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  • Conflicts of Interest

    • C4-3.1.4

      Category 4 investment firms must take all reasonable steps to identify conflicts of interest between themselves (or any person directly or indirectly linked to them by control) and their clients, which may arise in the course of providing a regulated investment service. Any such conflict of interest must be disclosed to the client and take reasonable steps to obtain the client’s no objection.

      Added: January 2022

    • C4-3.1.5

      Category 4 investment firms must establish policies and procedures to manage conflicts to interest, including where appropriate information barriers, Chinese walls etc. If the licensee is unable to manage a conflict of interest it must decline to act for the client. The policies must also cover an employee’s personal account transactions.

      Added: January 2022

    • C4-3.1.6

      Category 4 investment firms must establish controls, policies and procedures to ensure that neither they, nor any of their employees, offer, give, solicit or accept any inducement which is likely to conflict significantly with any duty that they owe to their clients.

      Added: January 2022