1. Overview

The key focus of managing conflicts is to ensure our research, strategies and/or recommendations have credibility and integrity and can reasonably be relied upon by our clients.

Although authorised pursuant to its AFS Licence to do so, RCC does not provide personal advice. Notwithstanding, RCC will take into consideration our clients’ best interest. In addition, RCC does not receive conflicted remuneration and does not provide its representatives conflicted remuneration.

2. Structural Arrangements to Manage Conflicts of Interest

RCC uses the following mechanisms to manage conflicts of interest:

• controlling the conflicts of interest;
• disclosing the conflicts of interest; and/or
• avoiding the conflict of interest.

3. Procedures for Controlling Conflicts of Interest

To control conflicts of interest RCC has:
• identified the conflicts of interest relating to its business;
• assessed and evaluated those conflicts; and
• decided upon, and implemented, an appropriate response to those conflicts.

(a) Remuneration practices
RCC has minimal conflicts of interest with regard to providing its services and it is controlled by clearly disclosing the remuneration structure in the FSG.

All RCC representatives (who are employees) are remunerated by way of salary and discretionary bonus based upon performance. Authorised Representatives are paid a fee per chart analysis they provide. Accordingly, the control implemented to manage this minimal conflict of interest is to ensure all recommendations are based on thorough and complete research.

(b) Treating clients fairly
RCC provides generic recommendations based on technical analysis undertaken. Accordingly, all clients receive the same advice based on RCC’s view and thus, all clients are treated the same.

4. Procedures for Disclosing Conflicts of Interest

Representatives of RCC (or any associated person) may, at times have a legal or beneficial interest in the financial products that are the subject of the financial product advice if they have invested in that product.

The Directors of RCC (and its other representatives) will disclose if they hold a position that is being recommended on the appropriate webpage of the secure area of the website. This information will be easily found and prominent to clients.

All research reports are issued (distributed) after the ASX market close allowing clients to implement any recommendations they choose to follow on the opening of the ASX market. The Directors of RCC (and its other representatives) may also choose to implement the RCC recommendation and will do so on the opening of the ASX market.