DISCLOSURE OF MINOR NON-MONETARY BENEFITS
This supplement should be read in conjunction with the Terms of Business for investment business conducted by, or any other specific product document for investment business conducted by, J.P. Morgan Securities plc, J.P. Morgan Europe Limited (and any of its branches established in the EEA), JPMorgan Chase Bank, National Association (London Branch, or any other of its branches established in the EEA), J.P. Morgan Limited, J.P. Morgan Markets Limited and J.P. Morgan SE (together J.P. Morgan).
Where you are subject to restrictions under regulatory rules applicable to you on the receipt of fees or commissions or the provision or receipt of non-monetary benefits (other than acceptable minor non-monetary benefits), in both cases to or from third parties, you are responsible for compliance with these requirements and must assess whether any non-monetary benefit we may provide to you is in compliance with the regulatory rules as they apply to you. Accordingly, we provide no assurance that any non-monetary benefit we may provide to you complies with the regulatory rules as they apply to you.
We may provide you with certain acceptable minor non-monetary benefits listed in the relevant EEA member state national implementation of Article 12(3) of Commission Delegated Directive (EU) 2017/593, which may include:
- information or documentation relating to a financial instrument or an investment service, that is generic in nature or personalised to reflect the circumstances of an individual client;
- written material from a third party that is commissioned and paid for by a corporate issuer or potential issuer to promote a new issuance by the company, or where the third party firm is contractually engaged and paid by the issuer to produce such material on an ongoing basis, provided that the relationship is clearly disclosed in the material and that the material is made available at the same time to any investment firms wishing to receive it or to the general public;
- participation in conferences, seminars and other training events on the benefits and features of a specific financial instrument or an investment service;
- hospitality of a reasonable de minimis value, such as food and drink during a business meeting or a conference, seminar or other training events mentioned above; and
- other minor non-monetary benefits which an EEA member state deems capable of enhancing the quality of service provided to a client and, having regard to the total level of benefits provided by one entity or group of entities, are of a scale and nature that are unlikely to impair compliance with an investment firm's duty to act in the best interest of the client.
Other minor non-monetary benefits:
Pursuant to the relevant EEA member state national implementation of Article 11(5)(a) of Commission Delegated Directive (EU) 2017/593, certain minor non-monetary benefits that J.P. Morgan may provide or receive, may be described in a generic way and these may include:
- Gifts and entertainment up to a value determined from time to time in J.P. Morgan’s policies
- Marketing material in the ordinary course of business (excluding marketing material that constitutes research)
- Trade ideas and commentary (excluding ideas or commentary that constitutes research)
- Training sessions in the ordinary course of business
- Deal and non-deal roadshows (where J.P. Morgan acts for the issuer)
- Conferences, seminars and other events (arranged by J.P. Morgan or places provided at third party events)
- Credit rating advisory services (where J.P. Morgan acts for the issuer)
This list of examples is non-exhaustive and subject to change.
- In accordance with your agreements with us, we may perform M&A, ECM or DCM services and/or other advisory services with the involvement of our affiliates including, inter alia, J.P. Morgan SE. When J.P. Morgan SE is involved in the provision of such services, the following applies:
- In accordance with the regulatory guidance from the German Federal Financial Supervisory Authority (BaFin), any payments for services made by companies affiliated with J.P. Morgan SE to J.P. Morgan SE may qualify as inducements pursuant to the German Securities Trading Act (Wertpapierhandelsgesetz). Therefore, J.P. Morgan SE may have an obligation to disclose such inducements to JPMorgan clients.
- For any M&A, ECM and DCM and/or other advisory services transactions in which J.P. Morgan SE is involved in the provision of services to JPMorgan clients, and in return receives a payment for such services from the client facing legal entity, the amount of the payment to J.P. Morgan SE could be up to 75% of the revenue earned by the client facing legal entity in connection with such transaction.
- The aforementioned payments do not lead to an increase of the overall fees to be paid by clients for M&A, ECM and DCM and/or other advisory services
- JPMorgan may decide to amend the revenue sharing outlined above at any time, and in such case J.P. Morgan SE will update this disclosure page if necessary.