IDENTIFICATION OF CONFLICTS OF INTEREST
When the Company offers Investment Services to the client, an associate or some other person connected with the Company, it may have an interest, relationship or arrangement that is material in relation to the transaction concerned or that conflicts with the client’s interest.
In such situation, the Company adheres to a policy that the creation of conflicts of interest must, insofar as is possible, be prevented.
This is applied through a combination of control measures that play a role in various aspects of our business operations, such as:
– effective procedures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest if the exchange of that information may harm the interests of one or more clients
– the separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the firm
– the removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, when a conflict of interest may arise in relation to those activities
– measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out services or activities
– measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate services or activities when such involvement may impair the proper management of conflicts of interest.Based on the business model and experience of the Company the following circumstances (not exhaustive) which may give rise to a conflict of interest have been identified and are set out below as examples :
(a) the Company may be matching a client’s Order with that of another client by acting on such other client’s behalf, as well as, on the client’s behalf;
(b) the Company may be providing other services to associates or other clients of the Company who may have interests in Financial Instruments or investments or Underlying Assets, which are in conflict or in competition with the client’s interests;
(c) the Company may have an interest in maximizing trading volumes in order to increase its commission revenue, which is inconsistent with the Client’s personal objective of minimizing transaction costs;
(d) the Company may receive or pay inducements to or from third parties due to the referral of new clients;
(e) 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’s portfolio, which is distinct from the client’s interest in that outcome;
(f) 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;
(g) the Company or a related person carries on the same business as the client.
For the purposes of identifying the types of conflict of interest that arise in the course of providing investment and ancillary services or a combination thereof and whose existence may damage the interests of a client, the Company takes into account, whether the Company or a relevant person, is in any of the following situations, whether as a result of providing investment or ancillary services or investment activities or otherwise:
1) is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
2 has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;
3) has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client;
4) carries on the same business as the client;
5) 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.