Conflict Of Interest Policy


Under the applicable legislation, the Company is required to take all reasonable steps to detect and avoid Conflict of Interest. The Company is committed to act honestly, fairly and professionally in the best of interests towards our Clients and to comply in particular with the principles set out in the applicable legislation when providing investment services and other ancillary services related to such services.

We provide a summary of the policy which we maintain in order to manage Conflict of Interest in respect of the duties we owe to our Clients.  This Policy is not intended to, and does not create third party rights or duties that would not already exist if the Policy had not been made available or if  forms part of any contract between the Company and any Client.



The purpose of this summary document is to set out the Company’s approach to identifying and managing Conflict of Interest which may arise during the course of its business activities. The Policy applies to all its Directors, Employees, any persons directly or indirectly linked to the Company (hereinafter called “related persons”) and refers to all interactions with all Clients.

The aim of our Policy is to identify and prevent Conflicts of Interest which may arise between the Company and its Clients or between one Client and another. Accordingly, we have adopted a Conflict of Interest Policy setting out the procedures, practices and controls in place to achieve this.


Identification of Conflict of Interest

To identify the type of Conflict of Interest that arise due to provision of investment and ancillary services or a combination of both and whose existence may damage the interest of a Client, the Company takes into account, whether the Company or a relevant person, is part of any of the following situations, whether or as a result of providing investment or ancillary services or investment activities or otherwise:

  1. The Company or relevant person is likely to make a financial gain or avoid a financial loss at the expense of the Client, especially when the Company is acting as a principal, or the Company or any of its agents provide advice or market information to the Client;
  2. The Company or relevant person 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 the outcome;
  3. The Company or relevant person has financial or other incentives to favour the interest of another Client or group of Clients over the interest of the Client;
  4. The Company or relevant person carries on the same business as the Client;
  5. The Company or relevant person 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 money, goods or services other than the standard commission or fee for that service.


Managing Conflict of Interest

The Company has set up internal policies and has an in-house Compliance Department that is responsible for identifying and managing the potential Conflict of Interest. The above will also update the relevant internal procedures and ensure compliance with such procedures.

The Company maintains and operates with effective organisational and administrative procedures to manage the identified conflict of interest. The Company also undertakes ongoing monitoring of business activities to ensure that internal controls are appropriate. In general, the procedures and controls that the Company follows regarding Conflict of Interest include the following measures:

  1. 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;
  2. 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 Company;
  3. 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;
  4. 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;
  5. 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 with proper management in a Conflict of Interest.


Internal Controls

Pursuant to Article 14 of the Act, The Company ensures the establishment of orders in the proceeding of internal control which includes the following issues and demands: (a) Defence from revealing confidential information and (b) Defence in the demands of market ethics.