Itaú Unibanco has clearly defined conflict of interest policies and procedures, which have been designed to identify and properly disclose, mitigate, and/or eliminate applicable conflicts of interest. However, written policies and procedures cannot address every potential conflict, so employees must use proper judgment in identifying and responding appropriately to actual or potential conflicts.
Conflicts of interest that involve Itaú on one hand and clients on the other hand, will generally be fully disclosed and/or resolved in a way that favours the interests of the clients. In some instances conflict of interests may arise between two or more clients. Responding appropriately to these types of conflicts can be challenging, and may require robust disclosures if there is any appearance that one or more clients have been unfairly disadvantaged. Employees must notify the relevant compliance officer promptly if it appears that any actual or potential conflict of interest exists and has not been appropriately addressed. The compliance officer will document the firm’s assessment of, and response to, such conflicts.