When identifying, preventing and managing conflicts of interests, the following aspects are generally acknowledged:
- The primary goal is to identify the relationships, services, activities or transactions in which conflicts of interests may arise and prevent them from arising;
- If a conflict of interests situation has arisen or seems likely to arise, the situation should be actively handled, and where relevant, it should be considered if the conflict of interests should be disclosed to the Client(s) involved;
- The relevant persons’ awareness of actual and potential conflicts of interests and the procedures to handle them should be highlighted.
In each identified situation, as listed above:
- The Chief Compliance Officer monitors the conflict of interest policy and procedures for administrative and operational activities of the Group;
- The Chief Compliance Officer and the Management propose appropriate measures when an Employee is involved;
- The Audit Committee and the Management take appropriate measures subsequently when a Director or the Management is involved;
- The Audit Committee and the Management ensure that all new activities and products are analysed in order to detect potential conflicts of interest.