LEGAL AND REGULATORY DISCLOSURES


General Disclosures

Your Data Protection Rights

Your information, our duty and your rights

To be our customer, you share information with us. To be your investment firm, we respect that information. On this page you will find out how we do that and what your rights are and how you can exercise them.

Right of Access to Information (Subject Access Request)

You can ask us for a copy of the personal information we hold and further details about how we collect, share and use your personal information.

You can contact us by your own preferred method.

You can request the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • where the personal data are not collected from the data subject, any available information as to their source;

Upon receipt of a subject access request we will contact you using our normal means of communication to ensure we provide you with exactly what you want via the means you require.

Updating and Correcting your Personal Details

If you want to update or correct any of your personal details, please contact us using the usual means or call us at 01 6670400.

Right to Restriction of Processing

You can request restriction of the processing of your personal information where one or more of the following apply:

  • the information we hold is inaccurate (if you would like to correct any of your personal details, please call us on 01 6670400);
  • we are processing your information unlawfully;
  • we no longer require your personal information however you want us to retain your information for use in a legal claim;
  • you have objected to the processing of your personal information based on our legitimate interests and want processing restricted while we consider whether we have overriding grounds to continue processing.

If you wish to request a restriction of the processing of your personal information based on the above criteria, you should advise us in writing and bring it along with a valid form of identification (current passport or drivers licence) to our offices Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99 or any of our branches.

In the event that you are unable to present your request in person, the request can be posted to Data Protection Officer, Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99 along with a certified copy of photo ID and certified copies of 2 proof of addresses (issued within the last 6 months) from independent sources. Your photocopies can be certified by a member of An Garda Síochána at your local Garda station, by a solicitor, an accountant, public notary or at your local bank branch.

Right to Object to Processing

You can request to object to the processing of your personal information where the processing:

  • Is for the purpose of direct marketing (you can opt out of direct marketing at any time in person, through our client portal or by calling 01 6670400);
  • Is carried out in the legitimate interests of us or third parties. Your right to object to processing based on legitimate interests will only be upheld if we can’t show compelling, legitimate reasons for the processing of your information which takes priority over your rights or we need to process it for establishment, exercise or defence of a legal claim.
  • Is for scientific or historical research purposes

If you wish to object to the processing of your personal information based on the above criteria, you should advise us in writing and bring it along with a valid form of identification (current passport or drivers licence) to our offices Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99 or any of our branches.

In the event that you are unable to present your request in person, the request can be posted to Data Protection Officer, Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99 along with a certified copy of photo ID and certified copies of 2 proof of addresses (issued within the last 6 months) from independent sources. Your photocopies can be certified by a member of An Garda Síochána at your local Garda station, by a solicitor, an accountant, public notary or at your local bank branch.

Deleting your Information (Right to be Forgotten)

The Right to Erasure, also known as the Right to be Forgotten, permits you to request that we remove any personal information relating to you from our records if one or more of the following apply:

  • your personal information is no longer required in relation to the purposes for which it was collected/processed;
  • the processing was based on your consent, which you withdraw and there is no other legal basis for processing your personal information;
  • you exercise your right to object and there are no overriding legitimate grounds for the processing;
  • your personal information has been unlawfully processed; or
  • your personal information needs to be erased to comply with a legal obligation.

To meet our legal, business and regulatory obligations, there are certain circumstances where we are required to retain your personal information. Examples of these circumstances include:

  • Legislation/regulation requires the retention of information
  • Your information is still subject to Goodbody’s Data Retention Schedule, which is the agreed period for which Goodbody Stockbrokers UC can store information on any account, product or application once it has been closed;
  • You are still a customer with Goodbody and have open accounts that you are transacting on and products that you are using;
  • You have an ongoing application with Goodbody for a product or account;
  • You currently have a non-account holding relationship with the firm (e.g. trustee, guarantor, Power of Attorney, Assisted Decision Making Authority, Director of a Company, etc.); or
  • If you are otherwise engaged with Goodbody, either directly or through a third party.

Where a right to be forgotten request has been upheld, the information we processed will no longer be linked to your identity.

If you wish to exercise your right to be forgotten based on the above criteria, you should advise us in writing and bring it along with a valid form of identification (current passport or drivers licence) to our offices Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99 or any of our branches.

In the event that you are unable to present your request in person, the request can be posted to Data Protection Officer, Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99 along with a certified copy of photo ID and certified copies of 2 proof of addresses (issued within the last 6 months) from independent sources. Your photocopies can be certified by a member of An Garda Síochána at your local Garda station, by a solicitor, an accountant, public notary or at your local bank branch.

