Currently, should conflicts of interest arise, discussions can take place within the front office, between the front office and the risk department or in the Investment Committee (IC). The case is discussed in order to seek an outcome. These range from not proceeding with the transaction, requesting additional information to clarify issues or placing additional requirements to manage the E&S risk. In every case, the transaction is evaluated critically against FMO's financing criteria.
In case FMO is envisaging providing debt and equity to a client, the conflicts of interest are mitigated by having separated legal counsels who will provide assistance and advice on debt and equity in the same transaction. An information barrier will be implemented between those legal counsels for that specific transaction. Separate Clients files and authorizations are also setup to create information barrier.
Information barriers exist between Front Office teams (Debt and Equity). Additionally, we have conflicts of Interest Policies in place.