E :  info@sharpequity.co.uk
T:   +44 (0) 20 7856 0453

disclosure of conflicts of interest policy

Sharp Equity Limited is authorised and regulated by the Financial Conduct Authority (FCA), registration number 751405.

Under Principle 8 of the FCA Principles of Business, as stated in ‘PRIN 2.1 The Principles’ within the FCA Handbook, Sharp Equity Limited (“Sharp Equity”) is required to manage conflicts of interest fairly. Sharp Equity operates a Conflicts of Interest Policy that aims to identify any conflicts of interest that may exist between:


1.      Sharp Equity and its customers

2.      One customer and another client


Sharp Equity will undertake all necessary measures to

a)     reasonably identify and consistently review any potential conflicts of interest and manage them accordingly in order to mitigate any material risk of damage to its clients;

b)     incorporate appropriate systems to manage those conflicts;

c)     endeavour to prevent actual damage to customer interests through the identified conflicts.


Where the potential risk cannot be effectively managed, we will write to the client disclosing this ahead of any provision of services to the client, including sufficient detail to enable the client to make an informed decision with respect to the service in the context of which the conflict of interest arises.

In accordance with the FCA Handbook, types of conflicts may arise in the course of providing a service when the firm or its employees:


a)     is likely to make a financial gain, or avoid a financial loss, at the expense of the client;

b)     has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;

c)     has a financial or other incentive to favour the interest of another client or group of clients over the interest of the client;

d)     carries on the same business as the client; or

e)     receives (or will receive) from a personal other than the client an inducement in relation to a service provided to the client, in the form of monies, goods or services, other than the standard commission fee for that service.

Sharp Equity has developed a range of policies and procedures to identify, mitigate and control conflicts of interest. The policy is reviewed regularly to ensure the record of conflicts is up to date and relevant and the appropriate controls are in place. Reviews are reported to Sharp Equity’s senior Directors on a regular basis.


Sharp Equity has additionally incorporated various policies and procedures as to how and when employees are allowed to undertake personal account transactions as well as implemented restrictions on the offering and receipt of gifts to or from clients and other business counterparties. Staff’s external directorships or other business interests are additionally monitored to ensure they do not conflict with their duties to Sharp Equity and its clients.


Should any personnel or client become aware or are concerned about a potential conflict of interest, they should discuss such issues with the Compliance Officer. Please contact info@sharpequity.co.uk, for additional information.