Compliance

Terms of Use of this Website

This website is provided by RFC Ambrian Group Ltd and its associated entities (together “RFCA”), including RFC Ambrian Limited (in Australia & UK) and RFC Ambrian Funds Management Pty Ltd, for the purpose of providing general information on RFCA’s business and activities and is subject to the following terms and conditions (“Terms”). By accessing and using this website you agree to these Terms.

Intellectual Property and Copyrights

All information, text, material, graphics, software and functionality (“Content”) on this website are the exclusive property of RFCA (or third parties) and is protected by Australian and international copyright laws. Provided that you keep all Content intact and in the same form as presented on the website you may download and view the Content for your personal, non-commercial use. You must otherwise not copy, modify, reproduce, republish, upload to a third party, post, transmit or distribute the Content in any way unless expressly authorised in writing by RFCA. All rights not expressly granted are reserved by RFCA.

No Representation or Warranty in Relation to Content

Except as required at law, RFCA does not represent, warrant and/or guarantee the accuracy, quality, integrity and currency of the Content of this website. RFCA has no obligation to update this website nor advise of any changes to its Content or information relevant to its Content. Nor does RFCA represent, warrant and/or guarantee that the Content of this website is free from any computer virus or any other defects or errors. Nor does RFCA provide any representation, warranty or guarantee in relation to the content of any website to which a link is provided on this website.

Except as required at law, RFCA accepts no liability in relation to any reliance on the Content of this website or in relation to the use of this website.

Nothing on this Website Constitutes Financial Advice or an Offer of Any Kind
Nothing in the Content of this website should be taken to constitute financial advice or an offer or solicitation of any kind, including advice or recommendation in relation to the subscription, purchase or sale of any securities or investments. RFC Ambrian Limited (Australia) is the holder of AFS Licence No. 233214. RFC Ambrian Funds Services Pty Ltd is the holder of AFS Licence No 560168. RFC Ambrian Limited (UK) is authorised and regulated by the Financial Conduct Authority.

Research Conflicts of Interest Procedures

Research underlies all aspects of RFCA business, from new issues and secondary fundraisings, through to supporting our corporate broking, corporate finance, and sales and trading teams. The quality, accuracy and timeliness of our equity research is key to our ability to service our institutional and corporate clients and, in light of this, we have built a team of analysts covering our core sectors.

RFCA adopts a team approach to stock and sector selection. We recognise that market sectors are linked to each other. By maximising dialogue between our sector analysts we gain a perspective on the stock market as a whole, helping us to identify broader economic trends and their likely effect on stock prices. We have implemented policies and procedures to monitor and mitigate the potential conflicts of interest involved in the preparation and publication of research. To view the complete research policy document please click here.

For all companies covered by RFCA research please contact publications@rfcambrian.com to ascertain where RFCA has a business relationship with the company or a material interest in the company, which could potentially conflict with our obligation to ensure that our investment research is clear, fair and unbiased.

RFC Ambrian Limited High Level Policy for Managing Conflicts of Interest

RFCA, as a multi-product financial services group, will inevitably find itself in situations where the interests of one client may compete with (i) those of another client; or (ii) the interests of RFC and/or its employees. In common with many financial institutions, RFC Ambrian has appropriate arrangements in place to identify and manage the conflicts which may arise during the normal course of its business activities.

This document summarises, at a high level, RFCA’s approach to identifying and managing conflicts of interest and has been prepared in accordance with the requirements imposed upon the Firm by the Markets in Financial Instruments Directive (“MiFID”). It is for information purposes only and does not seek to provide detailed descriptions of the RFCA’s internal processes and procedures in relation to the identification and management of conflicts of interest. To view the complete conflicts of interest document please click here.

Links to other Web Sites

RFCA may provide links to other websites but RFCA does not accept any responsibility for the content of those web sites. Linking to any other web site is at your discretion.

1. Summary

RFC Ambrian Group Limited (ABN 98 096 493 588) and its subsidiaries (“RFC Ambrian”) appreciate the importance of its role in handling and storing your personal data. This Privacy Statement explains how RFC Ambrian will manage the personal data which we may collect, use, store and disclose in the course of our  business relationship.

RFC Ambrian’s Privacy Statement has been drafted to comply with the requirements of the privacy legislation in the jurisdictions in which we operate, including but not limited to the Australian Privacy Act 1988 (Cth), Australian Privacy Principles and the EU’s General Data Protection Regulation (GDPR).

If you would like to contact us to discuss any aspect of this Statement, the contact details for RFC Ambrian are listed at the end of this page.

