Identification and Management of Conflicts of Interests Policy

Identification and Management of Conflicts of Interests Policy

Company has adopted the Identification and Management of Conflicts of Interests Policy (the “policy”) to address actions or transactions at the Company that may give rise to actual or potential conflicts of interest (“Conflicts”) and to set forth the processes by which the Company will identify and manage Conflicts going forward. This policy aims to uphold Company’s reputation for integrity and fair dealing, meet regulatory expectations and maintain the trust and confidence of our clients.
This policy is only one part of the Company’s ongoing commitment to adhere to the highest standards of ethical conduct in relation to Conflict management. As employees of the Company, you should also be aware of other relevant policies and processes that address conflicts of interest, both at the Company level, Regional and Local level (e.g. Outside Interests; Information Barriers; Gifts and Entertainment).
This policy also provides for a mechanism to ensure that Conflicts-related issues are reviewed periodically. This policy is not meant to replace, but to supplement existing Conflicts-related policies and processes.

CONTENT

1. OVERVIEW
1.1 PROCEDURE OWNER
1.2 CLASSIFICATION
1.3 APPLICABLE REGULATIONS
1.4 RELATED [COMPANY] NORMS AND PROCEDURES
1.5 OBJECTIVES
1.6 AUDIENCE AND SCOPE
1.7 DOCUMENT SUPPORT
2. DEFINITIONS & ABBREVIATIONS
3. POLICY
4. RATIONALE
5. IDENTIFICATION OF CONFLICTS
6. STRATEGIES FOR MANAGING CONFLICTS
7. GLOBAL CONFLICTS REVIEW PROCESS
8. EXCEPTIONS
9. FINAL CONSIDERATIONS
9.1 DISCIPLINARY ACTIONS AGAINST PROCEDURE VIOLATION
9.2 DOCUMENT REVISION
10. APPENDIX A – CONFLICTS CHECKLIST

Pages: 12

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