HC-2.4 HC-2.4 Disclosure of Conflicts of Interest
HC-2.4.1
Each
approved person oflicensees must inform the entire Board of conflicts of interest as they arise. Board members must abstain from voting on the matter in accordance with the relevant provisions of the Commercial Companies Law 2001, as amended. This disclosure must include all material facts in the case of a contract or transaction involving theapproved person . Theapproved persons must understand that any approval of a conflict transaction is effective only if all material facts are known to the authorising persons and the conflicted person did not participate in the decision.October 2019HC-2.4.2
Board members must declare annually in writing all of their interests (and those of their
family ) in other enterprises or activities (whether as aDirector ,shareholder , senior executive or other form of participation) to the Board (or appropriate Board sub-Committee).October 2019HC-2.4.3
The Board should establish formal procedures for:
(a) Periodic disclosure and updating of information by eachapproved person on his actual and potential conflicts of interest; and(b) Advance approval by directors or shareholders who do not have an interest in the transactions in which a card processing services', credit reference bureaus', and payment service providers'approved person has a personal interest. The Board should require such advance approval in every case.October 2019