Company Information

Conexim Regulation

Conexim Advisors Ltd. is regulated by the Central Bank of Ireland under Regulation 11 (1) of the European Communities (Markets in Financial Instruments) Regulations 2007, and as an insurance intermediary under the European Communities (Insurance Mediation) Regulations, 2005 (as amended).

The Financial Service Provider Profile for Conexim with the Central Bank is provided here: Central Bank Register.

The firm is authorised to provide the following services and with the following instruments.

Investment Services (MiFID)
1.1. Receiving/transmitting orders
1.4. Portfolio management
1.5. Investment advice

Ancillary Services (MiFID)
2.4. F/X re Investment Services
2.5. Research

Investment Business Services (IIA)
(f) Deposit Agent/Broker

Financial Instruments (MiFID)
1. Transferable securities
2. Money market instruments
3. Unit/Shares in UCITS
4. Units in a unit trust
5. Shares in an Inv Co.
6. Capital Contributions to an ILP
7. Units in a CCF
10. Financial CFDs
(8A) Securities, currencies, interest rates or yields etc.
(8B) Commodities that must be settled in cash etc.
(8C) Commodities that can be physically settled etc.
(8E) Climatic variables, freight rates, emission allowances etc.

Investment Instruments (IIA)
(kk) Tracker Bonds
(m) Insurance Policies
(n) PRSAs

Privacy Notice

This privacy notice explains when and why Conexim collects personal information, how it is used, the condition under which it may be disclosed to others and how it is kept secure. This privacy policy was last updated on the 25th May 2018, and may be updated periodically.

Conexim approach to Data Privacy

In order to provide clients, intermediaries, Trustees and other market participants with our Services, Conexim is required to control personal data for clients, intermediaries and other parties with whom we provide services to, or receive services from.

Conexim is committed to protecting and respecting your privacy. Conexim has adopted the principle of Privacy by Design and has reviewed and appropriately modified our business processes to comply with this element of the GDPR.

Our full privacy notice is attached here: CX Privacy Notice – 25th May 2018

Top 5 Trading Venues

MiFID II Regulatory Technical Standard number 28 (‘RTS 28’) requires that investment firms must publish on an annual basis, information on the top five execution venues used to execute client orders in MiFID II financial instruments.

Types of venues included are: trading venues, systematic internalisers, market makers and other liquidity providers. The information shows in percentages how trade consideration, and order count was split between those ‘top five’ venues. It also shows in percentages how many orders were ‘passive’ (entered into a ‘order book’ that provided liquidity) and how many orders were ‘aggressive’ (entered into an ‘order book’ that took liquidity).

Under the Model B arrangement Conexim have with Pershing Securities International Limited, Conexim transmits orders for execution to Pershing for execution for our retail clients where Pershing also provide those clients with custody services, as Conexim does not execute the orders for you directly.

Therefore, the up to date data required under RTS 28 may be found on Pershing’s website, at http://www.pershing.com/uk/en/about/topics/mifid-ii-rts-28-report

If you should have any questions around this, please contact Conexim and request further details on this from the Compliance Officer.

 

Principal Adverse Impact Statement

As of March 10th 2021, Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088) seeks to introduce rules for Financial Market Participants (‘FMP’s’) and Financial Advisers (‘FA’s’) with regards to the integration of sustainability risks into their processes, as well as the provision of sustainability-related information in financial products.

The regulation will require FMP’s and FA’s to consider sustainability risks across various aspects of their operations, including disclosures, integration into policies, investment process, product governance and wider internal processes and systems.

The term ‘sustainability risk’ refers to an environmental, social or governance (‘ESG’) event or condition that could cause an actual or a potential negative impact on the value of a product recommended to you.

Sustainability Factors are defined as environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. FMP’s and FA’s have an option to consider the principal adverse impacts of investment decisions on sustainability factors in their advice processes.

Conexim has two primary service models, each of which will be treated individually for the purposes of this disclosure.

Model 1: Execution-Only Service

An 'execution-only' service is a term that is used for a platform that does not offer advice when allowing investors to select which products or funds to invest in. By nature of the execution-only service model, Conexim does not consider the principal adverse impacts on sustainability factors of investment decisions or investment advice provided by external regulated investment intermediaries. Conexim does not provide investment advice or investment recommendations, therefore are not placed to influence the integration of ESG products into an investors portfolio.
Model 2: Portfolio Management Services

Conexim provides portfolio management services, in conjunction with discretionary investment managers. Under this arrangement, we do seek to integrate ESG (Environmental, Social and Governance) considerations into the investment process.

In practise, this means we endeavour to:

- Evaluate the responsible investment policies and processes of the funds used in client portfolios
- Use only those funds who demonstrate adequate levels of Stewardship
- All else equal, prefer funds who demonstrate better levels of ESG integration in their investment processes

To conclude, clients can find information in relation to both sustainability risks and the principal adverse impacts of investment decisions on sustainability factors on their FA’s website, or by engaging with them directly.