According to the Ministry of Justice Guidance, supply chains and joint ventures may qualify as associated persons.

Supply Chains.  Where several entities form a supply chain, or where a prime contractor uses various sub-contractors, an organization usually has control only over its counterparty, so that only the counterparty would qualify.  

Joint Ventures.  It is likely that an agent who has been engaged by a participant in a contractual joint venture will be regarded as an associated person.

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