In our conflicts of interest policy we register and focus the improvement process on:
- Identifying conflicts of interests
To control possible conflicts of interests we need to properly identify areas where conflicts of interests can arise.
- Measures concerning transparancy, control and monitoring
When there is a potential conflict of interest identified we analyse the possible consequences of this conflict. Besides we take proper measures to control and monitor this conflict.
- Information and communication
If we can´t avoid negative consequences (like missed opportunities) we communicate this with clients. This way they re-evaluate decisions concerning a certain transaction.
- Rules and procedures
We developed policy rules, procedures and measures to avoid unwanted incentives for employees to enter an area where there could be conflicts of interests.
Examples are: insider/ risktaker rules, a behavioural code on how to deal with sensitive information and signing an oath in which the employee promises to act carefully and with entegritiy his/ her role.