Summary of Conflicts of Interest Policy

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					Summary of Conflicts of Interest Policy
1 Introduction                                    f) Internaxx employees pursuing activities        4.8 Gifts
                                                     outside Internaxx or maintaining personal
Under the Markets in Financial Instruments           relationships potentially detrimental to the   Internaxx employees will not accept any gifts
Directive (‘MiFID’), Internaxx is required to        client;                                        other than those considered normal in their
maintain and operate effective organizational                                                       line of business. Excessive gifts from clients
and administrative arrangements with a view       g) personal relationships between Internaxx       may result in a conflict of interest, something
to taking all reasonable steps to identify,          employees and clients and additional           we are committed to avoiding.
monitor and manage conflicts of interest.            activities of Internaxx employees outside
Internaxx has put in place a policy to               Internaxx that could give rise to a conflict   4.9 Disclosure
safeguard its clients’ interests. The key            of interest.                                   Where there is no other way of managing a
information is summarized below. Detailed                                                           conflict, or where the measures in place do
information is obtainable on request.                                                               not sufficiently protect your interests as a
                                                  4 Our measures                                    client, the conflict will be disclosed to allow
                                                                                                    you to make an informed decision on whether
2 Our Conflicts of Interest Policy                The measures we have adopted to manage            to continue using our service in the situation
                                                  identified conflicts are summarized below.        concerned.
Internaxx is a bank, established and regulated    We consider them appropriate to our efforts
in Luxembourg offering investment services        to take reasonable care that, in relation to      4.10 Declining to act
to investors. Like any bank Internaxx is          each identified potential conflict of interest;
potentially exposed to conflicts of interest      we act impartially to avoid a material risk of    We may decline to act for a client in cases
in relation to its activities. However, the       harming your interests.                           where we believe the conflict of interest
protection of our clients’ interests is our                                                         cannot be managed in any other way.
number one concern and so our Policy sets         4.1 Policies and procedures
out how:                                          We have adopted many policies and proce-
a) we will identify circumstances which may       dures throughout our business to manage
   give rise to conflicts of interest entailing   potential conflicts of interests. Our employ-
   a material risk of damage to our clients’      ees receive guidance and training in these
   interests;                                     policies and procedures, and they are subject
                                                  to monitoring and review processes.
b) we have established appropriate mecha-
   nisms and systems to manage those              4.2 Information barriers
   conflicts; and                                 Our employees respect the confidential-
c) we will maintain systems in an effort to       ity of client information and do not disclose
   prevent damage to our clients’ interests       it or use it inappropriately. For particularly
   through identified conflicts.                  sensitive cases, we have established Chinese
                                                  walls and adopted Chinese wall procedures
                                                  to prevent unauthorized exchange of informa-
                                                  tion between employees and to organize the
3 Conflicts of interest                           separation of staff members concerned.
‘Conflicts of interest’ are impossible to rule    4.3 Separate supervision/functions
                                                  Two departments or businesses which, if run
Our policy defines conflicts of interest as:      together, could encounter conflicts of inter-
a) first, conflicts of interest between           est will be managed by different senior staff
   Internaxx and you. For instance, if we         members.
   are providing a service to you and,            4.4 Pay
   beyond that, we have a material interest,
   relationship or arrangement in the trans-      Pay and bonuses are linked to the profits
   action or product or service; the decisive     of Internaxx or the business or department
   factor is whether we make a profit or avoid    where an employee works. Pay and bonuses
   a loss to your disadvantage; or                linked to the performance of another depart-
                                                  ment, with possible conflicting interests, will
b) second, conflicts of interest between our      be avoided at all times.
   clients if we are acting for you and for
   another client and your two interests          4.5 Inducements
   conflict materially.
                                                  Inducements from third parties in relation to
We have identified such conflicts of interest     a service provided to you are acceptable to
in our business.                                  Internaxx only if (1) the inducement is dis-
                                                  closed to you and (2) it is either the payment
These could include:                              of a normal fee or commission to continue the
a) providing services in different capaci-        quality of our services to you and does not
   ties at the same time, e.g. credit services    impair our duty to act in your best interests.
   and services for the issue of financial        4.6 Personal account dealing
                                                  To prevent conflicts arising from the use of
b) selling Internaxx products to you;             information obtained from clients, and market
c) trading or dealing in financial instruments    abuse in general, all employees are subject to
   which we transact for you;                     personal account dealing rules.

d) holding confidential information on other      4.7 Employees’ activities outside
   clients which, if we can disclose or use,          Internaxx
   would affect the services provided to you;     Our employees are subject to rules designed
e) accepting gifts or entertainment that could    to avoid conflicts of interest with activities
   be construed as conflicting with our duties    they undertake outside Internaxx.
   to our clients;
                                              2007/11 (1) COI v.1 EN
             & (+352) 2603 2003
46a, avenue J.-F. Kennedy L-2958 Luxembourg

      Internaxx Bank S.A. R.C. B78729

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