Conflicts of Interest Policy Summary Conflicts Disclosure
InterestMe Financial Planning Limited is authorised and regulated by the Financial Conduct Authority (number 542680). Lloyds Avenue House, 6 Lloyds Avenue, London, EC3N 3AX. Registration Number: 07310886. Registered in England and Wales.
The Financial Conduct Authority (FCA) requires InterestMe Financial Planning to have in place appropriate systems and controls to prevent conflicts of interest from constituting or giving rise to a material risk of damage to the interests of its clients. In accordance with such requirements, we have taken reasonable steps to identify conflicts of interest that exist, or may exist, between InterestMe Financial Planning and its clients or between one client and another. We have further reviewed the organisational and administrative arrangements that are in place to manage such conflicts and believe they are sufficient to ensure, with reasonable confidence, that risk of damage to clients' interests will be prevented.
Our Conflicts of Interest Policy sets out the key information that is required by clients to understand the measures taken by InterestMe Financial Planning to safeguard the interests of its clients. All InterestMe Financial Planning entities and employees, consultants and contractors of any sort, (collectively “Staff�) are required to apply this Policy and seek advice as and when required. This Policy is a supplement to InterestMe's overall general obligation to act with integrity and fairness, both towards its clients and its counterparties.
Principle 8 of the FCA Principles for Businesses requires a firm to “manage conflicts of interest fairly, both between itself and its clients and between a client and another client�. Under the Markets in Financial Instruments Directive (MiFID), investment firms are required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage such conflicts of interest.
InterestMe Financial Planning provides a range of services to a number of different clients. As a result, circumstances may arise whereby the interests of the client may conflict with the interests of InterestMe Financial Planning, an employee or some other person connected with us, or with those of another client. A conflict of interest may arise even if no improper act or disadvantage to the client arises from it. It is of vital importance that any risk of a conflict of interest is identified and managed appropriately, both to comply with FCA rules and our wider duties to clients, and also to ensure that the integrity of our services is not eroded.
Our conflict of interest policy is deeply ingrained in our policies and procedures; we are committed to treating our clients fairly and we will never knowingly put ourselves in a position whereby our own interests, or our duty to another party, prevent us from discharging our duty to our clients.
InterestMe Financial Planning maintains processes, procedures and organisational arrangements to manage possible conflicts of interest, which include that all InterestMe Financial Planning Staff:
- are at all times, bound to act in full compliance with its policies and procedures;
- are bound by the ‘Gift and Hospitality Policy’ which prevents them from soliciting or accepting any gift or inducement which may influence their independence or create a conflict with the duty owed to InterestMe Financial Planning or its clients;
- are bound by our Data Security Policy, and access to confidential information is only permitted if essential for performing their job function;
- receive guidance and instructions regarding managing conflicts of interest;
- are bound by the Personal Account Dealing Policy and transactions undertaken by all employees are actively monitored;
- are required to seek prior consent by senior management before engaging in other external business interests.
Details of explicit conflicts of interest will be fully disclosed to all clients within our client/fee agreement documentation and suitability reports. Details of conflicts of interest are also available upon request.
If the measures in place are not sufficient to avoid or manage a conflict of interest relating to a client, InterestMe Financial Planning will disclose the conflict of interest before undertaking further business with the client.
InterestMe Financial Planning is therefore committed to identifying, monitoring and managing all actual and potential conflicts of interest that may arise in relation to its business.