Summary of Conflicts
1) Scope and definition
The present document summarizes the measures taken by the Company to prevent, manage and resolve any conflicts of interest that may arise in relation to the Company's duties to the Client. For the purposes of this Summary, a conflict is defined as a situation in which the interest of a Client or potential Client contradicts the interest of the Company (including its employees, affiliates, agents, assigns, successors, managers, and service providers, as well as any person or entity directly or indirectly controlled by the Company) and/or other Clients, resulting in a risk of harm to the interests of any of the parties. All the employees of the Company are required to comply with the policy set out in the present document.
2) Policy of disclosure
The Company maintains a list of activities and services that can result in a conflict of interest and follows a set of policies aimed at preventing, managing and resolving such conflicts and preventing that the Client's interests may be harmed. In those cases where our conflict prevention and management policies prove insufficient to prevent the risk of damage to the Client's interests, the Company will make all reasonable effort to inform the Client about the possible conflict, the risks that it entails, and the measures that the Company intends to take to prevent the Client's interests from being harmed, to allow the Client to make an informed decision.
3) The conflict management procedures
The Company's procedures aimed at preventing and managing conflicts include, but are not limited to: - Ensuring that only those employees who strictly require to have access to the Client's personal and trading information can access it; - Segregating employees' duties and responsibilities; - Monitoring any gifts offered to or by the employees and preventing them from offering or accepting any gifts that may be deemed excessive or otherwise violate the Company's internal policies; - Separating staff involved in different activities, either physically or through information barriers; - Ensuring compliance with any applicable legislation regarding conflicts of interest.