Director : David Greenall – Principal
Registered House : Redmere House, Lower Durford Wood, Petersfield,
GU31 5AS
Telephone : 01730 890024 || 07881 828411
Email :


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Policy of Independence

All investment research issued by DAVID GREENALL AND ASSOCIATES Investment Ltd (“DAVID GREENALL AND ASSOCIATES”) is independent, impartial and objective. DAVID GREENALL AND ASSOCIATES does not conduct any investment business with or for its clients, other than the provision of investment research and advice. DAVID GREENALL AND ASSOCIATES staff have no other responsibilities which could conflict with the interests of our clients. DAVID GREENALL AND ASSOCIATES does not carry out any corporate finance business; and has no involvement in raising capital for corporate clients. DAVID GREENALL AND ASSOCIATES has no other regulated or unregulated business activities which conflict with its provision of independent research.


Under FCA’s Principles for Businesses, Principle 8 requires a firm to “manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.” Under the Markets in Financial Instruments Directive (“MiFID”), DAVID GREENALL AND ASSOCIATES LIMITED (“DAVID GREENALL AND ASSOCIATES”) is required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage such conflicts of interest. DAVID GREENALL AND ASSOCIATES has put in place a policy to meet this obligation and set out below is a summary of that policy and the key information that is needed by clients and counterparties (together “customers”) to understand the measures DAVID GREENALL AND ASSOCIATES is taking to safeguard the interests of its customers.
Identify circumstances which may give rise to conflicts of interest entailing a material risk of damage to customers’ interests;
Establish appropriate mechanisms and systems to manage those conflicts; and
Maintain systems in an effort to prevent actual damage to customers’ interests through the identified conflicts.


DAVID GREENALL AND ASSOCIATES Limited is an appointed representative of Messels Ltd., authorised and regulated in the conduct of investment business in the United Kingdom by the Financial Conduct Authority. Our services are provided for information purposes only. Under no circumstances is the research content of this website (“the Research”) to be relied upon as constituting personal investment advice or construed as any offer to sell, or any solicitation of any offer to buy investments. While all reasonable care has been taken to ensure that the research published by DAVID GREENALL AND ASSOCIATES is not untrue or misleading at the time of publication, neither DAVID GREENALL AND ASSOCIATES nor its officers or employees makes any representation or warranty as to the accuracy or completeness of such materials. No liability is accepted for any loss whether direct or indirect, incidental or consequential, arising out of any of the research not being true and accurate except to the extent caused by the wilful default or gross negligence of DAVID GREENALL AND ASSOCIATES or its employees or which arises under the United Kingdom Financial Services and Markets Act 2000. All research on the DAVID GREENALL AND ASSOCIATES websites is believed to be up-to-date at the time it is posted, but is subject to variation without notice.
From time to time DAVID GREENALL AND ASSOCIATES and any of its officers or employees may, to the extent permitted by law, have a position or otherwise be interested in any transactions in investments (including derivatives) directly or indirectly the subject of our research. Also DAVID GREENALL AND ASSOCIATES may from time to time provide other services (including acting as adviser) to any company mentioned in our research.
The value of shares and other investments and the income derived from them may go down as well as up, and you may not get back the full amount you originally invested. Derivatives in particular are high risk investment instruments which carry a contingent liability, the value of which may be affected by a greater proportion than the change in the value of the underlying investment or asset. If you make an investment in securities that are denominated in a currency other than your own you are warned that changes in rates of foreign exchange may have an adverse effect on the value, price or income of the investment in your own currency. Any persons in doubt as to whether the investments referred to in our research material may be suitable for them, should consult an independent financial adviser.
The content of this website is protected by copyright and other intellectual property rights or similar rights, which unless indicated otherwise are the property of DAVID GREENALL AND ASSOCIATES. Except for permission to download a single copy for personal use, the research published by DAVID GREENALL AND ASSOCIATES may not be reproduced, distributed or published in whole or in part by any recipient for any purpose, without the prior express consent of DAVID GREENALL AND ASSOCIATES.
Neither DAVID GREENALL AND ASSOCIATES nor its employees officers or agents accepts any responsibility for the accuracy of any information contained within or otherwise the operation of any sites provided by third parties who at any time have links to or from DAVID GREENALL AND ASSOCIATES’s website pages. No liability is accepted for any loss, whether direct or indirect, incidental or consequential, arising from any visit or access to such third party site or the downloading from such site of any information, materials or software.
Whilst certain software may be made available to you from time to time at the DAVID GREENALL AND ASSOCIATES website, you are licensed to use such software on a non-exclusive basis only for the purposes specified. You are not permitted to use such software for any other purposes and may not redistribute, sell, decompile, reverse engineer, disassemble or otherwise deal with such software.
The “DAVID GREENALL AND ASSOCIATES” name and other trade marks and logos appearing on DAVID GREENALL AND ASSOCIATES websites are, unless indicated otherwise, the trade marks of DAVID GREENALL AND ASSOCIATES. All intellectual property rights in and to the same site expressly reserved to DAVID GREENALL AND ASSOCIATES or (as the case may be) the organisation which has licensed DAVID GREENALL AND ASSOCIATES to reproduce the same and accordingly none of the trade marks may be reproduced by you without the express prior consent of DAVID GREENALL AND ASSOCIATES.
DAVID GREENALL AND ASSOCIATES may from time to time send you promotional and other information about its products or services. In addition, DAVID GREENALL AND ASSOCIATES may pass your name on to carefully selected third parties who may contact you with similar or related information. If you would rather not receive the above information either telephone or email us.
Access to this website is not open to persons who are resident in or nationals of any territory outside the United Kingdom (“overseas persons”) where to allow such access would require any registration, filing or other steps to be taken by DAVID GREENALL AND ASSOCIATES in order to comply with local laws or other regulatory requirements. It is the responsibility of overseas persons to ensure there will be no breach of any such laws or regulatory requirements by reason of their choosing to access and/or download information from this and other DAVID GREENALL AND ASSOCIATES websites. This website is hosted in the United Kingdom and compiled in order to comply with English law. All visits to this website are subject to and governed in accordance with English law.
This website is ©2019 DAVID GREENALL AND ASSOCIATES Ltd. All rights reserved.