Goodbody will only be able to forget accounts or products that are outside Goodbody’s Data Retention schedules and those that do not fall into our list of exemptions.

Right to Portability

You have the right to request your personal data held by us in a digital and portable format. Your portability request will include your personal information which has been:

  • Processed automatically
  • Processed with your consent
  • Processed under the performance of a contract
  • Provided by you (including observed usage of the account)

You can raise a Portability data request by:

  • Advising us in writing at Data Protection Officer, Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99
  • Phoning us at 01 6670400.

Goodbody will contact you to let you know that your request has been completed which will include instructions for collection. If an invalid request is submitted, Goodbody will contact you to let you know along with instructions of what is required to resolve the issue.

The digital portability file can only be collected by you or a nominated third party from one of our offices. Prior to collecting the data you or your nominated third party must present a valid form of ID and proof of address. Your file will be held for 28 days. If it is not collected during this time, the file will be securely destroyed

.

Data Protection Notice

Your information

  • what we collect
  • why we collect it
  • what we do with it

This is our Data Protection Notice. Here we explain how we use, share and keep the information we collect about you. We must explain this to you under the General Data Protection Regulation (GDPR), which is a law that:

  • protects your information and
  • tells us how we can use your information.

You can ask for more details about how we use your information by:

  • calling us on 01 6670400
  • emailing us at [email protected] (DPO stands for Data Protection Officer); or
  • writing to us at Data Protection Office, Goodbody Stockbrokers, 9-12 Dawson Street, Dublin 2, D02 YX99.

Last updated: October 2024

Who we are

When we talk about “Goodbody”, “we”, or “us, we are talking about Goodbody Stockbrokers UC trading as Goodbody or one of our subsidiaries or group companies. This includes:

  • Goodbody Stockbrokers UC in Ireland and the UK
  • Goodbody Securities Inc
  • AIB Wealth Pensioneer Trustees Limited
  • Goodbody Pensioneer Trustees Limited
  • Goodbody Stockbrokers Nominees Limited

Our Data Protection Officer manages how we collect, use, share and protect your information to ensure your rights are fulfilled. You can write to our Data Protection Officer by:

  • Email: [email protected] , or
  • post: Data Protection Office, Goodbody Stockbrokers, 9-12 Dawson Street, Dublin 2, D02 YX99.

We may ask you for your consent to use your information

Sometimes we will ask you for your consent (permission) to use your general information. You can change your mind about this any time. You’ll find more about this in the ‘Your rights’ section of this Data Protection Notice.

Some information is called ‘special category personal data’. This includes sensitive data like medical details, or biometric information such as fingerprints. We explain more about these types of information in Special category personal data.

If we ever contact you to ask about ways to improve our services, it is up to you to decide if you want to answer or not.

What is information?

The General Data Protection Regulation (GDPR) uses the words ‘personal data’ which means ‘information’. Here we use the word ‘information’.

We collect and keep information about you, such as:

  • your name
  • proof of your identity and your address
  • your contact details
  • your bank details
  • your age
  • your PPS number
  • the type work you do (if you work) and where you work.

We also collect information from you like:

  • your employment and financial information including all forms of income and remuneration;

We need this information so that we can offer you the services you asked for. Our services include wealth management, asset management and investment banking.

These are some of the terms we use to describe your information:

What we call your information What that means
Personal information

Information like your:

  • name
  • date of birth
  • address
  • gender
  • PPS number
  • contact information
  • employment and tax residency information
  • marital status
  • life stage, for example, university student or pensioner
  • education and qualifications
  • investment experience and knowledge
Information about your financial situation

Information like:

  • regular income
  • value of net assets
  • source of investment (source of investment funds and source of wealth)
  • debts, current and planned financial commitments
Information about your life stage

Information which tells us:

  • if you are working, unemployed, retired or in further education
  • number of dependents
  • details that might mean you need help from us, for example if you are elderly or live with a mental/physical illness.
Information about your location

Information which tells us where:

  • you are located at a point in time
  • a transaction was carried out
  • a device you use with our digital services is located.
Information from your mobile device or computer

Information which tells us:

  • what device you are using
  • if it has been tampered with
  • how you use our website and what pages you visit.

Your rights

Your right to information

Under law, you have rights about your information. You have the right to:

  • see it
  • ask us to change it
  • ask us to transfer it to another company
  • ask us to delete it.

Contact us

You can take up your rights by:

Your right to ask us to send you information

You can ask us:

  • to send you the information we have collected about you; and
  • to update or correct the information we have collected about you.

