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We aim to identify and prevent any conflicts of interest which may occur between us and our clients, or between one client and another, to avoid possible adverse effects which may arise.
This Policy applies to all directors (Executive and Non Executive), officers, and employees of the company and refers to dealings with all of our clients.
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The FCA has detailed requirements relating to the management of conflicts of interest, which are primarily found in the FCA Senior Management Arrangements Systems and Controls sourcebook, section 10.
Our requirements as a firm under these include:
- establishing, implementing and managing an effective written conflicts of interest policy.
- taking all reasonable steps to identify conflicts of interest between us and our clients
- keeping and updating a record of the services we undertake, in which a conflict of interest entails a material risk of damage to the interests of one or more of our clients, which has arisen or may arise.
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We have identified the types of conflicts that may occur and which carry a material risk of damage to the interests of a client. These include, but are not limited to, when we or any person directly or indirectly linked to us:
- have an interest in the outcome of a service or product provided to, or of a transaction carried out on behalf of our client, which is distinct from our clients’ interest in that outcome.
- design, market or recommend a product or service without properly considering all of our other products and services and the interests of our clients.
- are likely to make a financial gain or reduce/avoid a financial loss at the expense of our client.
- receive or will receive from a person other than our client an inducement in relation to the service provided to our client in the form of monies, goods or services, other than the standard commission or fee for that service.
- have a financial or other incentive to favour the interests of another client or group of clients over the interests of our client.
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We have implemented the systems and procedures referred to below, to minimize the potential causes for conflicts of interest, to manage all conflicts of interest and where possible avoid material conflicts of interest.
- Personal Account Dealing All Personnel are bound by the requirements of our Personal Account Dealing Notice. All transactions undertaken are actively monitored by our Compliance Department.
- Data Access The access to data on computer drives is restricted by the use of passwords and user ID’S. Computers are automatically locked if unattended for a short period. Personnel are regularly reminded of the importance of data protection.
- Information Release Personnel may not release and or disclose information to another party without ensuring that there is a clear need to know basis for the recipient and that they are made aware of the requirement to treat the information as confidential.
- External business interests Personnel may not engage (unless granted prior written consent from our senior management or permitted under the terms of their employment) or have an interest in any business which is or may be in competition with us and or which would involve the use of our time, property, facilities or resources.
- Segregation of duties Employment duties are designed to limit the potential for conflicts of interest. Given the nature of our business there can be occasions which could give rise to a conflict, in these circumstances additional controls are in place to identify inappropriate behavior. All Personnel are regularly assessed for competency in their roles and are required to follow the internal procedures detailed in our Compliance Manual.
As part of the Compliance Department’s duties, they undertake regular reviews of each department’s operations, the roles undertaken by the individuals within that department and the segregation of duties are reviewed as appropriate.
- Training Regular training is provided to our Personnel on conflicts of interest and the procedures for managing conflicts of interest.
- Independence Policy Situations may arise where it is appropriate to manage conflicts of interest by requiring personnel to adhere to and observe a policy of independence. If this arises, Personnel will be required to sign an undertaking to disregard relevant conflicts of interest in discharging their functions.
- Disclosure Policy We believe that our internal policies and procedures, systems and controls, generally mitigate the risk of any conflict of interest arising, either between us and our client or between two or more of our clients. However, where despite this, the potential for conflict arises and cannot be avoided we would either make a full disclosure or not proceed with the transaction.
- Public Interest Disclosure Policy We are committed to ensuring that malpractice is prevented and should it arise is dealt with immediately. Personnel are informed as to whom they can and should report public interest issues.
The United Kingdom Public Disclosure Act 1998 (PIDA) allows employees to disclose certain issues to particular external parties where there is good reason to believe that internal disclosure will not be taken seriously or will cause the employee to be penalized in some way
For the purposes of this procedure and PIDA, the following constitute malpractice;
- the commission of a legal offence
- failure to comply with a legal obligation
- the occurrence of a miscarriage of justice
- the endangerment of an individuals health and safety
- the endangerment of the environment and
- the concealment of any information relating to any of the above.
Gifts and Inducements Personnel may not solicit or accept any gift of inducement which may influence their independence or business judgement or which could create a conflict with any duty owed to us or our clients.
This restriction does not include any special promotions which have been agreed by our senior management, nor does it cover corporate gifts and hospitality which are considered to be incidental to our standard business.
Personnel are required to register with the Compliance Department details of hospitality of gifts, whether given or received with an estimated value in excess of £200 and to seek guidance if in doubt about the suitability of the gift.