A conflict of interest under MiFID is a conflict that arises in any area of DAVID GREENALL AND ASSOCIATES’s business in the course of providing its customers with a service which may benefit DAVID GREENALL AND ASSOCIATES (or another customer for whom DAVID GREENALL AND ASSOCIATES is acting) whilst potentially materially damaging another customer where DAVID GREENALL AND ASSOCIATES owes a duty to the customer. There may be a conflict where DAVID GREENALL AND ASSOCIATES (or anyone connected to DAVID GREENALL AND ASSOCIATES including another DAVID GREENALL AND ASSOCIATES affiliate):

· is likely to make a financial gain (or avoid a loss) at the expense of its customer;

· is interested in the outcome of the service provided to its customer where the interests of DAVID GREENALL AND ASSOCIATES is distinct from that of the customer;

· has a financial or other incentive to favour the interests of one customer over another;

· carries on the same business as a customer;

· receives money, goods or services from a third party in relation to services provided to a customer other than standard fees or commissions.

DAVID GREENALL AND ASSOCIATES has sought to identify conflicts of interest that exist in its business and has put in place measures it considers appropriate to the relevant conflict in an effort to monitor, manage and control the potential impact of those conflicts on its customers. The conflicts identified include:

· those between customers with competing interests;

· those between customers and DAVID GREENALL AND ASSOCIATES where their respective interests in a particular outcome may be different; and

· those between the personal interests of staff of DAVID GREENALL AND ASSOCIATES and the interests of DAVID GREENALL AND ASSOCIATES or its customers where those interests may be different.


DAVID GREENALL AND ASSOCIATES has adopted internal policies and procedures in order to manage recognised conflicts of interests. These policies and procedures will be subject to our normal monitoring and review processes and include:


DAVID GREENALL AND ASSOCIATES insists that in its dealings with customers its staff must use the highest standard of integrity in their actions at all times. The induction programme, training and competency procedures and monitoring programme at DAVID GREENALL AND ASSOCIATES are designed to ensure that all relevant staff are familiar with and observe, inter alia, the FCA Principles for Businesses, the Statements of Principle and the Code of Practice for Approved Persons.


