Conflict of Interest Summary
Introduction
Investa Markets Limited ("IML", the "Firm") is committed to identifying, preventing, and managing conflicts of interest that may arise during our business activities. Our policy is designed to ensure that the interests of our clients are always placed above our own or those of our staff.
What is a conflict of interest
A conflict of interest may arise when there is a mismatch between:
- The Firm’s interests and those of a client.
- The interests of our staff (directors, managers, or employees) and those of a client.
- The interests of one client and those of another client.
Specific examples include situations where the Firm is likely to make a financial gain at a client’s expense, or where a staff member receives an inducement from a third party in relation to a service provided to a client.
Identifying and monitoring
IML maintains a Conflicts of Interest Register to record and monitor circumstances that may entail a risk of damage to client interests. To keep our management of conflicts relevant, we utilise:
- Staff Training: Ensuring all personnel understand how to identify and report potential conflicts.
- Product Approval: Assessing conflict risks during the launch of any new service or business change.
- Data Reviews: Regularly reviewing personal account dealing records and staff disclosures regarding Outside Business Interests.
- Board Oversight: Providing regular reports to the Board of Directors on the efficiency of our conflict management measures.
How we manage conflcits
We take all reasonable steps to prevent or manage conflicts through robust organizational and administrative arrangements, including:
- Information Barriers: Procedures to prevent or control the exchange of information between staff engaged in activities where a conflict risk exists.
- Separate Supervision: Ensuring staff providing services to clients with conflicting interests are supervised independently.
- Remuneration Structures: Removing direct links between the remuneration of staff in different activity areas where a conflict might arise.
- Influence Controls: Measures to prevent any person from exercising inappropriate influence over how staff carry out investment services.
Disclosure
If our internal arrangements are not sufficient to ensure, with reasonable confidence, that the risk of damage to your interest will be prevented, IML will provide a formal disclosure to you. This disclosure will be made in a durable medium (such as email or paper) before business is undertaken, providing enough detail for you to make an informed decision regarding the service.