on an issuer in the context of an issuer capital raising;
- research provided for a trial period, openly and publicly available, or relating to fixed income, currency or commodity instruments (with the exclusion of macro-economic research); and
- such other services and/or benefits that can be considered minor non-monetary benefits under Applicable Law from time to time.
If you have a complaint, please write to:
DB Investment Partners Limited
1 Great Winchester Street
EC2N 2DB, UK
Or by email to:
DB Investment Partners Limited will send a prompt written acknowledgement that the firm has received the complaint and is dealing with it.
This document is issued by DB Investment Partners Limited (FRN: 966618), at Winchester House, 1 Great Winchester Street, London EC2N 2DB, UK. Authorised and regulated by the Financial Conduct Authority.
Telephone and communications recording
Provided for the purposes of compliance with rule 10A.1.11 of the Senior Management Arrangements, System and Controls (“SYSC”) Sourcebook of the UK Financial Conduct Authority Handbook.
Telephone conversations between DB Investment Partners Limited, a Client and/or third parties may be recorded without the use of a warning tone and used as evidence in the event of a dispute or investigation.
DB Investment Partners Limited may retain records of all communications with a Client for, in principle, a period of five years and, where requested by the competent authority, for a period of up to seven years. A copy of the recording of such records will be available on request from a Client during the applicable period.
DB Investment Partners Limited is required, in the case of personal conversations with clients relating to investment services, to record in a durable medium notes of the conversation which include at least the following:
- Date and time of the meeting,
- Location of the meeting,
- Identity of the attendees,
- Initiator of the meeting, and
- Relevant information about the order including the price, volume, type of order and when it shall be transmitted or executed.