Aggregation of Orders

Statement of Policy

  • We may combine a customer order with own account orders, orders of connected person and orders of other customers.
  • It is essential, however, that by combining such orders we must reasonably believe that we will obtain a more favourable price for customers than if the orders had been executed separately.

Anti Bribery and Corruption Policy

1. Introduction.

M.D. Barnard & Co. Ltd values its reputation and is committed to maintaining the highest level of ethical standards in the conduct of its business affairs. The actions and conduct of the firm’s staff as well as others acting on the firm’s behalf is key to maintaining these standards.

The purpose of this document is to set out the firm’s policy in relation to bribery and corruption. The policy applies strictly to all employees, directors, agents, consultants, contractors and to any other people or bodies associated with M.D. Barnard & Co. Ltd.

2. Understanding and recognising bribery and corruption

Acts of bribery or corruption are designed to influence an individual in the performance of their duty and incline them to act in a way that a reasonable person would consider to be dishonest in the circumstances.

Bribery can be defined as offering, promising or giving (or other) advantage to another person with the intention of inducing or rewarding that person to act or for having acted in a way which a reasonable person would consider improper in the circumstances. Corruption is any form of abuse entrusted power for private gain and may include, but is not limited to, bribery.

Bribes are not always a matter of handling cash. Gifts, hospitality and entertainment can be bribes if they are intended to influence a decision.

3. Penalties

The Bribery Act 2010 came into force on 1 July 2011. Under the Act, bribery by individuals is punishable by up to 10 years imprisonment and/or an unlimited fine. If the firm is found to have taken part in the bribery or is found to lack adequate procedures to prevent bribery, it too could also face an unlimited fine.

A conviction for bribery or corruption related offence would have severe reputational and/ or financial consequences for the firm.

4. M.D. Barnard & Co. Ltd Policy

M.D. Barnard & Co. Ltd will not tolerate bribery or corruption in any form.

The firm prohibits the offering, giving, solicitation or the acceptance of any bribe or corrupt inducement, whether it be cash or in any other form:

  • To or from any person or company wherever located, whether a public official or public body, or a private person or company.
  • By any individual employee, director, agent, consultant, contractor or other person or body acting on the firm’s behalf.
  • In order to gain any commercial, contractual, or regulatory advantage for the firm in any way which is unethical or to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.

This policy is not intended to prohibit the following practices provided they are appropriate, proportionate and are properly recorded:

  • Normal hospitality provided that it complies with the firm’s Corporate Entertainment Policy.
  • Fast tracking a process which is available to all on the payment of a fee; and/or
  • Providing resources to assist a person or body to make a decision more efficiently, provided that it is for this purpose only.

It may not always be a simple matter to determine a possible course of action is appropriate. If you are in any doubt as to whether a possible act might be in breach of this policy or the law, the matter should be referred to your Head of Department/ Office Manager. If necessary, guidance should also be sought from the Compliance Officer or Managing Director.

The firm will investigate thoroughly any actual or suspected breach of this policy, or the spirit of this policy. Employees found to be in breach of this policy may be subject to disciplinary action which may ultimately result in their dismissal.

5. Key Risk Areas

Bribery can be a risk in many areas of the firm. Below are the key areas you should be aware of in particular:

Excessive gifts, entertainment and hospitality: can be used to exert improper influence on decision makers. Gifts, entertainment and hospitality are acceptable provided they fall within the firm’s Corporate Entertainment Policy.

Facilitation payments: are used by businesses or individuals to secure or expedite the performance of routine or necessary action to which the payer has an entitlement as of right. The firm will not tolerate or excuse such payments being made.

Reciprocal agreements: or any other for of ‘quid pro quo’ are never acceptable unless they are legitimate business arrangements which are properly documented and approved by Management. Improper payments to obtain new business, retain existing business or secure any improper advantage should never be accepted or made.

Actions by third parties for which the firm may be held responsible: can include a range of people i.e. agents, contractors and consultants, acting on the firm’s behalf. Appropriate due diligence should be undertaken before a third party is engaged. Third Parties should only be engaged where there is a clear business rationale for doing so, with an appropriate contract. Any payments to third parties should be properly authorised and recorded.

