Conflict of Interests
The following examples illustrate potential conflicts of interest that may arise in the course of the Company's operations. These examples serve as a non-exhaustive reference to assist Employees, Clients, and third parties in identifying and mitigating risks associated with conflicts of interest.
Example 1
A Conflict of Interest may arise between the Company and a Client when the Company is responsible for allocating a product, service, or securities. The Company may have an incentive to allocate or price transactions in a manner that is favorable to itself or certain investor Clients (for example, in exchange for promises of reciprocal business). Such conduct may result in a disadvantage to the Company’s issuer/seller Clients or other investor Clients.
Example 2
A Conflict of Interest may arise between the Company, an Employee, and a Client if an Employee engages in cross-selling activities or offers multiple services/products to a Client with the primary objective of generating higher fees or revenue for the Company, rather than ensuring that such services/products are in the Client’s best interests.
Example 3
A Conflict of Interest may arise where the Company or its Employees possess confidential or inside information concerning a Client while another Client or Employee has a competing interest in utilizing such information. The use of such information in a manner that benefits one party to the detriment of another may constitute a breach of the Company’s obligations and could adversely affect affected Clients or other stakeholders.
Example 4
A Conflict of Interest may arise where an Employee engages in business dealings with individuals who are Family Members or with whom they have Close Personal Relationships. Such transactions may compromise or create the appearance of compromising the Employee’s objectivity, impartiality, or ability to act in the best interests of the Company and its Clients. Furthermore, these dealings may give rise to reputational risks for the Company, including concerns regarding favoritism, undue influence, or improper advantages.
Example 5
A Conflict of Interest may arise between the Company, an Employee, a Client, and/or a third party when fees, commissions, or other monetary and non-monetary benefits are given or received in a manner that may improperly influence the decision-making process. Such conduct could lead to biased actions, unfair treatment, or unethical commercial practices, ultimately creating a disadvantage for the Company or its Clients.
These examples are illustrative and do not constitute an exhaustive list of conflicts of interest that may arise. Employees, Clients, and third parties are encouraged to remain vigilant and adhere to the Company's internal policies and ethical standards to prevent, identify, and mitigate any potential conflicts of interest.
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