Conflict of interest policy

As referred to in our General Conditions of Business, this document provides further insight on our conflicts of interest policy.

The purpose and applicability
Under the European Directive 2004/39/EC of 21 April 2004 on Markets in Financial Instruments (“MiFID”), we will maintain and operate effective organizational and administrative arrangements with a view of taking all reasonable steps to identify, monitor and manage such potential conflicts of interest. This document summarises a policy which we have put in place. This document provides key information designed to enable you to understand the measures we are taking to safeguard your interests.

Conflicts of Interest Policybr/> Our Conflicts of Interest Policy sets out how we will:
• identify circumstances which may give rise to conflicts of interest entailing a material risk of damage to your interests;
• establish appropriate mechanisms and systems to manage those conflicts; and
• maintain systems designed to prevent actual damage to your interests through any identified conflicts.

Identifying a “conflict of interest”
A conflict of interest under MiFID is a conflict that arises, in any area of our business, in the course of providing you with a service which may benefit us (or another client for whom we are acting) whilst potentially materially damaging your interests where we owe a duty to you. There may be a conflict where we (or anyone connected to us affiliate):

• are likely to make a financial gain (or avoid a loss) at your expense;
• are interested in the outcome of the service provided to you where our interests are distinct from your interests;
• have a financial or other incentive to favor the interests of one client over another; • carry on the same business as you; or
• receive money, goods or services from a third party in relation to services provided to you other than standard fees or commissions.

We have carried out an exercise to identify where potential conflicts of interest may exist in our business and have established measures we consider appropriate to monitor, manage and control the potential impact of those conflicts. The potential conflicts of interest identified include:

• those between our clients with competing interests;
• those between our clients and us where the respective interests in a particular outcome may be different; and
• those between the personal interests of our staff and our own interests or of our clients where those interests may be different.

Policies and procedures
We have well established internal policies and procedures designed to manage potential conflicts of interest. These policies and procedures, which are designed to ensure the required level of independence, are the subject of ongoing monitoring and review processes and include, but are not limited to:

Information barriers and Chinese walls:
We enforce procedures which control the exchange of information between our employees and/or parts of our business where the interests of one client may conflict with the interests of another client or with our own interests.
We have well established ‘Chinese Walls’ policies and procedures designed to manage confidential information and prevent the inappropriate transmission of confidential or price sensitive information (often referred to as ‘insider information’).

Separate supervision and segregation of function:
Where appropriate, we have arranged for the supervision and/or functional segregation of our employees and/or parts of our business carrying out activities for clients whose interests may conflict, or where the interests of our clients and our own interests may conflict. These steps are designed to prevent the simultaneous involvement of a relevant person in separate services or activities where such involvement may impair the proper management of conflicts.

Disclosure:
Where there is no other means of managing an identified conflict or where the measures in place do not, in our view, sufficiently protect your interests, the conflict of interest will be disclosed to you to enable an informed decision to be made by you as to whether you wish to continue doing business with us in that particular situation.

Declining to Act:
Where we consider we are not able to manage the conflict of interest in any other way we may decline to act for you. If you would like further detail regarding our Conflicts of Interest Policy please contact your Relationship Manager

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