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French to English: Conflict of interest management policy

French source text


English translation
As required by law, XYZ has a conflict of interest management policy and makes every effort to identify conflicts of interests that may arise in the course of providing investment or related services or UCITS management.

As a result of the identification of conflicts of interests, a mapping of conflicts of interests was prepared. This mapping identifies those circumstances that give rise or may give rise to a conflict of interest.

It makes it possible to identify and, if necessary, fairly manage any conflicts of interest that may arise in the course of carrying out its services, between its own interests and those of its clients, or between the interests of a number of clients.

This notably involves identifying and scrutinising:

- the participation of an employee in one or more investment services offered by the management company;
- the separation of activities that may lead to potential conflicts (such as proprietary activities and those on behalf of third parties);
- the circulation of confidential or privileged information within the management company;
- corporate offices held by employees of the management company on a personal basis or as part of their professional activities;
- commission paid or received in connection with services or activities performed by or on behalf of the management company;
- the method by which employees are remunerated in connection with the distribution of financial products;
- benefits or gifts that employees of the management company may receive in connection with their professional activity;
- potential conflicts of interest relating to the procedure for selecting intermediaries and service providers;
- the introduction of an incident management procedure designed to protect the primacy of the client’s interests;
- the introduction of a procedure for personal transactions;
- the introduction of a procedure for giving gifts to and/or receiving gifts from clients and service providers.

 
     
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