Your right to tell us how we can use your information

You can ask us to:

  • remove the consent you have given us to use your information (for example, you can tell us not to send you marketing emails);
  • restrict, in certain circumstances, our use of your information;
  • stop using your information if you don’t want us to; and
  • delete your information and not to contact you again.

Consent

We sometimes need your consent to do certain things, such as sending you marketing emails. When you consent we will:

  • be clear when we are asking for your consent;
  • only use your information if you have freely given us your consent to use it;
  • not have any pre-ticked boxes on our forms (for example, we will not send you marketing emails unless you consent by ticking the marketing box when you apply for a service); and
  • keep a record of your consent and how we got it.

You can remove your consent

  • at any time by contacting the person you have been dealing with;
  • by emailing the Data Protection Officer at [email protected]; or
  • by writing to us at Data Protection Office, Goodbody Stockbrokers, 9-12 Dawson Street, Dublin 2, D02 YX99.

You can remove your consent for marketing by

  • clicking the notification settings in your Online Client Portal or by
  • following the instructions in any marketing message you receive.

Special category personal data

We will ask for your consent before we collect certain special information about you called ‘special category personal data’ under the General Data Protection Regulation. Sometimes this information may come from someone else who you have consented to act for you.

These special categories are your:

  • race
  • ethnic origins
  • political opinions
  • religious or philosophical beliefs
  • trade union membership
  • physical or mental health
  • sexual orientation
  • genetic information

How we collect your information

Account information

We collect information you give us when you apply for an account or a service with us, for example:

  • invest in shares;
  • open an account to buy and/or sell shares;

We also collect information about how you use our services, for example when you:

  • ask us for advice; or
  • obtain any additional products e.g. Financial Planning

Phone conversations

Sometimes we record phone conversations we have with you to train our people, manage our records, improve services and offerings, and follow laws and regulations. We will let you know if we are recording the conversation.

Websites, Cookies and CCTV

We collect information through our website and online client portal and through CCTV cameras at our offices. We use CCTV for the safety and security of our people, customers and buildings.

We also collect information through ‘cookies’ each time you visit our website. A ‘cookie’ is a piece of digital information that remembers what you do on our website. If you visit our websites, we place a cookie on your phone or computer. This means our website will work better for you the next time you visit. You can read more about our cookies on our cookies policy.

How we collect information about you from others

We collect and keep information about you from trusted Third Parties including:

  • registries such as Companies House, or other organisations that help us carry out identity checks to reduce the incidence of financial crime;
  • Your authorised representatives such as your attorney (under a Power of Attorney) and any other party authorised by you to act on your behalf;
  • Financial institutions such as intermediaries that facilitate the services or products you request;
  • Pension fund administrators, trustees of collective investments, undertakings and pensions trustees;

When you choose to share your information with third parties

You can let what’s called a ‘third-party ’ see your account. If you allow a Third Party to see your account:

  • You must tell us in writing about this first and we must agree to it; and
  • You will also need to tell the people you share the account with.

Examples of third-party providers include financial planner or a tax expert.

How we collect information about you if you are not a customer

Sometimes we collect and use your information even though you are not a customer of ours. Examples of this include when you apply for an account before you become a customer, or when an account of yours moves from another investment firm to us.

We also collect and use your information if you are connected to a customer, for example if you are:

  • a director of their company
  • their business partner

If you are worried that someone has access to your account who should not, please phone our customer service team on:

Why we use your information

Here we tell you about why we use your personal information and the type of information we use in each case. The General Data Protection Regulation (GDPR) says we must tell you this. We can use your information:

  • because we have a contract with you and need to use your personal information to carry out that contract;
  • to follow laws;
  • for legitimate interests, so that we can carry out our business;
  • because you have given us your consent to do so; or
  • to protect your interests and the interests of others.

You can read about the terms we use to describe your information here.