Record Keeping: can be exploited to conceal bribes or corrupt practices. We must ensure that we have robust controls in place so that our records are accurate and transparent.

6. Employee responsibility and how to raise a concern

The prevention, detection and reporting of bribery or corruption is the responsibility of all employees throughout the firm. If you become aware or suspect that an activity or conduct which is proposed or has taken place is a bribe or corrupt, then you have a duty to report this immediately.

If any employee has a concern about malpractice, he/she should raise the concern with his/her line manager. If they are unable to do this, it should be raised with the Compliance Officer who will investigate the matter. Such approaches will be treated in confidence and with discretion.


This document describes the conflicts and potential conflicts that may arise during the course of our business and how we at M.D.Barnard & Co. Ltd mitigate, avoid or plan to manage those conflicts.

We are bound by the rules of the Financial Conduct Authority and this policy is designed to meet our obligations under those rules.

We are required to maintain and operate effective organisational arrangements to prevent conflicts of interest arising or giving rise to material risk of damage to the interests of our clients. This allows us to assess any potential conflict or circumstances giving rise to an actual conflict with a degree of autonomy/distance from the business. If we identify potential conflicts that are not covered by this document these will be assessed by the Managing Director or Compliance Department.

Where we do not have conflicts:

M.D.Barnard & Co. Ltd does not trade for their own account and so we do not have conflicts which would result from proprietary trading.

M.D.Barnard & Co. Ltd does not operate a corporate finance function and therefore we do not have any conflicts which would result from offering these services to clients.

Investment research is not published or made available to clients.

Where we do have conflicts:

Conflicts may arise from the way we do business in the following ways:

  1. When we act for multiple clients.
  2. Where we are involved in the allocation of new shares through Placings.
  3. Where our employees are in receipt of gifts.
  4. Where our employees have outside business interests.
  5. Where our employees trade for their own account.
  6. In how we remunerate our employees.
  7. Where we receive complaints about our service.

1. Multiple clients

We have a large client base and as such there may be times where the action of one client conflicts with the actions of another. For example, where we invest in a stock for one client and take a sale order from another client. All of our discretionary clients have their own personal broker whose role is to manage their investments depending upon the service that is required. Your personal broker will always act in your best interests based upon what is suitable for your needs. We operate a best execution policy which ensures that all orders are dealt with sequentially and without bias.

2. Allocation

From time to time we may become aware of the issuance of new shares (Placings) in a company where we would recommend the purchase of such shares. However, we may not be able to obtain all the shares we would like and on occasion fall short of that amount. Our policy is then to allocate investments on a pro rata basis wherever practical.

Where we obtain such a small allocation of shares that we feel is not practical to make a distribution across the whole client base, there may arise a conflict between clients, as we choose which clients should be asked to participate in the Placing. The alternative would be charging each client a fixed amount for a nugatory number of shares, which would neither be practical nor acting in the collective best interests of our clients.

Before allocating investments to clients, we first comply with our regulatory obligations to assess suitability – it is our primary policy to offer allocations to clients for whom the investment is suitable or appropriate. Then we determine which clients have sufficient funds by the commitment date and both understand the investment’s terms and conditions and are willing to be bound by them.

On other occasions we may also be given a fixed number of shares with the allocation already determined by the issuing company, known as a “Chairman’s List” where we are granted no discretion over the recipients of the shares.

3. Gifts

It is the policy of the firm that Brokers may not accept a gift valued at over £100 without the prior consent of either the Managing Director or the Compliance Department. Such permission must be withheld if a conflict is considered likely betweens the firm’s clients and the Director if such a gift is accepted.

4. Outside Business Interests

There may be situations where our employees operate their own business in addition to the role they carry out for us. We require all employees to disclose any such interests to us and would restrict any that may conflict with a persons’ work at M.D. Barnard & Co. Ltd.

5. Personal Account Dealing

Our staff may operate their own personal dealing account subject to our internal policy. This policy includes restrictions for certain employees and post trade review of all trades by the Managing Director & Compliance Department.

6. Remuneration

Our employees are remunerated by a combination of salaries and discretionary bonuses. There is no sales-linked element. Introductory agents are remunerated on a shared commission basis and they are monitored and supervised in all aspects of the client relationship.

7. Complaints

Complaints made to us that cannot be resolved by the next business day enter our formal complaints procedure. This procedure is designed to ensure the fair treatment of clients. Where compensation is due to a client this may be financially detrimental to a broker and may prevent them from treating the client fairly. The Compliance Department is independent of the broker – client relationship.

Disclaimer & Regulation

Target Audience

This website is intended for use only by investors who are resident in the United Kingdom and by Financial Advisors. In particular, this website is not for use by residents of the United States of America or other US person (as defined in The Securities Act 1933).


Information on this site has been obtained from sources which we believe to be accurate but cannot be guaranteed. Whilst all reasonable care has been taken to ensure the facts stated and any opinions expressed are fair, no member (staff or Account Executive) of M.D. Barnard & Co. Ltd shall in any way be responsible for the site contents. Prices, if shown, are factual details and are deemed to be correct at the time of publication but may change subsequently. Fluctuations in the rate of exchange may have an adverse effect on the value, price or income on non-sterling denominated investments. M.D. Barnard & Co. Ltd, its associates, employees and/or clients may own or have a position in securities referred to on this website.

Nothing on this website is intended to exclude or restrict any duty or liability which M.D.Barnard & Co. Ltd may have under the Financial Services and Markets Act 2000 (or any replacement legislation) or the rules and regulations for the conduct of business hereunder.

For the purpose of the Financial Services and Markets Act 2000, this website has been approved by M.D. Barnard & Co. Ltd which is authorised and regulated by the Financial Conduct Authority.

Non Offer, Non Recommendation

This website is solely for the provision of information and does not constitute an offer to buy or sell any stock, share or other product mentioned herein. No advice is given nor implied. This website serves only to help clients (or prospective clients) to make their own investment decisions. Accordingly, it may not be suitable for all users and does not constitute a personal recommendation to invest.

You should seek your own professional advice as to the suitability of any such investment or service before you enter into any transaction.

M.D. Barnard & Co. Ltd does not provide or offer advice to clients.

Past Performance

Past performance is not necessarily a guide to future performance. The value of investments and the income from them can fall as well as rise and investors may get back less than they originally invested. In the case of higher volatility investments, these may be subject to large or sudden falls in value.

If you have any doubts as to the suitability of this service you should seek advice from an Independent Financial Advisor.

Taxation Matters

Matters relating to levels and basis of tax relief are based on our current understanding of current tax legislation. M.D. Barnard & Co. Ltd are not specialist tax advisors and you should seek specialist advice regarding your personal tax situation and the consequences any investment decisions may have on your personal circumstances.

Regulatory Information

M.D. Barnard & Co. Ltd is registered in England and Wales. Registration Number: 2198303 Registered office: 17-21 New Century Road, Laindon, Basildon, Essex, SS15 6AG M.D. Barnard & Co. Ltd is a member of the London Stock Exchange and authorised and regulated by the Financial Conduct Authority, FCA number 124885.

Treating Clients Fairly Policy

M.D. Barnard & Co. Ltd. is committed to act in the best interests of our clients at all times.

In our dealings with you, we endeavour to:

  • Treat you fairly and assure you that fair treatment of our clients is embedded into our way of thinking.
  • Place your interests first.
  • Be open and transparent.
  • Communicate clearly.
  • Notify you of our charges in advance.
  • Handle complaints promptly and fairly.
  • Ensure our staffs are adequately trained.

Treating Clients Fairly Policy – Supporting Policies

Supporting Policies

These additional policies bolster our commitment to Treating Clients Fairly (TCF)

  • Order execution: to obtain the best possible results on behalf of our clients when executing orders or receiving and transmitting orders for execution.
  • Conflicts of interest: as set out in our Conflicts of Interest Policy.
  • Data Protection: the proper custody of sensitive client data.
  • Personal account dealing: the monitoring of personal dealing by account executives and staff to reduce the risk of conflicts of interest with clients.
  • Gifts and inducements: the observance of protocol on giving or accepting of gifts, ensuring there is no conflict with duties owed by the Company.
  • Clients complaints: responding and dealing with client complaints promptly and fairly.

Compliance Arrangements

  • Checks are carried out regularly to ensure that all Policies, as listed above, are achieved and are being conformed to.
  • The team manages a robust compliance monitoring programme.

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