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Don't invest unless you're prepared to lose all the money you invest. This is a high-risk investment and you are unlikely to be protected if something goes wrong. Take 2 minutes to learn more.

Bonham Coutts

Responsibility

How we are governed.

Governance is the part of responsible business that most directly affects an investor, so we set it out in detail.

The framework we apply

We apply the QCA Corporate Governance Code, which is designed for smaller companies and is proportionate to our size. Larger private companies more often apply the Wates Principles, and premium-listed companies the UK Corporate Governance Code.

Applying a code is not the same as complying with every provision of it. Where we depart from a provision we explain why, which is what the codes themselves ask for.

Codes: QCA Corporate Governance Code · Wates Principles · UK Corporate Governance Code.

Board and oversight

  • The board meets quarterly with a standing agenda covering compliance, conflicts, and the status of every live offer.
  • No financial promotion is published without compliance review, recorded against the reviewer's name.
  • The record of completed investor statements is reviewed at each meeting, including expiries.
  • Departures from the screening process require board approval and are minuted.

Conflicts of interest

We are paid by the companies whose offers we present. That is a conflict with your interests and no amount of process removes it, so we manage it in the open.

We publish underlying documents rather than our summary of them. Risk factors appear on the deal page beside the terms, not in an appendix. We do not offer any incentive to invest, which the FCA prohibits in any event. And we state the arrangement here rather than leaving you to infer it.

Reference: FCA Handbook COBS 4.12A, including the ban on inducements to invest.

Protecting and growing shareholder value

Shareholder value in this asset class has three parts: income, which is usually nil in the early years; capital growth, which is uncertain and often takes longer than expected; and reputation, which is the only one within our direct control.

We protect it by being accurate. We do not describe a projection as a forecast, we do not present a valuation without the comparable transactions behind it, and we do not describe an investment as low risk because tax relief reduces the cost of a loss.

Where an offer we have presented does not go well, we say so on this site. A record that only shows successes tells you nothing.

Records and accountability

  • Completed investor statements retained as evidence that an exemption was properly relied upon.
  • A dated copy of every financial promotion as published, with its approval or exemption basis.
  • Introducer agreements in writing, with fees disclosed.
  • A complaints log, reviewed at board level.