Piper Jaffray Ltd.

Conflicts of Interest Policy

 

This Conflicts of Interest (COI) Policy applies to Piper Jaffray Ltd. our UK based broker-dealer, referred herein as "PJL."

Overview / Background

Piper Jaffray Ltd. is engaged in a wide variety of financial services, including securities sales and trading, corporate and investment banking, private asset management and research. In compliance with our statutory obligations, this document defines our Conflict of Interest Policy (“COI” Policy) maintained by PJL in respect of our regulated activities carried out within the European Economic Area.

PJL is committed to maintaining the highest professional standards and principles to our clients. The interests of clients must come first and PJL’s COI policy and related policies and procedures address and manage conflicts as they arise to ensure your interests are well served.

PJL defines a Conflict of interest (COI) as a situation in which a person or organization has multiple interests which could possibly influence or otherwise effect the motivation of the individual or organization. It is important to note that the mere existence of a conflict is not indicative of any impropriety, but rather prompts the Firm’s obligation to disclose, manage and/or eliminate the conflict.

COIs present unique challenges to the financial services industry, the core of which is determined by complexities of human behavior and the motivation behind it. Financial services firms frequently act as intermediaries, whether as a financial advisor, investment banker or in another capacity, and must manage competing interests in these situations. At PJL, we continually strive to avoid conflicts of interest where possible, and otherwise to manage them as effectively as we can by first identifying the conflict and then by eliminating it, disclosing it or mitigating it in some other way.

The variety of actual and potential conflicts of interest we face is significant and changes as the markets and the industry evolve. Further, there is no "one-size-fits-all" approach to identifying or managing conflicts of interest. Each actual and potential conflict must be identified and then analyzed individually. This is an ongoing challenge, but one that we believe is essential to earning our clients’ trust.

PJL has its COI policy (and related policies and procedures) in place to identify, consider and manage potential conflicts of interest and protect the integrity of our relationships with professional, institutional and eligible counterparty clients. All PJL employees must comply with this policy and may not do indirectly, that which they are prohibited from doing directly under the COI policy.

POLICY

Every PJL employee is required, to continuously manage the COIs inherently present in our individual and collective business activities.

Conflicts are to be avoided or eliminated if possible. If conflicts cannot be avoided or eliminated, then we must manage them effectively by formally identifying them and mitigating them through meaningful controls and/or full disclosure.

Piper Jaffray is committed to managing conflicts by making decisions on the right level. This means recognizing that our Guiding Principles and Code of Ethics go beyond policies, rules and regulations. It means complying with the “spirit” or “intent” as well as the “letter” of the law, and actively doing what is right. It also means being willing to forego questionable business, even if others in the industry are engaged in it. We cannot feel safe in assuming that we are making an ethical decision simply because we are following the letter of the law and/or industry custom or practice.

Supervisory Controls and Compliance Review Procedures

As referenced above, COIs arise in any relationship where on one hand a duty of care or trust exist between two or more parties, and on the other hand the extent of benefits derived can be influenced by an act or omission. The financial services industry, like other industries, is challenged with such conflicts, and consequently, PJL has established a conflicts framework that incorporates an initial inventory of existing and potential conflicts; an assessment of the conflict in terms of the Firm’s ability to eliminate or otherwise manage and mitigate the conflict (including through disclosure); and finally, ongoing and periodic reviews of and for conflicts.

Conflicts of Interest Inventory

The PJL COI inventory consists of known and ongoing conflicts posed by employee’s personal activities as well as those inherent in PJL’s business activities.

In this regard, PJL utilizes a “conflict matrix” that identifies all known conflict categories from an enterprise-wide standpoint as well as by business line, and that includes within its inventory of conflicts an identifier as to whether the Level of Conflict is between:

While not an exhaustive listing, PJL has identified several categories of COI that we actively monitor and manage, including:

MANAGING CONFLICTS OF INTEREST

Generally speaking, once a COI is identified the Firm has three options to manage the conflict by (a) elimination; (b) management or supervision of the conflict; and/or (c) disclosure. To the extent possible and practical, it is always the goal of PJL to eliminate COI. Where a COI continues to exist, such COI is described in the Firm’s COI inventory, and also identifies the control process (policy and procedure) in place to manage the COI.

Although, it is not an exhaustive list, there are a number of methods that PJL uses to manage actual or potential conflicts of interest including:

ESCALATION PROCEDURES

PJL Compliance and Legal representatives coordinate conflict reviews with business line personnel. COIs are reviewed through various committees, such as investment banking commitment committees, as well as more holistically during the annual conflicts review. The Firm’s inventory of COIs is updated as appropriate, and periodically shared with PJL’s Leadership Team.

REVIEWING PJL'S COI POLICY

PJL will monitor the effectiveness of the COI policy and implement necessary changes from time to time. We will notify our clients of any material changes that may be relevant to you.

CONTACT FOR QUESTIONS

If you have any questions regarding our COI policy or our compliance with this policy, please contact you sales representative or PJL’s compliance department.