This summarized Conflict of Interest Policy (“the Policy”) is provided to you in accordance with the applicable laws and it may be subsequently amended from time to time in accordance the necessity to take all reasonable steps to detect and avoid conflicts of interest.
The Company is committed to act honestly, fairly and professionally and in the best interests of its Clients and to comply, in particular, with the principles set out in legislation during service providing.
The purpose of this document is to set out the Company’s approach in identifying and managing conflicts of interest which may arise during the course of its normal business activities. In addition, this document identifies circumstances which may give rise to a conflict of interest.
The Policy applies to all its directors, employees, any persons directly or indirectly linked to the Company (hereinafter called “Related Persons”) and refers to all interactions with all Clients.
When the Company deals with the Client, the Company, an associate or some other person connected with the Company may have an interest, relationship or arrangement that is material in relation to the Transaction concerned or that it conflicts with the Client’s interest.
While it is not feasible to define precisely or create an exhaustive list of all relevant conflicts of interest that may arise, as per the current nature, scale and complexity of the Company’s business.
To identify different types of conflicts that might arise in the course of providing the Service, and whose existence may harm or otherwise damage one or more Clients’ interests, by way of minimum criteria, the question of whether the Company itself or a Related Person or a person directly or indirectly linked by control to the Company, is in any of the following situations, as a result of providing investment services or otherwise:
3.1 The Company or a Related Person is likely to make a financial gain or avoid a financial loss at the expense of a Client.
3.2 The Company or a Related Person receives or will receive from a person other than the Client an inducement in relation to a service provided to the Client, in the form of monies, goods or services, other than the standard commission or fee for that service.
3.3 The Company or a Related Person has an interest in the outcome of a service provided to the Client or of a transaction carried out for the Client, which is distinct from the Client’s interest in that outcome.
3.4 The Company or a Related Person has a financial or other incentive to favor the interest of another Client or group of Clients over the interests of the Client.
3.5 The Company or a Related Person carries on the same business as the Client.
In general, the procedures and controls that the Company follows to manage the identified conflicts of interest include the following measures (list is not exhaustive):
4.1 The Company undertakes ongoing monitoring of business activities to ensure that internal controls are appropriate.
4.2 The Company undertakes effective procedures to prevent or control the exchange of information between Related Persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more Clients.
4.3 The separate supervision of Related Persons whose principal functions involve providing services to Clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company.
4.4 Measures to prevent or limit any person from exercising inappropriate influence over the way in which the Related Person carries out investment services.
4.5 Measures to prevent or control the simultaneous or sequential involvement of a Related Person in separate investment services where such involvement may impair the proper management of conflicts of interest.
4.6 Restricting the flow of confidential and inside information within the Company, and physical separation of departments.
4.7 Internal procedures governing access to electronic data.
4.8 Segregation of duties that may give rise to conflicts of interest if carried on by the same individual.
4.9 Personal account dealing requirements applicable to Related Persons in relation to their own investments.
4.10 Prohibition on officers and employees of the Company having external business interests conflicting with the interests of the Company without the prior approval of the Company’s board of directors.
By entering into a Client Agreement with the Company for the provision of Services, the Client is consenting to an application of this Policy on him. Further, the Client consents to and authorizes the Company to deal with the Client in any manner which the Company considers appropriate, notwithstanding any conflict of interest or the existence of any material interest in a Transaction, without prior reference to the Client. In the event that the Company is unable to deal with a conflict of interest situation it shall revert to the Client.
If during the course of a business relationship with a Client or group of Clients, the organizational or administrative arrangements/measures in place are not sufficient to avoid or manage a conflict of interest relating to that Client or group of Clients, the Company will disclose the conflict of interest before undertaking further business with the Client or group of Clients.
The Company reserves the right to review and/or amend this Policy and arrangements whenever it deems this appropriate without notice to the Client. In case, if require any further information and/or have any questions about conflicts of interest please direct your request and/or questions to firstname.lastname@example.org.