Policies
Our clients and counterparties may wish to refer to the following policies which address various regulatory matters:
Complaints Handling Policy
At DCMD, we are committed to providing products and services of the very highest standards. If you feel that you have not received the products or services that you expected in any way, we would like to know so that we can investigate and further improve the service we provide.
Details of how to submit a complaint and how it will be handled by DCMD are outlined in DCMD’s Complaints Handling Policy.
Terms of Business
The following Terms of Business (ToBs) set out the basis on which DCMD will provide services to you:
Data Privacy Notice
In our Data Privacy Notice, we provide you with information on how DCMD collects and processes your personal data through our interactions with you, whether they be via your use of our website, your subscription to our marketing communications, or information that you or your employer may provide to us in the ordinary course of business.
It is important that you read this Data Privacy Notice together with any other data privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Data Privacy Notice supplements the other notices and is not intended to override them.
Best Execution
DCMD is required to establish and implement a best execution policy and provide appropriate information on this to its clients. This Best Execution Policy Notice is intended to summarise the details of this.
The policy and arrangements are designed to allow DCMD to obtain the best possible result when executing orders on our clients’ behalf in accordance with MiFID II (specifically Directive 2014/65/EU article 27 para. 1 and Delegated Regulation (EU) 2017/565 article 65 para. 4).
Cost and Charges Disclosure Notice
Information in relation to ex-ante aggregated costs and associated charges for DCMD’s investment services and financial instruments in accordance with MiFID II article 24 para. 4 (c) are outlined in our Cost and Charges Disclosure Notice.
Conflicts of Interest Summary
Daiwa Capital Markets Deutschland GmbH ("DCMD") is part of the Daiwa Securities Group Inc, which is an independent full-service securities group providing an extensive range of financial services centred on retail, wholesale and investment banking business and asset management business. Daiwa Capital Markets Europe Limited ("DCME"), parent company of DCMD (holding 100% of its ownership), is responsible for providing institutional clients with sales & trading and investment banking services.
We continue to recognise that in the normal course of our business, circumstances may arise that could result in our interests conflicting with the interest of, or with the duties we owe to, our clients. These could include conflicts between the interests of DCMD, or other group companies and our clients, or between the interests of different clients.
DCMD has always sought to ensure that conflicts are identified and managed at an appropriate level. Procedures have therefore been established to protect the interests of our clients and ensure that all parties are treated fairly and reasonably. In particular, arrangements exist to control the flow and use of non-public, price sensitive information, the execution of client orders, staff’s personal account dealing and their receipt of gifts or other inducements from clients or suppliers.
Where necessary, we segregate the activities of staff working in areas where conflicts of interest may arise. Where we feel that our procedures in themselves may be insufficient to manage the risk we will look to disclose the potential conflict to our client and obtain their agreement to precede. Ultimately we will decline to act where we feel the risks cannot be managed or mitigated. DCMD may share information regarding investment banking relationships with other group companies. The list of group companies can be viewed here (under ‘Company Structure’): http://www.uk.daiwacm.com/about-us/overview.
The risks and associated controls relating to conflicts of interest have been documented internally in the Conflicts of Interest Map. This map details the potential conflicts of interest in each department and the controls in place to mitigate these risks. The Conflicts of Interest Map is subject to regular review.