Thank you so much for choosing to find out more about how we operate. If you have any questions about this Compliance Statement, please contact us on firstname.lastname@example.org.
1. Legal entity information
We are Fat Gladiator Limited (“Fat Gladiator”), a company registered in England and Wales with the registration number of 12969075 and a registered office at NT Accountancy, Chartered Accountants, 43 Lynton Mead, London, N20 8DG. Our registered VAT number is GB361770004. We are an appointed representative of Messels Limited which is authorised and regulated by the Financial Conduct Authority (“FCA”).
2. Compliance with requirements and best practices
We take compliance with all applicable laws, statues, regulations, and codes in force seriously. This includes in respect of insider dealing, market abuse, anti-money laundering, anti-bribery and corruption and anti-slavery and human trafficking. As a club with a social conscience, we ensure to comply with best practices and industry standards when operating and conducting our club at all times.
3. Services that we provide
The Fat Gladiator club is an exclusive club which (a) introduces and facilitates investment opportunities to its members through its meetings and events and (b) offers its members with benefits in the areas of lifestyle, travel, health and wellness.
If you’re interested in finding out about the club, please contact our Head of Membership by clicking here: https://fatgladiator.com/enquiry/.
4. Conflict of interest
Under Principle 8 of the FCA’s Principles for Business, a firm is required to “manage conflicts of interest fairly, both between itself and its customers and between a customer and another client”.
Under the Markets in Financial Instruments Directive (“MiFID”), a firm is required to maintain the operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage such conflicts of interests.
Fat Gladiator has put in place the appropriate policies and procedures to manage conflicts of interest and to safeguard the interests of its clients and counterparties (collectively referred to as “customers”).
4.1. What is a conflict of interest?
A conflict of interest is a conflict that arises in any area of Fat Gladiator’s business in the course of providing its customers with a service which may benefit Fat Gladiator (or a customer for whom Fat Gladiator is acting) whilst potentially materially damaging another customer to which Fat Gladiator owes a duty.
4.2. When could a conflict of interest arise?
Conflicts of interest could arise between:
- customers with competing interests;
- customers and Fat Gladiator where their respective interests in a particular outcome may be different; and
- the personal interests of staff at Fat Gladiator and the interests of Fat Gladiator or its customers whose interests may be different.
There may be a conflict where Fat Gladiator (or anyone connected to Fat Gladiator including another Fat Gladiator affiliate):
- is likely to make a financial gain (or avoid a loss) at the expense of its customer;
- is interested in the outcome of the service provided to its customer where the interest of Fat Gladiator is distinct from that of the customer;
- has a financial or other incentive to favour the interests of one customer over another;
- carries on the same business as a customer; or
- receives money, goods or services from a third party in relation to services provided to a customer other than standard fees or commissions.
Fat Gladiator has sought to identify conflicts of interest that exist in its business and has put in place measures it considers appropriate to the relevant conflict in an effort to monitor, manage and control the potential impact of those conflicts of interest.
4.3. What is our approach on managing conflicts of interest?
Fat Gladiator has adopted internal policies and procedures in order to manage conflicts of interests. Our policies and procedures allow us to:
- identify circumstances which may give rise to conflicts of interest entailing a material risk of damage to customers’ interests;
- establish appropriate mechanisms and systems to manage those conflicts; and
- maintain systems and records (such as in our Conflicts Register) in an effort to prevent actual damage to customers’ interests through identified conflicts.
Examples of key content covered in our policies and procedures is summarised below.
4.3.1. Integrity and standards of conduct – We insist that in our dealings with customers, our staff must use the highest standards of integrity in their actions at all times. Our induction programme, training and competency procedures and monitoring programme are designed to ensure that all relevant staff are familiar with and observe, inter alia, the FCA Principles for Business and the Statement of Principle and the Code of Practice for Approved Persons.
4.3.2. Personal account dealing – We have a Personal Account Dealing Policy which is required to be reviewed and signed-off as understood by all relevant employees regardless of their position within Fat Gladiator.
4.3.3. Confidentiality and information barriers – We insist on strict customer confidentiality to ensure that information is disclosed only to those entitled to receive it or otherwise with the prior approval of the Compliance function.
4.3.4. Inducements to employees from customers – Our staff are not allowed to accept gifts, entertainment or any other inducement from any person which might benefit one customer at the expense of another when conducting investment business. We have a Gifts & Entertainment Policy, which is part of our Compliance Manual and is monitored by senior management on a regular basis.
4.3.5. Remuneration – We have a Remuneration Policy in place whereby all staff who are open to a conflict of interest are paid a basic salary including those in key support functions such as Compliance, Finance and Operations. We have a discretionary bonus scheme which is linked to the company’s performance, performance of the individual and their adherence to our compliance standards.
4.3.6. Separate supervision and segregation of function – Where appropriate, we have arranged for the separate supervision of those carrying out functions for customers whose interests may conflict, or where the interests of customers and Fat Gladiator may conflict. We also take steps to prevent the simultaneous or sequential involvement of a relevant person in a separate services or activities where such involvement may impair the proper management of conflicts of interest.
4.3.7. Disclosure – Where there is no other means of managing the conflict or where the measures in place do not, in our view, sufficiently protect the interests of customers, the conflict of interest will be disclosed to the relevant customers to enable an informed decision to be made by each customer as to whether they wish to continue doing business with us in that particular situation.
4.3.8. Declining to act – Where we consider that we are not able to manage a conflict of interest in any other way, we will decline to act for a customer.
All investment research issued by us is independent, impartial and objective. We do not conduct any investment business with or for our customers, other than the provision of investment research and advice. We do not carry out any corporate finance business and have no involvement in raising capital for corporate finance. We have no other regulated or unregulated activities which conflict with our provision of independent research.