Hardman Co is committed to ensuring the good standing of its brand, and maintaining confidence in the integrity and credibility of all our services.
To meet this commitment, we abide by the principles below.
At the end of these principles, we outline the companies who who have paid us to produce research in the last 12 months.
The research reflects the objective views of the analyst(s) named on the front page and does not constitute investment advice.
All information used in our publication comes from publicly available sources that are believed to be reliable. However, no guarantee, warranty or representation, express or implied, can be given by Hardman & Co as to the accuracy, adequacy or completeness of the information contained in the research and we are not responsible for any errors or omissions or results obtained from use of such information.
Our research is prepared purely for information purposes, and nothing in the reports should be construed as an offer, or the solicitation of an offer, to buy or sell any security, product, service or investment.
Our research is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Hardman & Co or its affiliates to any registration requirement within such jurisdiction or country.
Any forecast, fair value or view on a company or variable is made at the date on the note and is the opinion of the author of the report. Inevitably, conditions may change over time and events occur, which may mean that forecasts, fair values and opinions published on a particular date might no longer be valid.
Hardman & Co is under no obligation to revisit forecasts, fair values and opinions in the event of such changes. Absence of a further research note or commentary should not be construed to mean that the original forecasts, fair values and opinions remain valid, unless we specifically state so.
Whilst we endeavour to publish on our clients as soon as reasonably practical after an announcement, we are under no obligation to our client (the company) to do so by any deadline.
If we have written regularly about a company in the past, but do not do so shortly after an announcement, one of the following things has occurred:
It is not our general policy to announce the ending of a contract, and investors should understand that we would not comment on any of the other reasons.
Securities or legal entities mentioned in our research may not be suitable or appropriate for all investors. Where a note refers to a particular tax treatment, the tax treatment will depend on each investor’s particular circumstances and may be subject to future change. Each investor’s particular needs, investment objectives and financial situation are not taken into account in the preparation of our research and the material contained herein.
Each investor must make his or her own independent decisions and obtain their own independent advice regarding any information, projects, securities, tax treatment or financial instruments mentioned in our research. The fact that Hardman & Co has made available through this document various information constitutes neither a recommendation to enter into a particular transaction nor a representation that any financial instrument is suitable or appropriate for a particular investor. Each investor should consider whether an investment strategy of the purchase or sale of any product or security is appropriate for them in the light of their own investment needs, objectives and financial circumstances.
Some or all alternative investments may not be suitable for certain investors. Investments in small and mid-cap corporations and foreign entities are speculative and involve a high degree of risk. An investor could lose all or a substantial amount of his or her investment. Investments may be leveraged and performance may be volatile; they may have high fees and expenses that reduce returns
We pride ourselves on the experience and professionalism of our research team. All analysts have spent many years analysing companies for investment purposes and many have been highly ranked in the sectors by external parties, such as ‘Institutional Investor’.
The views expressed in our research are always that of the analyst/s detailed on the front of the note, based on their experience of the sector or similar companies. The analyst is expected to come to his/her opinions and views after a careful review of the available information about the company, an independent assessment of information about the sector and competitors, and by applying their professional experience to their research.
No client contract is entered into before approval by our Commitment Committee
Our client contracts for published research contain the following provisions:
In the event of a disagreement between the analyst and the company management about non-factual matters, the following steps are taken:
We are required to restrict the availability of research on some of our clients. For example, our research on ‘Non-Mainstream Pooled Investments’ is not available to any person who is a “U.S. person” or to any person who is physically present in the United States, and it is available only to persons who are “relevant persons” (as defined below) for U.K. regulatory purposes.
Investors will be required to self-certify, before they can gain access to such work.
Hardman & Co’s research fees
The analyst team consists of both employees and consultants.
As well as publishing research on companies, Hardman & Co undertakes investment engagement activities for select clients. This may include roadshows, webinars, lunches and forums.
These events are designed to enable investors to understand the business case and meet the management. At no stage in any of these events will Hardman & Co make a recommendation, and the holding or organisation of such events should not be construed as a recommendation or incitement to invest.
Hardman & Co is paid a set fee in cash by our clients for these events.
Hardman & Co may provide investment banking services to clients. In such an event, this will be explained in the disclaimer
Hardman & Co does not deal in any securities for its own book or on behalf of others, with one exception. We may take shares in a former client as payment because its financial position is such that payment in this way is the only practical way to meet their liability; if we do so we would seek to dispose of those shares as quickly as possible.
All members of the Hardman & Co team are required to abide by our code on personal dealing
Other parts of these principle cover potential conflicts of interest.
In addition, Hardman & Co staff, consultants and officers are barred from being employed or engaged by the companies or legal entities covered by our research. Their only engagement with our clients is through their relationship with Hardman & Co.
Criminal Finances Act 2017 (“CFA”).
In the course of its business, Hardman & Co processes personal data. We have internal policies and procedures that address data protection issues, to ensure data is handled and protected as required by GDPR.
Hardman & Co is registered at the Information Commissioner’s Office with reference number ZA409679
Hardman Research Ltd is an appointed representative of Capital Markets Strategy Ltd (Firm reference number 438697). Hardman Research Ltd has three trading names registered with the FCA (Hardman Research Ltd, Hardman & Co and Hardman Agribusiness). Hardman Research Ltd’s own ‘Firm reference number’ is 600843.
Documents which we publish constitute ‘financial promotions’ for the purposes of section 21 Financial Services and Markets Act 2000 (United Kingdom) (‘FSMA’) and accordingly have been approved by Capital Markets Strategy Ltd.
Hardman & Co is the trading name of Hardman Research Limited, whose company number is 08256259, and whose registered address is 9 Bonhill Street, London, EC2A 4DJ
Some professional investors, who have been subject to the MiFID II rules since 3rd January 2018, may be unclear about the status of Hardman & Co research and, specifically, whether it can be accepted without a commercial arrangement.
Hardman & Co’s research is paid for by the companies, legal entities and issuers about which we write and, as such, falls within the scope of ‘minor non-monetary benefits’, as defined in the Markets in Financial Instruments Directive II. In particular, Article 12(3) of the Directive states: ‘The following benefits shall qualify as acceptable minor non-monetary benefits only if they are: (b) ‘written material from a third party that is commissioned and paid for by a corporate issuer or potential issuer to promote a new issuance by the company, or where the third party firm is contractually engaged and paid by the issuer to produce such material on an ongoing basis, provided that the relationship is clearly disclosed in the material and that the material is made available at the same time to any investment firms wishing to receive it or to the general public…’
The fact that Hardman & Co is commissioned to write the research is disclosed in the disclaimer, and the research is widely available. The full detail is on page 26 of the full directive, which can be accessed here: http://ec.europa.eu/finance/docs/level-2-measures/mifid-delegated-regulation2016-2031.pdf
In addition, it should be noted that MiFID II’s main aim is to ensure transparency in the relationship between fund managers and brokers/suppliers, and eliminate what is termed ‘inducement’, whereby free research is provided to fund managers to encourage them to deal with the broker. Hardman & Co is not inducing the reader of our research to trade through us, since we do not deal in any security or legal entity
No part of any Hardman & Co document may be reproduced, stored in a retrieval system or transmitted in any form or by any means, mechanical, photocopying, recording or otherwise, without prior permission from Hardman & Co. By accepting our documents, recipients agree to be bound by the limitations set out in this notice. This notice shall be governed and construed in accordance with English law.
A list of companies who have paid us to produce research in the last 12 months are listed below: