Electronic Communications Policy

RECORDING COMMUNICATIONS POLICY

Conversations or communications  relating  to  dealing  with  own  conduct,  receiving,  and  transmitting  orders  or executing client  orders,  are  key  parts  in  implementing any  advice  and  services  we  provide.  Furthermore,  the recording of telephone calls and emails stretches to circumstances where a transaction is intended to take place, but never actually occurs. It is important that instructions are clear and understood by both the client and us. Details of these conversations should therefore always be recorded and stored.

Instructions may be received from clients via several forms of media e.g. face-to-face meetings, over the phone, email, or other electronic forms. These are collectively referred to in this document as relevant communications. The form in which our record is maintained will depend on how the instruction has been received.

It is worth noting that the recording of telephone and electrical communications is only permissible if new and existing clients have been notified that the relevant electronic communications between them and Oberon will be recorded. Such a notification must be made before the provision of any investment services.

This policy sets out our procedures for recording and retaining relevant communications as referred to above and will ensure that we always comply with the FCA requirements on this area.

This policy relates to all parts of our business.

OUR COMMITMENT

Telephone and electric recording help deter and detect market abuse. Furthermore, it is through these calls that Oberon Investment Group PLC can evidence or process the terms of any orders given by clients and its correspondence with transactions executed by the firm. Lastly, telephone recording assists regulators such as the FCA with supervision of the firm. Moreover, compliance of such regulations transposes a level of transparency to which Oberon Investment Group PLC is very much committed.

Oberon Investment Group PLC will take all reasonable steps to record and retain copies of all relevant communications that relate to the reception, transaction, and execution of client orders. This will include any communications that are made with, sent from, or received on equipment:

•   provided by our firm to an employee or contractor
• used by an employee or contractor e.g. a privately owned device, which we have accepted or permitted prior to its use

STAFF AWARENESS

Training on this policy, and on the risk our business faces from electronic communications, will be provided as necessary.