What we do with your information Why we use your information What information we use
To follow laws and regulations
  • to follow laws such as consumer and investor protection, anti-money laundering and assisted decision-making laws
  • personal information
  • information about your investment portfolios
  • information about your financial situation
  • information about your life stage
To check your identity, address, and where your money comes from
  • to follow laws such as anti-money laundering laws, and
  • for our legitimate interests, that we can carry out our business.
  • personal information
  • information about your transactions
  • information about your financial situation
To provide accounts and services that are suitable for you
  • to follow laws such as anti-money laundering laws,
  • for legitimate interests, so that we can carry out our business,
  • because we have a contract with you and need to use your personal information to carry out that contract, and
  • because you may need help managing your money.
  • personal information
  • information about your transactions
  • information about your life stage
  • information about your financial situation
To improve our accounts and services to better understand what you like and want from us
  • to get your consent to ask if you are happy with the accounts and services we give you, and
  • for legitimate interests, so that we can carry out our business.
  • personal information
  • information about your transactions
  • information about your life stage
To maintain and monitor your accounts and services
  • to follow laws such as consumer protection laws and anti-money laundering laws,
  • for legitimate interests, so that we can carry out our business, and
  • because we have a contract with you and need to use your personal information to carry out that contract.
  • personal information
  • information about your transactions
  • information about your life stage
  • information about your financial situation
To protect you, your money and our interests from financial crime and fraud and scams
  • to follow laws such as anti-money laundering laws, and
  • for our legitimate interests, such as protecting you from financial crime.
  • personal information
  • information about your transactions
  • information about your financial situation
  • information about your location
  • information from your mobile device or computer
To decide which of our accounts and services are best suited to you
  • to follow laws such as consumer protection laws,
  • for legitimate interests, so that we can carry out our business, and
  • because we have a contract with you and need to use your personal information to carry out that contract.
  • personal information
  • information about your transactions
  • information about your financial situation
  • information about your life stage
To understand trends and share them with others
  • to get your consent so we can understand how our customers use our products.
  • information about your transactions
  • information about your life stage
  • information about your location
  • information from your mobile device or computer
  • your personal opinions

To manage risk, so we can protect:

  • our customers and their money,
  • our employees
  • our shareholders.
  • to follow laws such as consumer protection and anti-money laundering laws, and
  • for legitimate interests, so that we can carry out our business.
  • personal information
  • information about your transactions
  • information about your financial situation
  • information about your life stage
To understand how you use our services, how well we meet your expectations and to market accounts and services to you
  • to get your consent so we can market accounts and services to you and make your experience more personalised.
  • personal information
  • information about your transactions
  • information about your life stage
  • information about your location
  • information from your mobile device or computer
To decide if we have been given false or misleading information and if we suspect criminal activity
  • to follow laws such as consumer protection and anti-money laundering laws.
  • personal information
  • information about your financial situation
  • information about your transactions
  • information about your location
  • information from your mobile device or computer
To confirm your identity
  • to get your consent so you can access our services through the technology available on devices more quickly.
  • personal information
  • information about your location
  • information from your mobile device or computer
To share your information with companies with whom we have a joint venture or working agreement.
  • for legitimate interests, so that we can carry out our business and provide services.
  • personal information
  • information about your transactions

How we keep your information

We keep your personal information while you are a customer with us and for some time after that.

The length of time we keep your information for depends on things like regulations, the type of service or accounts we have provided to you and what we have discussed with each other.

Examples of where we keep your information for a longer time include:

  • legal reasons, for example to comply with anti-money laundering laws; or
  • if there is a disagreement between us, or with third parties.

We also have obligations about how long we keep your information to government agencies like the Financial Service and Pensions Ombudsman. The Financial Services and Pensions Ombudsman is an independent body that helps with complaints from consumers, against financial service providers. This can mean we need to keep your information for a longer time. We do this to protect your and our interests.

We also keep your information for as long as we need it to:

  • resolve complaints;
  • prevent fraud and scams; and
  • protect our business.

How we use technology to process your information

When you use your account, especially online, we use technology to decide if your account is at risk from crime. We do this to:

  • protect you and your money;
  • protect our interests; and
  • follow laws and regulations.

The technology can tell us quickly if there are risks with your location, your device or how your account is being used

How we share your information inside Goodbody Stockbrokers UC

We share your information within Goodbody to help us:

  • provide our services;
  • improve our services; and
  • follow laws and regulations.

For example, we follow guidelines from the European Securities & Markets Authority (ESMA). ESMA sets rules for investment firms in the European Union including how they share information within their group. Under these rules, we must keep a record of the money you have in your account with us.

How we share your information outside Goodbody Stockbrokers UC

We share your information with third parties so we can give you the best service. You can read more about the information we share with third parties in the table on the following section.

How we share information with third parties

Click here to read about how we describe your information.

