We endeavour to maintain a record of the types of activity we carry on in which a material conflict could arise or has arisen, including the activities of other members of our group of companies.
We also maintain procedures to manage actual or potential conflicts. This includes procedures to maintain appropriate independence between members of our staff who are involved in different activities, for example, through the operation of information barriers, physical separation of staff, the segregation of duties and responsibilities and maintenance of a policy of independence which requires our staff, when providing services to a client, to act in the best interests of the client and to disregard any conflicts of interest; and, in some circumstances declining to act for a client or potential client.
Where our arrangements to manage conflicts are not or cannot be sufficient to be reasonably confident that risks of damage to a client’s interest will be prevented we aim to disclose the general nature and/or sources of conflicts before carrying on business for the client. This is to allow the client to consider whether to ask for more information and whether to continue with the service. We do not aim to provide detailed, highly specific or comprehensive information.