Conflicts of interest policy – General
Under FCA’s Principles for Businesses, Principle 8 requires a firm to “manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.” Under the Markets in Financial Instruments Directive (“MIFID”), Smart Insider Limited (“Smart Insider”) is required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage such conflicts of interest. Smart Insider has put in place a policy to meet this obligation and set out below is a summary of that policy and the key information that is needed by clients and counterparties (together “customers”) to understand the measures Smart Insider is taking to safeguard the interests of its customers.
Smart Insider seeks to:
- identify circumstances which may give rise to conflicts of interest entailing a material risk of damage to customers’ interests;
- establish appropriate mechanisms and systems to manage those conflicts; and
- maintain systems in an effort to prevent actual damage to customers’ interests through the identified conflicts.
What is Conflict Of Interest?