Conflict of Interest Policy
This policy, adopted by AGEA International AD (hereinafter referred to as "AGEA", "the Company") to identify and manage conflicts of interest, applies to all AGEA's employees, including managers and directors, and to any person directly or indirectly linked to the Company (hereinafter called "related persons").
The main conflicts of interests which may arise in the conduct of AGEA's business are the potential conflicts of interest between the Company and its customers or between one customer and another.
AGEA takes responsibility to identify and prevent conflicts of interests and adopts all the following measures to achieve this:
Effective procedures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients;
The separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company;
The removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities;
Measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities;
Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of conflicts of interest. Such measures include the following:
A "need to know" policy governing the dissemination of confidential or inside information within the Company.
Chinese walls restricting the flow of confidential and inside information within our company, and physical separation of departments.
Procedures governing access to electronic data.
Segregation of duties that may give rise to conflicts of interest if carried on by the same individual.
Personal account dealing requirements applicable to relevant persons in relation to their own investments.
A gifts and inducements log registering the solicitation, offer or receipt of certain benefits.
The prohibition of external business interests conflicting with our interests as far as the Company's officers and employees are concerned, unless board approval is provided.
A policy designed to limit the conflict of interest arising from the giving and receiving of inducements.
Establishment of in-house Compliance Department to monitor and report on the above to the Company's Board of Directors.
Appointment of Internal auditor to ensure that appropriate systems and controls are maintained and report to the Company's Board of Directors.
Establishment of the four-eyes principle in supervising the Company's activities.
The Company also undertakes ongoing monitoring of business activities to ensure that internal controls are appropriate;
The Company has an in-house Compliance Department that is responsible for identifying and managing potential conflicts of interests. The above will also update the relevant internal procedures and ensure compliance with such procedure.
Where a conflict arises and the Company is aware of it, it will disclose the conflict to the client prior to undertaking investment business for that client or, if it does not believe that disclosure is appropriate to manage the conflict, we may choose not to proceed with the transaction or matter giving rise to the conflict.
The Company reserves the right to review and / or amend its Policy and arrangements whenever it deems this appropriate.