DAVID GREENALL AND ASSOCIATES has a policy on Personal Account Dealing and the rules are signed off as understood by all relevant employees regardless of their position within DAVID GREENALL AND ASSOCIATES.


DAVID GREENALL AND ASSOCIATES insists on strict customer confidentiality to ensure that information is disclosed only to those entitled to receive it or otherwise with the prior approval of the Compliance Department.


Staff are not allowed to accept gifts, entertainment or any other inducement from any person which might benefit one customer at the expense of another when conducting investment business. DAVID GREENALL AND ASSOCIATES has a Gifts and Entertainment Policy which is part of the staff’s Policy Manual and is monitored by management on a regular basis.


All relevant staff who are open to a conflict of interest are paid a basic salary including those in key support areas such as Compliance, Finance and Back Office. This salary is not dependent on company performance. A bonus scheme does exist which is linked to the company’s performance and the performance of the individual. It is entirely discretionary.


Where appropriate, DAVID GREENALL AND ASSOCIATES has arranged for the separate supervision of those carrying out functions for customers whose interests may conflict, or where the interests of customers and DAVID GREENALL AND ASSOCIATES may conflict and has taken steps to prevent the simultaneous or sequential involvement of a relevant person in separate services or activities where such involvement may impair the proper management of conflicts of interest.


As a last resort, where there is no other means of managing the conflict or where the measures in place do not, in the view of DAVID GREENALL AND ASSOCIATES, sufficiently protect the interests of customers, the conflict of interest will be disclosed to customers to enable an informed decision to be made by the customer as to whether they wish to continue doing business with DAVID GREENALL AND ASSOCIATES in that particular situation.


Finally, where DAVID GREENALL AND ASSOCIATES considers it is not able to manage the conflict of interest in any other way it may decline to act for a customer.


DAVID GREENALL AND ASSOCIATES, its directors or employees may have interests in the securities on which we provide research and may add to or dispose of such securities from time to time. DAVID GREENALL AND ASSOCIATES may have provided advice, other investment or professional services to the issuer of the securities. Any such interests are reviewed by a director of DAVID GREENALL AND ASSOCIATES to ensure that they do not represent conflicts of interest with our customers.


All of DAVID GREENALL AND ASSOCIATES’s investment analysts are supervised by directors of the firm. The remuneration structure for DAVID GREENALL AND ASSOCIATES’s analysts may be linked in any way to dealing or other activities which our customers carry out as a result of the independent research provided by the firm. In the event of any conflict of interest, DAVID GREENALL AND ASSOCIATES requires all relevant employees to disregard any material interest or conflict of interest when advising a customer. Our analysts are not permitted to be involved in any activities which could be seen as conflicting with our provision of investment research to our clients. No inducements offered by issuers, or others with a material interest in the subject matter of investment research, may be accepted by our investment analysts or directors of the firm. No employee of DAVID GREENALL AND ASSOCIATES may carry out any personal account dealing which could create a conflict of interest which might affect the impartiality of DAVID GREENALL AND ASSOCIATES’ investment research. Any proposed personal account dealing by employees is subject to pre-approval by a director of DAVID GREENALL AND ASSOCIATES and no dealing which could create a conflict of interest between the employees of DAVID GREENALL AND ASSOCIATES and its customers is permitted. In addition, a prohibited list of securities is maintained. All outside business activities of employees are subject to prior approval by a director of the firm.


The timing and manner of publication and distribution of investment research and of the communication of its substance must be approved in advance by a director or senior analyst of DAVID GREENALL AND ASSOCIATES. Before being issued, all research documents must be approved and signed-off by a director or senior analyst. No one outside DAVID GREENALL AND ASSOCIATES may comment on draft investment research before publication, other than, where necessary, to verify factual information. Certain disclaimers may be included in our research where appropriate, for example for legal reasons. DAVID GREENALL AND ASSOCIATES’s policy and procedures require investment research to be distributed in an appropriate manner.
Our investment research is published and distributed either in hard copy or on line. No employee may communicate the substance of any investment research, except in accordance with our policy of independence.


