A conflict of interest is defined as any circumstance that creates a risk that the professional judgement, decisions or actions of employees with regard to a primary interest (e.g. customer interest) will be unduly influenced by a secondary interest (e.g. interest of CSS, interest of employees, etc.). The following measures are in place: Measures to avoid and manage conflicts of interest
a. Identification and monitoring
The EMF or its employees are obliged to identify potential conflicts of interest arising in the course of their activities or the provision of their services at the earliest possible opportunity. In this context, all activities and services shall be continuously monitored to determine whether any potential conflicts of interest may arise in the course of their performance. To this end, the sources of conflicts of interest must be identified and precautions, i.e. suitable and appropriate procedures or effective organisational and personnel measures, taken to prevent, control, avoid or manage them. This may also include physical and electronic information barriers. Any unavoidable conflicts of interest must be disclosed to the clients concerned. Identified conflicts of interest must be reported immediately to management.
b. Handling conflicts of interest
Identified conflicts of interest are to be dealt with if a client experiences an impairment or threat of disadvantage as a result. However, the existence of a conflict of interest should not be automatically concluded on the basis of a profit, an advantage or the avoidance of a disadvantage (for CSSP). The management of conflicts of interest is supervised by the management.
In order to avoid that our services for our customers and investors are influenced by interests that are not related to the subject, CSSP has structured the structural and procedural organisation and made a separation of functions. Active sales is completely separated from strategy (e.g. coordination with the various fund stakeholders such as fund managers, asset managers, custodians, etc.) and reporting. The tasks are allocated accordingly and the work contents are comprehensibly recorded.