This policy may be reviewed and amended at any time. This document is not intended to create third party rights or duties or form part of any contractual agreement between the firm and any client.
General Statement of Policy
YLDFX, or any party to whom it may have delegated its functions (a “delegate”), may without priorreference to a client, effect transactions in which the firm or a delegate has, directly or indirectly, amaterial interest or a relationship which may involve a potential conflict with the firm’s duty to theclient. In the event of any such transaction, however, the firm will ensure that:
- Such transactions are effected on normal commercial terms negotiated at arm’s length andon terms which are not materially less favourable to the client than if the potential conflict had not existed;
- Such transactions do not adversely affect the performance of the firm’s duties andresponsibilities to the client; and
- We take reasonable steps to ensure fair treatment for the client.
Identification of Conflicts of Interest
We have sought to identify and assess the materiality of conflicts of interest that may arise in the course of providing financial services.
These include circumstances in which there is:
- a conflict between the interests of the firm, an individual member of staff, certain persons directly or indirectly connected to the firm or a delegate; and the duty that the firm owes to a client; or
- a conflict between the differing interests of two or more clients, as the firm owes a separate duty to each of them.
Record Conflicts of Interest
YLDFX maintains a register of those identified conflicts of interest and the controls deployed to mitigate the potential risks arising.
This register is reviewed periodically and the controls are tested to ensure we are effectively managing those conflicts.
Inducements and gifts
YLDFX maintains a general policy on the giving and receiving of gifts and entertainment.
We do not prohibit our staff from receiving small gifts and minor hospitality from other parties. However, no employee or director may accept from, or give to, any person any gift or other benefit that cannot properly be regarded as justifiable in all the circumstances. Employees may not accept gifts from, or provide gifts to, an individual or firm with whom they conduct, or intend to conduct, business on behalf of the firm unless it can be demonstrated that no conflict of interest (actual or perceived) is created by doing so.