DAVID GREENALL AND ASSOCIATES Ltd. DOES NOT endorse or recommend any securities or other investments and all analysis/commentary is presented for informational purposes only. All information on this Site, as well as reference materials or links to other sites, has been compiled from publicly available sources believed to be reliable and are for general informational purposes only. Accuracy or completeness of the information contained herein is NOT guaranteed and is NOT intended to be relied upon for transactional purposes. Neither DAVID GREENALL AND ASSOCIATES or its publishers, owners, investors, nor any of its data or content providers shall be liable for any errors or delays in the content, or for any actions, losses or damages, monetary or otherwise, taken in reliance of such information, judgments and opinions thereon. All such information is subject to change at any time without notice. “Hypertext links” and /or “hyperlinks” to or from other Internet sites may be introduced at times as a convenience to the user.

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We assume no responsibility for the content of any linked site. The fact that such links may exist does not indicate approval or endorsement of any material contained on any linked site. We also cannot be held liable for any harm caused by the transmission, through accessing the services or information on this site, of a computer virus, or other computer code or programming device that might be used to access, delete, damage, disable, disrupt or otherwise impede in any manner, the operation of the site or of any user’s software, hardware, data or property.
This commentary in no way constitutes financial, investment, tax or any related forms of advice and is one of many possible sources of information for readers. All information contained herein is believed to be accurate, but mistakes can and do happen. Be sure to consult an investment professional before acting on any information that is contained in this website. Views and opinions expressed as of the date of publication are exclusively those of the author and are subject to change based on market and other conditions. This publication is provided for informational purposes only and should not be used or construed as a recommendation for any security or sector.
The User must make their own decisions on whether or not to rely on any information posted on the Site. The Siteowner reserves the right to modify information displayed on this Site but it does not make any commitment to update the information displayed on this Site. From time to time the Siteowner will make available to the User links from the site to third party sites. These sites are not in any way approved, checked, edited, vetted or endorsed by the Siteowner and the User agrees that the Siteowner shall not be responsible or liable in any way for the content, advertising or products available from such sites, the quality, functionality, suitability or legality of such sites or for any dealings that the User may have, or the consequences of such dealings, with such third party site operators.

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Third Parties The provisions of the Contracts (Rights of Third Parties) Act 1999 shall not apply to this Agreement, Proper Law and Jurisdiction This Agreement and all matters arising from it shall be governed by and construed according to the laws of England and Wales and shall be subject to the [exclusive] jurisdiction of the courts of England and Wales.


This Agreement supersedes all prior agreements, arrangements and undertakings and constitutes the entire agreement relating to the subject matter of this Agreement. The User confirms that they have not entered into this Agreement on the basis of any representation that is not expressly incorporated into this Agreement.
David Greenall & Associates Ltd Ltd is an appointed representative of Messels Ltd., which is authorised and regulated by the Financial Conduct Authority of the UK.

David Greenall & Associates Ltd Ltd has made every reasonable effort to ensure the information provided in this communication is correct, but David Greenall & Associates Ltd Ltd makes no representation nor any warranty as to whether the information is accurate, complete or up to date. To the extent permitted by law, David Greenall & Associates Ltd Ltd accepts no responsibility for any errors or misstatements, negligent or otherwise. David Greenall & Associates Ltd Ltd, its associates, officers or employees may also have interests in the financial instruments referred to in this information by acting in various roles. The information in this email is confidential. If you are not the intended recipient, you are not authorised to use the information in this email in any way. David Greenall & Associates Ltd Ltd does not guarantee the integrity of any emails or attached files. The view or opinions expressed are the author’s own and may not reflect the view or opinions of David Greenall & Associates Ltd Ltd. Electronic communications carried within the David Greenall & Associates Ltd Ltd system may be monitored.



The Data Controller is DAVID GREENALL AND ASSOCIATES Limited, a limited company registered in England and Wales (registration number 11729412) the registered office of which is at Redmere House, Lower Durford Wood, Petersfield,
GU31 5AS. You can contact the data controller by writing to DAVID GREENALL AND ASSOCIATES Ltd, Redmere House, Lower Durford Wood, Petersfield, GU31 5AS, or sending an email to
DAVID GREENALL AND ASSOCIATES have no Data Processors, in relation to personal data, i.e. any person (other than an employee of the data controller) who processes the data on behalf of the data controller.