Who we share your information with Why we share it What we share
Asset management firms that manage funds for people and companies
  • to provide accounts and services that are suitable for you.
  • personal information
  • information about your accounts with us
  • information about your transactions
Corporate services
  • to provide accounts and services that are suitable for you, and
  • transfer your accounts such as transferring to another investment firm.
  • personal information
  • information about your accounts with us
  • information about your transactions
  • information about your security for a loan
Third-Party Provider that you allow to access your accounts.
  • to provide accounts and services that are suitable for you, and
  • to share information that may help you when you are in financial difficulty or need extra support.
  • personal information
  • information about your accounts with us
  • information about your life stage
  • any other information you want us to share
Market research
  • to find out more about your experiences with us, so that we can improve our services.
  • personal information
  • details of your opinions or experiences with us
Trading Venues
  • to follow laws and regulations inside and outside Ireland.
  • Personal information
  • Full information on shares bought and/or sold
Research and analytic companies that study trends and patterns. These companies may combine this information with other information they hold from other companies.
  • to provide accounts and services that are suitable for you,
  • to share information that may help you when you need extra support, and
  • to help us and them to understand trends which we use to improve services.
  • information about your transactions.
Financial service providers, such as banks
  • to provide accounts and services that are suitable for you
  • personal information
  • information about your accounts with us
  • information about your transactions
Insurance companies
  • to provide accounts and services that are suitable for you.
  • personal information
  • details of relevant insurance claims
  • information about your life stage
Law enforcement agencies, government bodies
  • to investigate possible crime and to help recover your money if you are a victim of fraud and scams,
  • to protect you, your money and our interests,
  • to follow laws and regulations inside and outside Ireland.
  • personal information
  • information we reasonably believe is true about you and your money that we must share under law
  • Information that helps to protect your interests and ours.
Payment software providers such as online payment providers
  • to provide accounts and services that are suitable for you.
  • personal information
  • information about your transactions

Professional advisors:

  • auditors
  • legal advisors
  • to sell part or all of our business,
  • to protect your interests and ours,
  • to follow laws and regulations inside and outside Ireland.
  • personal information
  • information about your accounts
  • information about complaints you have made about us
  • Information about any other agreements you have with us
Regulators such as the Data Protection Commission, Central Bank of Ireland, Pensions Authority and the European Securities & Markets Authority
  • to prevent crime,
  • to follow laws and regulations,
  • to manage any complaints from regulators.
  • personal information
  • information about your accounts with us
  • Information about your transactions
  • information about complaints you have made
Security operations
  • to prevent crime.
  • personal information
  • CCTV images
Security trustees, for example a person or company that manages property or assets for a third party
  • to provide accounts and services that are suitable for you.
  • personal information
  • information about your accounts with us
  • information about your transactions
Social media platforms such as X, Instagram, and LinkedIn
  • to find out what is being said about us on social media
  • information such as what you say about us
  • information about your social media posts about us.
Joint venture companies, that we work with. These companies may combine this information with other information they hold from other companies.
  • to provide accounts and services that are suitable for you, and
  • to help us and them to understand trends which we use to improve services
  • personal information

Sending your information outside the European Economic Area (EEA)

Sometimes, to give you the service you ask for, we will send your personal information outside the European Economic Area (EEA). This includes countries in the European Union, Norway, Iceland and Liechtenstein. We only send information to countries that have the same standard of protection for your information that we have in Ireland.

The level of protection of information we send to organisations outside the EEA, for example organisations in the United Kingdom, United States or India, is decided by the European Union. The details of these protections are available by contacting [email protected]

If you want to make a complaint

If you are unhappy with the way we collect, use, keep and share your information, please tell us. This can be done via email, letter or phone call to your Relationship Manager/point of contact within Goodbody.

If you are unhappy with our response, you can take your complaint to the Data Protection Commission in Ireland. You can do this by:

  • visiting their website at www.dataprotection.ie
  • writing to Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland.

Updates to this notice

We will make changes to this notice from time to time, particularly when we change how we use your information, and change our technology and services. You can always find an up-to-date version of this notice:

  • on this website or,
  • by asking us for a copy.

Your Data Protection Rights

To see more details about how you can action your data protection rights, please click here.

Investment Banking

Conflicts of Interest Policy Related to the Production of Investment Research Reports

Introduction

This policy sets out the measures adopted by Goodbody Stockbrokers (the “Firm”) to ensure the objectivity and impartiality of its Capital Markets investment research. It has been prepared for information purposes for the Firm’s clients and other interested parties. More detailed internal policies and procedures with which all relevant staff are required to comply support this policy.

Goodbody Stockbrokers, trading as Goodbody, is regulated by the Central Bank of Ireland. Goodbody is a member of the Irish Stock Exchange and the London Stock Exchange. Goodbody is a wholly owned subsidiary of Allied Irish Banks, p.l.c. Registered Office: 9-12 Dawson Street, Dublin 2, D02 YX99. Tel:+353 1 667 0400; Registered In Ireland: Registration No. 54223.

 

Nature of Investment Research

The Capital Markets Research department provides research coverage on most securities listed on the Irish Stock Exchange, Irish Issuers listed on other markets and other issuers which in the opinion of the Head of Research, are likely to be of significant interest to our clients. The department also provides sectoral coverage relevant to issuers covered by Goodbody Stockbrokers and macroeconomic analysis.

