Marketing Policy

Boccard is highly committed to responsible and sustainable decision-making in all aspects of our operations. We work in partnership to plan, grow and protect our clients’ financial futures. Our desire as an organisation is to deliver positive impact, both socially and environmentally, through our advice and business operations, including in our marketing operations. This Responsible Marketing Policy covers all of our marketing activities, ensuring we hold ourselves accountable to the highest standards, in line with the expectations of all our stakeholders, which includes clients, employees, shareholders, and society.

Use of Imagery

All Boccard imagery, and the language we use, follows demographic national averages, supplied by local and regional census data within the European Union as well as other regions in which we operate. This ensures the appropriate representation of society as well as our client pool, including age, gender, ethnicity, and disability. Whether through the written or spoken word, photography, or illustration – all our content is intended to be true-to-life, impactful, and reflect the humanity that our company, and its people, represent.

Compliance and Oversight

All marketing activity and communications are subject to a financial promotion policy, covering anything that promotes the Boccard brand, the products available, or the services offered. Within the UK and BVI, all relevant collateral is reviewed and approved considering all the following criteria: (a) what it is and how it’s going to be used, (b) who the audience is going to be, (c) the FCA Rulebooks, (d) Advertising Standards Authority, and (e) whether and where risk warnings are needed. In addition, marketing specialists review statements of fact made, language used, spelling and grammar. This process is constantly monitored and optimised to ensure the best outcomes for all stakeholders.

In addition, all marketing activity within the UK and BVI follows the high-level principles set out by the FSC, with a commitment to act with integrity, due skill, care, and diligence, pay due regard to the interests of clients and to treat them fairly, and pay due regard to the information needs of our clients and communicate information to them in a way in which is clear, fair, and not misleading.

Conflicts of Interest

In all of our communications and marketing materials, including correspondence from our Relationship Managers, we will disclose any circumstances that may potentially lead to a conflict of interest, or that may give rise to the impression of conflict of interest, regardless of whether or not a conflict of interest is actually in existence.

Examples of such circumstances may include, but are not limited to: (a) the fact that a Boccard employee might be in a position to personally benefit from any investment made by a client, excepting the standard internal compensation, (b) the fact that a Boccard employee is related to a third-party who is involved in a transaction being reviewed by a client, (c) the fact that a Boccard employee may have a financial interest in an investment decision being considered by a client, (d) the fact that a third-party fund manager or financial professional was formerly an employee or board member of Boccard within the past 3 years.

Use of Social Media to Conduct Business

Boccard employees are not permitted to indicate their status of employment at Boccard on their personal social media accounts (including, but not limited to Facebook, Twitter/X, Instagram, LinkedIn, Threads, TikTok, YouTube, Snapchat, Reddit and Clubhouse) or to use these same social media accounts in any way to solicit or conduct business on behalf of Boccard, or promote or advertise any offers related to Boccard, in any way. This covers the promotion and advertisement of specific products or services as well as of Boccard (or any of its affiliated companies) in general. Any correspondence from Boccard employees via their social media accounts shall strictly be regarded as having been undertaken in their personal capacities, and not in their professional capacities, and as such, does not represent Boccard in any way. Accordingly, Boccard disclaims any and all legal liability in regards to communications from employees purporting to make representations or warranties via their personal social media accounts.

Email Lists, Data-Crawling and Other Lead Generation Practices

Boccard does not permit the utilisation of any software or digital tools whose function or purpose is to crawl web pages for personal or professional data for the purposes of soliciting business or generating leads.

Apart from sending out newsletters or memoranda containing updates on certain financial, commercial or regulatory developments (including Boccard’s analysis or opinion of such developments), Boccard does not engage in sending unsolicited e-mails to current or prospective clients for the purposes of marketing or advertising. This covers the promotion and advertisement of specific products and services as well as of Boccard (or any of its affiliated companies) in general.

Copyright 2022, Boccard Asset Management Limited. Incorporated in the British Virgin Islands.

Expiration: 31/12/2026 Approval Date: 01/09/2023 Review Code: KS3665333

Investment advisory services and brokerage services are distinct and separate. Each service differs in material ways and is governed by different laws, regulations and internal policies. It is important that you understand the ways in which we conduct business, and that you carefully read the agreements and disclosures that we provide to you about the products or services we offer. For more information, please ask your Boccard Financial Advisor for a copy.

The products, services, information and/or materials contained within these web pages may not be available for residents of certain jurisdictions. Please consult the sales restrictions relating to the products or services in question for further information.

Copying, editing, modifying, distributing, sharing, linking or any other use (whether for commercial purposes or otherwise) of this material, other than personal viewing, without prior written permission from Boccard is strictly prohibited.

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Copyright 2024, Boccard Asset Management Limited.

Investment advisory services and brokerage services are distinct and separate. Each service differs in material ways and is governed by different laws, regulations and internal policies. It is important that you understand the ways in which we conduct business, and that you carefully read the agreements and disclosures that we provide to you about the products or services we offer. For more information, please ask your Relationship Manager for a copy.The products, services, information and/or materials contained within these web pages may not be available for residents of certain jurisdictions. Please consult the sales restrictions relating to the products or services in question for further information.

The contents of this web page are proprietary. Copying, editing, modifying, distributing, sharing, linking or any other use (whether for commercial purposes or otherwise) of this material, other than personal viewing, without prior written permission from Boccard is strictly prohibited.

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