Summary of Conflicts
Summary of Conflicts
Summary of Conflicts
- INTRODUCTION
This is a summary of our primary policy to prevent and manage conflicts of interest in relation to our obligations to Clients.
- DEFINITION AND IDENTIFICATION OF CONFLICTS
Conflict situations occur when a client or potential client's interests conflict with another client's or ours. Thus, one or more clients may be affected. This policy includes our employees' and agents' interests.
We will take reasonable measures to identify conflicts of interest between our Company, our managers, employees, and associated agents, or any person directly or indirectly controlled by us, and our Clients or between our Clients when providing a service.
III. POLICY
We keep an updated list of investment services and activities that may cause a conflict of interest or harm one or more clients. To avoid or resolve such disagreements, we have certain established procedures.
- DISCLOSURE
Where our organizational and administrative arrangements to prevent or manage conflicts are not, or cannot be, adequate to provide reasonable assurance that the risk of harm to a client's interests will be avoided, we will attempt to disclose the nature and/or sources of conflicts, as well as the risks to the client arising from the conflict and the steps taken to mitigate these risks, prior to engaging in business with the client. Any disclosure must provide enough information for the client to make an informed choice.
- CONFLICT MANAGEMENT
We have established operational procedures for managing real and potential conflicts. This entails the implementation of information barriers, segregation of jobs and responsibilities, and physical separation of individuals, among other measures, in order to ensure enough independence between Company employees engaged in separate activities. It has been meticulously ensured that access to Client information and company data is restricted to those with an absolute need for it. Employee responsibilities are compartmentalized so that no information is shared, and whenever possible, Company support personnel are physically separated. Gifts and/or hospitality presented to or given by workers are regulated, and no gift or series of gifts may be received or donated by employees if deemed excessive or if they may compromise the Company's obligation to act in the best interests of Clients.