 

Law and Regulation

Written Institutional Research is prepared for the use of institutional investors and emailed to those clients. Research activities are carried out in accordance with all applicable laws and regulations, and must not be carried out in a manner which the Researcher knows or should know to be likely to put any other person at significant risk of acting in an unlawful manner or in breach of the rules or regulation applicable to that person. Researchers are expected to be aware of the laws and regulations applicable to their work and to seek advice from the Head of Research or the Compliance Department in cases of doubt. Researchers are also expected to act in a manner, which promotes high standards of ethical behaviour and professionalism.

 

Independence

Goodbody policy is that the views expressed in research pieces must be independent and in particular must not take into account any business relationship or interest which Goodbody Stockbrokers may have or any conflicting personal interests. No person is authorised to put direct or indirect pressure on an Analyst to change his opinions or the manner in which they are expressed or to take action of any type against an Analyst because of the expression of views which do not coincide with Goodbody Stockbrokers.

Analysts are not permitted to hold external positions (i.e. appointment to a board of Directors, as an officer or its equivalent) the nature of which might compromise their independence. All external positions must be approved by Compliance In common with other staff of Goodbody Stockbrokers, Analysts are prohibited from accepting any gift or inducement, which could call into question their integrity or independence. This does not preclude acceptance of reasonable corporate hospitality in common with the Firm’s general policies on gifts and benefits.

 

Information Barriers

The Firm has formal policies relating to the maintenance and operation of Information Barriers procedures. These procedures generally enable research coverage and trading to continue in circumstances where, in the absence of such procedures, insider dealing and market abuse legislation would prevent Goodbody Stockbrokers from trading in or covering the stock. Under no circumstances are Analysts to seek to directly or indirectly obtain unpublished confidential information which is material to a listed company. Research Management has to pre-approve any request by Investment Banking staff to bring an Analyst over the wall to ensure the Analysts activities are managed to avoid actual or potential conflicts with other activities that the Analyst may be involved in.

 

Management and Supervision Arrangements

The Capital Markets Research department operates as an independently managed department. All Research Analysts, report to the Head of Research. The Head of Research reports into the Head of Capital Markets who in turn reports into the Managing Director. Analysts do not report to, and are not supervised by, personnel in any other department, including Corporate Finance The Head of Research is responsible for allocating coverage of issuers among the research team and for ensuring that appropriate arrangements are in place to clearly identify responsibility for any given piece of research and for ensuring that appropriate arrangements are in place for the preparation, review and issuance of research.

 

Remuneration of Research Analysts

Similar to all other staff members of the Firm, Analysts remuneration consist of an annual salary together with bonuses based on both the Firm’s profitability and the individual performance. Factors which may be taken into account when determining remuneration include the individuals productivity and performance, the overall quality of their research, feedback and evaluation from the Firm’s institutional clients and sales team and the Firm’s overall performance and profitability. No Analyst is remunerated on the basis of involvement in any particular transaction or for any particular piece of work.

 

Personal Account Dealing

Research Analysts are not permitted to deal for their own account or that of their immediate family, in any securities of the companies they cover save in limited cases relating to holdings which existed prior to the introduction of Goodbody Stockbrokers Capital Markets Research policy or the date the Analyst commenced coverage of the stock. Analysts holding shares in companies, which they do not cover, are subject to the Firm’s normal staff dealing rules.

 

Restrictive Activities

Analysts are not permitted to participate in efforts to solicit investment-banking business or attend any company or investment-banking business sponsored road shows, related to a public offering or secondary fundraising. In general, where Goodbody Stockbrokers are acting in connection with an Initial Public Offering or a large secondary offering, research cannot be issued for a set period of time. Researchers will however meet companies including corporate clients separately in the normal performance of their duties.

 

Discontinuation of Coverage

In the rare event that the Firm discontinues coverage of a stock, (other than a delisting) it will be disclosed in the Firm’s monthly book citing the rationale for such termination.

 

Disclosures

All Institutional Equity Research publications contain required general and specific disclosures.

Conflicts of Interest

Goodbody has procedures and policies in place to identify and manage any potential conflicts of interest that arise in connection with its research business. Goodbody analysts and other staff who are involved in the preparation and dissemination of research operate and have a management reporting line that is independent to its business. Information barriers are in place between the Corporate Finance arm and the Research arm to ensure that any confidential and or price sensitive information is handled in an appropriate manner.

Our Investment Research Conflicts of Interest Policy is available at Conflicts of Interest. Investors should be aware, that, where appropriate, research may be disclosed to the issuer(s) in advance of publication, in order to correct factual inaccuracies only and not to materially amend the research in any way. Goodbody is satisfied that it has operational procedures in place, which ensure that such disclosures will not compromise the report’s objectivity.