The Data Protection Officer.


The European General Data Protection Regulation, came into force on 25th May 2018 and is the basis of this Data Protection Policy.


This Data Protection Policy sets out how we, DAVID GREENALL AND ASSOCIATES Limited, collect, store and use information about you when you use our website, and where we otherwise obtain or collect information about you.
The reasons for the policy are to comply with the law, follow good practice, to protect clients, staff and other individuals and to protect the company.


We collect individual information from our company staff and individual and company information from consumers of our research.


This Data Protection Policy complies with both the law and good practice and respects individuals’ rights. The company will be open and honest with individuals whose data is held and provide training and support for staff who handle personal data, so that they can act confidently and consistently.
In the event of data breaches the Supervisory Authority (the ICO) will be notified within 72 hours. In addition, for major breaches the data subjects will be notified without delay. A personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.


We record the names and contact details of the individuals within institutions with whom we have research supply agreements.


We record the names, ‘know your client’ information and contact details of the institutions with which we have research supply agreements.


We have a regular cycle of checking, updating or discarding old data on our staff and research clients.


DAVID GREENALL AND ASSOCIATES is committed to ensuring that Data Subjects are aware that their data is being processed and
· for what purpose it is being processed
· what types of disclosure are likely, and
· how to exercise their rights in relation to the data


We retain contact details of research clients so that we can provide them with research products in accordance with the Agreements we have with them.


We record the name, email address, postal address and telephone number of individuals filling in the form on the Contact page on the website. This information is not transferred outside the EEA and is stored on our own web server in the United Kingdom.


We do not use cookies on our website.


We collect and store emails on three personal computers and on our email server in the United Kingdom. Information is not transferred outside the EEA.


We use a third-party provider, XXX, to deliver our research products. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our products.


We store information on the hard drives of XXX computers and back it up on Dropbox, Office 365 and Google cloud-based systems.


Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means) you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.


We log all telephone calls with research clients for monitoring purposes but do not record conversations.


Information from compliance procedures, such as on-boarding, research handling and quarterly compliance meetings, is stored on hard copy files and kept in secure storage.


The lawful basis for the personal data processed is one or more of the following, described in Article 6 (1) of the General Data Protection Regulation:

(a) Consent: the individual has given clear consent for us to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract we have with the individual, or because they have asked us to take specific steps before entering into a contract.

(c) Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.

(f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.)

Data collected from our research clients is on the basis of (b) Research contracts and (f) Our legitimate interests.
Data collected from our Appointed Representatives is on the basis of (a) Consent, (b) AR Agreements, (c) Legal obligations and (f) Our legitimate interests.


Once given, consent can be withdrawn, but not retrospectively. There may be occasions where DAVID GREENALL AND ASSOCIATES has no choice but to retain data for a certain length of time, even though consent for using it has been withdrawn.


All employees of DAVID GREENALL AND ASSOCIATES and those who have access to any kind of personal data will have their responsibilities outlined during their induction procedures.


Data Protection issues will be covered during employee training, team meetings, supervisions, etc.


Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by contacting the Data Protection Officer by email at, in writing to: DAVID GREENALL AND ASSOCIATES Ltd, Redmere House, Lower Durford Wood, Petersfield, GU31 5AS, or by phone on 01730 890024 or 07881 828411:

– to request access to your information and information related to our use and processing of your information;
– to request the correction of your information;

– or request the erasure of personal data (right to be forgotten) providing there is no overriding legitimate grounds;
– to request that we restrict our use of your information;
– to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller;
– to object to the processing of your information for certain purposes; and
– to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

The controller will provide information on action taken on request to the data subject without undue delay and in any event within one month of receipt of the request.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, which is the Information Commissioner’s Office (ICO), whose website is below.

Any enquiries please contact us

David Greenall – Principal

01730 890024 || 07881 828411

Registered Office: Redmere House, Petersfield, GU31 5AS



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David Greenall & Associates Ltd Ltd is an appointed representative of Messels Ltd., which is authorised and regulated by the Financial Conduct Authority of the UK.