There is a reasonable expectation that a Conflict of Interest might arise in financial institutions with a diverse range of activities, including those trading as Principal with their clients. Make Capital Ltd seeks to manage conflicts of interest fairly at all times. In this context a Conflict of Interest is a situation which may result in a decision being made which may not be in the best interests of clients.
Under such general principles, we and our employees should not directly or indirectly:
- make any financial gain, or avoid any financial loss, at the expense of any client;
- have an interest in the outcome of a service provided to a client, or a transaction carried out on a client’s behalf, which is distinct from the client’s interest in that outcome;
- have a financial or other incentive to favour the interests of one client or group of clients over the interests of another client or group of clients;
- receive from any person an inducement in relation to a service provided to a client in the form of monies, goods or services, other than the standard commission or fee paid by the client for that service.
Where other instances arise which might give rise to a conflict of interest, we follow the general principles and policies that govern our business.
Our staff are trained to be aware of the risk of Conflicts of Interest and to report where any such actual or potential conflicts are identified. Our management team regularly monitors our activities including analysing client dealing and our positions in markets at the time of client trade execution.
Managing Conflicts of Interest
Where we identify an actual or potential conflict of interest, we may take the following steps:
- decline to act where there is a potential conflict or cease engaging in the activity leading to the conflict;
- accept the conflict of interest but take steps to protect your interests.
Some conflicts of interest cannot be satisfactorily managed either by declining to act or protecting your interests. In such cases, we will disclose appropriate and proportionate information to you or, as needed, obtain your consent to act.