Goodbody Stockbrokers is a registered market maker in the majority of companies listed on the Irish Stock Exchange and their equivalent on the London Stock Exchange and may hold positions in any of the companies mentioned in this report from time to time. The list of companies for which Goodbody acts as market maker and on which it provides research, is available at Regulatory Disclosures. We would like to inform you that Dudley Shanley holds shares in Dalata Hotel Group, Ryanair and Wizz Air.

Goodbody has provided investment banking services to AIB Group, Applied Nutrition, Cairn Homes, CRH, Datalex, FD Technologies, Grafton Group, Greencore, Hammerson, Hostelworld, ICG, Kingspan, LungLife AI, Molten Ventures, Origin Enterprises, Playtech, Rank Group, Ryanair, Smurfit Westrock, NTMA, BNP, Goldman Sachs, JP Morgan, ING Groep NV, Bank of America Merrill Lynch, Morgan Stanley, Flutter, NatWest, Accorinvest, Wells Fargo, UBS, PTSB and Barclays in the past 12 months.

Goodbody Stockbrokers UC acts as corporate broker to AIB Group, Applied Nutrition, Cairn Homes, CRH, Datalex, Grafton Group, Greencore, Hostelworld Group, ICG, Kingspan, Molten Ventures, Origin Enterprises, Playtech and Ryanair.

 

Other Disclosures

A description of this company is available at Company Descriptions. All prices used in this report are as at close of business of the previous working day unless otherwise indicated.

A summary of our standard valuation methods are available at Valuation Methodologies. A summary of share price recommendations and whether material investment banking services have been provided to these companies is available at Regulatory Disclosures. Other important disclosures are available at Regulatory Disclosures. Goodbody updates its recommendations on a regular basis. A breakdown of all recommendations provided by Goodbody is available at Regulatory Disclosures. Where Goodbody has provided investment banking services to an issuer, details of the proportion of buys, holds and sells attributed to that issuer will also be included. This is updated on a quarterly basis.

The date on which stock recommendations were first released for all stocks mentioned in this report are available at Regulatory Disclosures. If a different recommendation has been made in the previous twelve months, this will also be disclosed here.

 

Recommendation Definitions

Goodbody uses the terms “Buy”, “Sell” and “Hold. The term “Buy” means that the analyst expects the security to appreciate in excess of 10% over a twelve month period. The term “Sell” means that the security is expected to decline in excess of 10% over the next twelve months. The term “Hold” means that the analyst expects the security to neither appreciate more than 10%, or depreciate more than 10% over the next twelve months.

On 26th November, 2012, the terms “Add” and “Reduce” were removed from the Recommendation Definitions and both were replaced with the “Hold” recommendation. Any Previous Recommendation that refers to either an “Add” means that the analyst expected the security to appreciate by up to 15% over a twelve month period. Any Previous Recommendation to “Reduce” means that the analyst expected the security to decline by up to 15% over the next twelve months.

In the event that a stock is delisted the firm will automatically cease coverage. If however the firm ceases to cover a stock for any other reason the firm will disclose this fact.

Goodbody Stockbrokers UC is an unlimited company registered in Ireland. The firm’s head office is based at 9-12 Dawson Street, Dublin 2, D02 YX99, Ireland. The firm’s issued share capital is €10 million. The firm is not subject to any insolvency or analogous proceedings.

GSI distributes third-party research produced by its affiliate, Goodbody.

GSI is a member of FINRA and SIPC.

GSI does not act as a market-maker.

An affiliate of GSI may have acted, in the past 12 months, as lead manager/co-lead manager of a publicly disclosed offer of the securities in this company. Investors should be aware that an affiliate of GSI may have provided investment banking or non-investment-banking services to, and received compensation from this company in the past 12 months or may provide such services in the next three months. The term investment banking services includes acting as broker as well as the provision of corporate finance services, such as underwriting and managing or advising on a public offer. All transactions by US persons involving securities of companies discussed in this report are to be effected through GSI.

Regulatory Information

Goodbody Stockbrokers UC, trading as Goodbody, is regulated by the Central Bank of Ireland. In the UK, Goodbody is also subject to regulation by the Financial Conduct Authority. Goodbody is a member of Euronext Dublin and the London Stock Exchange. Goodbody is a wholly owned subsidiary of Allied Irish Banks, p.l.c. This publication has been approved by Goodbody. The information has been taken from sources we believe to be reliable, we do not guarantee their accuracy or completeness and any such information may be incomplete or condensed. All opinions and estimates constitute best judgement at the time of publication and are subject to change without notice. The information, tools and material presented in this document are provided to you for information purposes only and are not to be used or considered as an offer or the solicitation of an offer to sell or to buy or subscribe for securities.

