MANAGING CONFLICTS OF INTEREST. The Company has established suitable and adequate internal procedures for minimising any potential conflicts of interest. The Company maintains a compliance department that is an independent unit within the Company. Among the duties of the CO is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest. Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliance function will assess each conflict and determine if the conflict is actual or perceived and what the value of the conflict or exposure is and the potential reputational risk. Compliance will then decide whether it is viable to go ahead with the transaction or if the conflict is too severe. If Compliance decides that the particular conflict can be mitigated, then controls to manage the conflict should be put in place and documented. The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its employees and between its customers and to organise and control their internal affairs responsibly and effectively. The Company and its employees should act as per the principle of placing clients’ interests before self-interests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures: • The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably arises, ensure fair treatment to the client by complete disclosure or by declining to act. • Employees are also prohibited to keep investor accounts in other Brokers without Company’s prior authorization and are obliged to bring this to Company’s attention. They are also obliged to authorize the Company to directly request transaction reports from the other Brokers. • If the Company has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to the transaction, the licensee shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only exception is when the licensee has fairly disclosed that material interest or relationship, as the case may be, to the client or the client has taken reasonable steps to ensure that neither the materia...
MANAGING CONFLICTS OF INTEREST. As part of its efforts to manage conflicts of interest, T1/HCI management has undertaken the following measures, which include but not limited to:
MANAGING CONFLICTS OF INTEREST. We may act for clients which may compete with or, more rarely, may even be involved in business with you. Naturally, we will continue to assist those clients or new clients in projects that are not substantially related to work we are engaged to perform for you. We will not disclose or use any confidential information you may disclose to us in the course of our working for you except where required in the course of our acting for you.
MANAGING CONFLICTS OF INTEREST contractors and people who provide services to the group
MANAGING CONFLICTS OF INTEREST. (a) The Expert agrees to abide by the DRS Conflict of Interest Policy (attached).
MANAGING CONFLICTS OF INTEREST. (a) The Mediator agrees to abide by the DRS Conflict of Interest Policy (attached).
MANAGING CONFLICTS OF INTEREST. We maintain and operate effective organisational and administrative procedures to manage and prevent any identified conflict of interest from constituting or giving rise to a material risk of damage to the interests of our clients. We also undertake ongoing monitoring of business activities to ensure that these internal controls are appropriate. The measures adopted are designed to ensure that relevant persons engaged in different business activities involving a potential conflict of interest carry on those activities at a level of independence proportionate to the size and activities of the Firm, and to the materiality of the risk of damage to the interests of our clients. In general, the procedures and controls that we follow regarding conflicts of interest include the following measures to ensure the requisite degree of independence: a) Effective procedures to prevent or control the exchange of information between relevant 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; b) 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 FxPro; c) 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, where a conflict of interest may arise in relation to those activities; d) Measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities; e) Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of conflicts of interest.
MANAGING CONFLICTS OF INTEREST. 4.1 The Company has set up internal policies and has an in-house Compliance Department that are responsible for identifying and managing potential conflicts of interests. The above will also update the relevant internal procedures and ensure compliance with such procedures.
MANAGING CONFLICTS OF INTEREST. The Chief Executive should delegate to the Institute’s Finance Director16 (or one of the other Executive Institute Board members) the discretion to refer proposals which could involve a conflict of interest to the Institute’s Board, without first consulting him or her, if they believe that a conflict of interest arises and it would be inappropriate to bring it to the Chief Executive’s attention first. In any case where the Chief Executive is asked to consider a proposal which they believe could involve a conflict of interest, they should refer that decision to the Institute’s Board, along with the recommendation that the Institute’s Board take the advice of the PAO before making their decision.
MANAGING CONFLICTS OF INTEREST. The Company acknowledges that Consultant is now or may become a party to agreements with third parties relating to the disclosure of information, the ownership of inventions, restrictions against competition and/or similar matters. Consultant represents and agrees that the execution, delivery and performance of this Agreement does not and will not conflict with any agreement, policy or rule applicable to Consultant. Consultant will not (i) disclose to the Company any information that Consultant is required to keep secret pursuant to an existing confidentiality agreement with any third party, (ii) use the funding, resources, facilities or inventions of any third party to perform the Consulting Services, or (iii) perform the Consulting Services in any manner that would give any third party rights to any intellectual property created in connection with such services. Consultant shall comply with all applicable laws and regulations in connection with the performance of the Consulting Services.
