CONFLICT OF INTEREST POLICY
1. WHAT IS A CONFLICT?
A conflict of interest is a situation in which the G-Force Capital or employee finds itself in a position where its own interests conflict with the duty owed to its clients or a situation in which duty to one client conflicts with duty to another.
The mismanagement of conflicts can present risks to G-Force Capital, its employees, clients and other market participants, and for this reason the avoidance or proper management of conflicts is critical to the fair and effective operation of financial markets.
This Conflicts of Interest Policy assists G-Force Capital in the effective identification, prevention and management of conflicts of interest and aims:
a. To identify the specific services and activities carried out by G-Force Capital, and circumstances which can adversely affect the interest of one or more clients.
b. To specify procedures to be followed and measures to be adopted to prevent and manage any conflicts.
c. To communicate this information to all those who are part of G-Force Capital.
We aim to achieve highest standards of ethical and market practice in respect of the management of conflicts of interest and to act at all times in the best interests of our clients.
2. IDENTIFICATION OF CONFLICTS
For the purposes of identifying and preventing the types of conflict and potential conflicts that can adversely affect the interest of a client, we must consider whether the firm or a relevant person, or a person directly or indirectly linked by control to the firm:
a. Is likely to make a financial gain, or avoid a financial loss, at the expense of the client
b. Has an interest in the outcome of a service provided to the client or transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome
c. Has an incentive to favour the interest of another client or group of clients over the interests of the client
d. Carries on the same business as the client
e. Receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monetary or non- monetary benefits.
3. MANAGEMENT OF CONFLICTS
All G-Force Capital employees have a responsibility to consider any potential or actual conflicts of interest during day-to-day business activities or ad-hoc project work and disclose such conflicts to the Compliance function.
The Compliance function will consider whether it can manage the conflict with appropriate mitigating controls. If the conflict is assessed to be unmanageable, the employee may be asked to remove himself from the conflict position. We must not knowingly advise in relation to a transaction unless we take reasonable steps to ensure fair treatment for the client. This is normally achieved by managing the conflict of interest by taking reasonable steps in one or more of the following ways:
a. Managing the conflicts internally
b. Establishing special arrangements such as a Chinese wall
c. Disclosing our interest to the client
d. Declining to act for a client
e. The conflicts disclosed to Compliance are recorded in the Conflict of Interest Register
The Register is reviewed periodically by Compliance and at least quarterly by the Management team and Directors.
The Conflict of Interest Register is as follows:
Possible or Identified Conflict
Process and Procedure for Dealing with Conflict
G-Force Capital may be able to demonstrate that it has taken reasonable steps to ensure fair treatment for its clients by relying on our Conflicts of Interest policy. In such cases, relevant employees are required to disregard any material conflict of interest when advising a client.
4. DISCLOSING AN INTEREST
If arrangements made by G-Force Capital to manage conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of a client will be prevented, G-Force Capital will clearly disclose the general nature and/or sources of conflicts of interest to the client before undertaking business for the client.
The disclosure will be:
a. Be made in a durable medium.
b. Include sufficient detail to enable that client to take an informed decision with respect to the service in the context of which the conflict of interest arises.
Disclosing an interest to a client would normally be required where the firm has an interest in a transaction on which it is advising or where the firm derives, or will derive, consultancy, non-executive director or other fees from clients involved in a transaction. Disclosure of a material interest or conflict of interest to a client can be made in writing or orally, on a recorded line.
Disclosure must be made before we advise our client on a transaction, and we must be able to demonstrate that we have taken reasonable steps to ensure that the client does not object to our material interest or conflict of interest.
5. DECLINING TO ACT
If G-Force Capital determines that it is unable to manage a conflict of interest using one of the methods described above, we will decline to act on behalf of the relevant client.
6. EDUCATION AND AWARENESS
All employees receive periodic training in respect of conflicts of interest and the specific and potential conflicts to which we are subject.