2. The legal basis for data collection and processing

We collect and use your personal data:

• when it is necessary for the performance of a contract or for pre-contractual negotiation
• when we are required to do so by law
• when we have your free and informed consent or
• when we have other legitimate interests that do not override your personal interests or rights

3. Principles of privacy and data protection

In processing your personal information, we will ensure your data is:

• processed fairly, lawfully and transparently
• obtained for specified and lawful purposes, and processed only in relation to those purposes
• collected and processed only to the degree necessary for the purpose
• securely destroyed when no longer required
• recorded accurately and, where necessary, kept up to date
• not kept for longer than is necessary
• protected against accidental loss, unauthorized use, disclosure or processing
• generally processed in the jurisdiction in which it was collected. If data transfer is required to another of our offices, equivalent protections are in place in the alternative jurisdiction

4. The information we collect

Personal data we collect is primarily contact information (eg. name, phone, email address) which enables us to communicate with you.

Other confidential personal information may be collected when it is reasonably necessary for the performance of a corporate financial transaction, the recruitment process, the employee relationship or a variety of other financial dealings.  We will inform you of the intended use of the information at the point we collect it from you (usually by a privacy note on our business documentation or web form).  We will also refer you to this Policy Statement.

To satisfy our legal and/or commercial obligations we may collect and use information such as:

• date, place of birth and other information used to identify you
• banking or trading account details
• membership to organisations and professional bodies
• employment history and education details
• driver’s licence or passport details
• government identifiers such as tax file numbers or National Insurance number

Wherever possible we collect information directly from you via one or more of the following modes:

• completion of transaction documentation
• completion of forms
• an interview or meeting
• shared business card or
• any other direct communication with us (email, online, letter, fax, telephone call, videoconference).

We do not buy and sell personal data.

5. Anti-Money Laundering legislation

RFC Ambrian operates in jurisdictions which require it to comply with laws designed to combat money laundering and terrorism financing.  For some transactions we may be required by law to collect and verify particular personal information before we can deliver certain services to you. We are mindful of the apparent intrusiveness of these identification procedures and the staff you deal with would be pleased to discuss any concerns you may have. We may be required to store your personal identifying information for statutorily defined durations.

6. Cross border disclosure

RFC Ambrian operates from offices in Australia and the United Kingdom which may give rise to the need to transfer data between these two jurisdictions.  Such data transfers may only occur in accordance with this Privacy Statement and will be subject to the same administrative and technical controls.

7. Cookie Policy & information collected via our website

RFC Ambrian employs limited use of ‘cookies’ in the operation of its website.  These small text files enable our website to interact with your web browser (on your computer or mobile device) helping us to analyse how our website is used, which countries our website traffic comes from and to assist with providing an efficient user experience to you.

The cookies cannot collect any information stored on your computer or device. Although cookies can identify your IP address, RFC Ambrian has no means of identifying you from this information unless you supply personal details by submitting the information on our contact form. Where you are accessing our online dataroom facilities on this website using log-in information provided, you are responsible for the security of the log-in information and take responsibility to ensure the confidentiality of this information.

8. Security of your personal information

At all times RFC Ambrian will take such steps as are reasonable in the circumstances to protect your data from unauthorised access, unnecessary duplication, modification and disclosure or for uses not consistent with this policy. These measures include having appropriate policies in place, staff training, utilization of passwords and network wide security measures.

It should be noted however that it is impossible to fully guarantee security for communications conducted over the internet. Therefore, you should note that you also have a role to play in maintaining the confidentiality of your personal information such as strong password protection, encryption and physical security of your private data.

The majority of our information, including your personal information may be held on our computer network which is maintained by a third-party specialist IT company which monitors the integrity of our systems and equipment. We also may maintain paper records which are held securely in our offices. When your data is no longer required operationally or by law it will be securely disposed of, deleted, de-identified or put ‘beyond use’.

Compulsory staff training is conducted to ensure staff are familiar with appropriate management of private data and actions to be taken in the case of any data breach.

If a breach occurs the appropriate authority will be notified.  If there is a likely risk to an individual, they too will be notified to enable them to mitigate that risk.

9. Your rights

You have the right to

• be informed of the reasons we collect your personal information
• request a copy of your personal data from us
• request correction or deletion of your personal information
• ask us to stop processing your information for direct marketing process

Please note that there are some circumstances where we may be restrained by law from providing or correcting your information.  Wherever possible we will advise you of the reasons we cannot comply with your request.

10. Contact information

Please direct requests, enquiries or complaints to the Compliance Officer at one of the offices below or via email at rfcambrian@rfcambrian.com

Privacy Complaints may also be directed to the Information Regulator in each jurisdiction.

The Office of the Australian Information Commissioner: www.oaic.gov.au

The Information Commissioner’s Office: www.ico.org.uk