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Investment recommendation disclosure

The Market Abuse Regulation (Regulation (EU) No 596/2014 (including as applicable in the United Kingdom) (“MAR”) requires that persons who produce or disseminate investment recommendations or other information recommending or suggesting an investment strategy shall take reasonable care to ensure that such information is objectively presented, and to disclose their interests or indicate conflicts of interest concerning the financial instruments to which that information relates.


Material covering financial instruments in scope of MAR may contain investment recommendations, including information recommending an investment strategy. Reasonable steps have been taken to ensure that the material is presented in a clear, accurate and objective manner and in compliance with Article 20 of MAR.  Westpac does not apply MAR investment recommendation requirements to Spot Foreign Exchange which is out of scope of MAR.


Any investment recommendation produced and disseminated by the Westpac Sales and/or Trading teams or other non-research functions at Westpac should be considered as a marketing communication as it contains non-independent research. It does not constitute independent investment research, is not a research report, has not been prepared by Westpac’s research team and has not been prepared in accordance with legal requirements to promote the independence of research. 


Investment recommendations contain current independent views and interpretations of the markets, products or events held by the author(s) based on their market knowledge and experience and must not be relied upon as investment advice. Any investment recommendation is for informational purposes only and is not intended to provide personal investment advice, does not consider the specific investment objectives or the particular needs of the recipient and should not be construed as legal, tax, investment, financial, or other advice. Any opinions expressed may be based on information from publicly available sources believed to be reliable but no representation or warranty, express or implied, is made that such information is accurate, complete or up to date. Investment recommendations are intended for distribution to eligible counterparties and professional clients only and are not intended for retail clients. Any investment recommendation does not constitute an offer or solicitation to buy or sell any securities or other investment. A list of historic investment recommendations that are marketing communications produced during the preceding 12-month period is available upon request free of charge.


An explicit investment recommendation may contain the following terms and meanings:


  • Buy – we expect the financial instrument to increase in value.
  • Sell – we expect the financial instrument to decrease in value.
  • Hold/Neutral – we do not expect the value of the financial instrument to materially change and/or we do not recommend either a Buy or Sell.


Explicit investment recommendations will generally provide a summary of the basis of valuation or the methodology used along with any underlying assumptions. Where this is not the case, this information is available upon request free of charge.


Unless otherwise stated, investment recommendations are current at the time of publication only and therefore after the publication date may contain information that is no longer current or accurate and should not be used to make an investment decision. Unless otherwise indicated, there is no intention to update any investment recommendation.  Westpac has no obligation to update, modify or amend investment recommendations or to notify the recipients of investment recommendations should any information, including opinion, forecast or estimate change or subsequently become inaccurate. The price of any financial instrument mentioned in an investment recommendation is the price as of the date of publication of the recommendation and the time stated in the recommendation.


Westpac may from time to time dispose of, hold and/or acquire financial instruments of issuers covered in investment recommendations as principal or when acting as a market maker or a liquidity provider in such financial instruments. Westpac does not have any proprietary positions in equity shares of issuers that are the subject of any investment recommendation. Westpac may have financial interests in companies that are the subject of an investment recommendation including securities, options, futures or other derivative instruments. 


Westpac may have acted as lead manager or co-lead manager or provided investment banking services and activities and/or ancillary services to an issuer subject to an investment recommendation over the past 12 months where Westpac may have received or paid financial compensation relating to these services.


Individuals who produce and communicate investment recommendations may or will be paid based on the overall profitability of the firm, including that relating to activities of its financial markets division. 


Westpac does not permit any issuer to see or comment on any investment recommendation prior to its completion and distribution. Westpac is not party to any agreement relating to the production of any investment recommendation with any company mentioned in an investment recommendation.


Westpac has implemented policies and procedures, which are designed to ensure conflicts of interests are managed consistently and appropriately, and to treat clients fairly.  The following arrangements have been adopted for the avoidance and prevention of conflicts in interests associated with the provision of investment recommendations:


i. Chinese wall/cell arrangements functioning as information barriers;

ii. Physical separation of various business/support units; 

iii. Strict and well defined wall/cell crossing procedures;

iv. A “need to know” policy; 

v. Documented and well defined procedures for dealing with conflicts of interest, including rules of conduct for managing any conflicts of interest; 

vi. Reasonable steps by Compliance to ensure that the Chinese wall/cell arrangements remain effective and that such arrangements are adequately monitored; and

vii. Strict personal account trading policies and procedures.