Goodbody Stockbrokers is a registered market maker in variety of companies listed on Euronext Dublin and the London Stock Exchange and may hold positions in any of the companies mentioned in this report from time to time. The list of companies for which Goodbody acts as market maker and on which it provides research, is available at Regulatory Disclosures.

 

Disclaimer for recipients of research reports.

While all reasonable care has been taken in the production and dissemination of this report it is not to be relied upon in substitution for the exercise of independent judgement. Nothing in this report constitutes investment, legal, accounting or tax advice, or a representation that any investment or strategy is suitable or appropriate to your individual circumstances, or otherwise constitutes a personal recommendation to you.

Private customers having access, should not act upon it in anyway but should consult with their independent professional advisors. The price, value and income of certain investments may rise or may be subject to sudden and large falls in value. You may not recover the total amount originally invested. Past performance should not be taken as an indication or guarantee of future performance; neither should simulated performance. The value of securities may be subject to exchange rate fluctuation that may have a positive or adverse effect on the price or income of such securities.

All material presented in this report, unless specifically indicated otherwise is copyright to Goodbody. None of the material, nor its content, nor any copy of it, may be altered in any way, transmitted to, copied or distributed to any other party, without the prior express written permission of Goodbody.

Information regarding communications from Goodbody Capital Markets Sales or Specialist Sales Teams.

Any commentary received from the Goodbody Capital Markets Sales team or Specialist Sales Team should be regarded as a marketing communication as described in Article 36 of Commission Delegated Regulation (EU) 2017/565.

Publications received from the Goodbody Capital Markets Sales team or Specialist Sales team do not constitute investment research and should not be regarded as being objective or independent. Such publications are not prepared in accordance with the legal requirements designed to promote the independence of investment research and are not subject to any prohibition upon dealing ahead of their dissemination. Communications from Goodbody Sales or Specialist Sales are not prepared in accordance with conflicts of interest requirements relating to the objective production of investment research.

Material received from Goodbody Sales or Specialist Sales teams is intended for the sole use of the person or firm to whom it is provided and is for discussion purposes only. It is not intended for further dissemination in its present form and may not be disseminated to other parties.

In the event of any significant business disruption, Goodbody has in place a business continuity process to ensure that we can maintain continuity of services for our clients. In the event of any such disruption you can contact us as you usually do on our main phone line +353 1 667 0400. We can also be contacted by email at [email protected]

Goodbody Stockbrokers apply a range of valuation methodologies in the production of Equity Research, within which the following are the main methods adopted:

1. Share-based multiples include:

  • Forward price/earnings (P/E) ratios, based on adjusted earnings.
  • Forward price/cash-earnings ratios
    Price to net asset value (NAV) per share and
  • Dividend yields.

 

2. Enterprise-based valuation multiples include:

  • Forward earnings before depreciation, interest, tax, depreciation or amortisation (EBITDA) ratios;
  • forward operating cash-flow ratios
    Enterprise value (EV)/sales ratios; and
  • EV/invested capital ratios.

 

3. Cyclical consideration

In the case of average earnings multiples, consideration is given to the stage of the relevant industry cycle, as it may not be appropriate to apply average multiples towards the peak or trough of a cycle. In such cases, earnings multiples prevailing at the corresponding stages of previous cycles may be used.

 

4. Asset based valuations

In the case of asset-based valuations, reported tangible net assets generally provide a floor to a company’s valuation. However, in many cases, company financial statements can understate the underlying economic value of a company’s assets and a ratio such as return on invested capital to weighted average cost of capital (ROIC/WACC) may provide a more appropriate indicator of the book value multiple.

 

5. Company comparisons

The ratings of similar companies (peer groups) may be taken into account as a proxy for the average ratings for particular industry sectors. Such ratings are commonly used in analysts’ sum-of-the-parts (SOTP) valuations.

 

6. Cashflow based valuation

In discounted cash-flow (DCF) models a company’s forecast future free cash-flows are discounted by its weighted WACC. However, due to the inherent uncertainties involved in forecasting long-term cash-flows, analysts tend to adopt a range of both WACC and terminal values within the DCF models, producing a range of alternative valuations.

 

7.Other valuation techniques

In some instances, other valuation metrics may be used. For instance, for airlines metrics per passenger and / or available seat kilometre flown may be used for inter-company and valuation purposes.

Goodbody Asset Management

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