Independent, unconflicted and FSA regulated

The ASR business model - Independent and Unconflicted– is focused on our clients’ needs

• We do not engage in investment banking activities, or sell our research to trading desks.
• We do not engage in proprietary trading activities.
• We do not manage money on behalf of clients (whether institutional or private).
• We are not paid to be on the advisory boards of any investment managers.
• We do not have any other activities - either regulated or unregulated - outside our core research activities.
• Our business model is solely based on providing clients with the highest quality, independent and impartial macro-strategy research.

We are FSA regulated and all our research is governed by FSA document CP05/09 "Bundled Brokerage and Soft Commission Arrangements" - which sets out a definition of "Eligible Research"

(1) Where the goods or services relate to the provision of research, an investment manager will have reasonable grounds to be satisfied that the requirements of COB 7.18.3R are met if the research:

(a) is capable of adding value to the investment or trading decisions by providing new insights that inform the investment manager when making such decisions about its customers' portfolios;

(b) whatever form its output takes, represents original thought, in the critical and careful consideration and assessment of new and existing facts, and does not merely repeat or repackage what has been presented before;

(c) has intellectual rigour and does not merely state what is commonplace or self-evident; and

(d) involves analysis or manipulation of data to reach meaningful conclusions.

None of our Research is based on non-public information.

We are also members of EuroIRP