Test
The objective of this policy is to provide guidance around managing conflicts of interests under the Companies Act 2006 and the FCA/PRA High Level Standards - Senior Management Arrangements, Systems & Controls (SYSC). It covers what is a conflict of interest, when a conflict of interest may arise, the types of conflicts which may arise, policy on managing conflicts of interest, the actions that an individual should take if there is a conflict and regulatory requirements.
Foreign Currency Innovations Limited (FCI) is authorised and regulated by the Financial Conduct Authority (with firm reference number 616985)
Foreign Currency Innovations Limited (FCI) is involved in dealing, managing, and arranging on investments and as such may have a material interest in the services or transactions it carries out with or on behalf of its clients. The Company utilises this Conflicts of Interest Policy to outline the arrangements we have in place to manage conflicts of interest that may arise when we provide services or execute transactions for our clients.
Every employee of FCI, regardless of their title and position in the company, receives the present policy for their review and awareness and is obliged to fully implement and observe the following conflicts of interest procedures during the term of her/his contract with FCI.
The information given below is a summary only.
FCI has a fiduciary duty to act in the best interests of its clients. FCA Principle 8 requires us to manage conflicts of interest fairly, both between itself and its customers and between a customer and another client. SYSC 10.1 requires the Company to take all reasonable steps to identify conflicts of interest between:
Accordingly, our Conflicts of Interest Policy is designed to identify, assess, manage and if appropriate, disclose all potential and actual conflicts of interest in our business.
Types of Conflict of interest that might occur
A
Conflicts of interest relating to Clients can be broadly described as scenarios where FCI (the firm), an Employee or a Third Party Representative:
Conflicts of interest relating to the firm can be broadly described as scenarios where:
Managing Conflicts
Governance
FCI has robust governance arrangements. Key business decisions are taken by the board. This Policy will be reviewed annually by the Board.
Management information relevant to identifying conflicts is reviewed by the Board (including risk reports and monitoring of accounts and position statements).
Reporting Lines
FCI has defined and clear reporting lines. An organisational chart is maintained.
The Company also has external compliance consultants (MPAC Group) to advise on our compliance programme, to undertake independent monitoring of our regulatory obligations, including management of conflicts of interest. All directors and staff must report conflicts of interest situations or potential conflicts of interest situations immediately by email to FCI’s Compliance Officer.
Segregation of Functions
The Company has structured its senior management to appropriately segregate duties so as to avoid conflicts of interest wherever possible.
Remuneration/Compensation Arrangements
FCI interests and the staff interests are aligned with those of the Company’s clients, included by way of remuneration.
Disclosure of Personal Conflicts
Staff are required to disclose actual or perceived conflicts of interest upon commencement of employment or admission to the Company and thereafter on an ongoing basis in declarations to the Company. Staff and Directors will disclose any conflicts of interest directly to the board. Upon receiving any material disclosure, the Board will note it. All directors and staff must report conflicts of interest situations or potential conflicts of interest situations immediately by email to FCI’s Compliance Officer.
Disclosure to Clients
FCI discloses to its clients all material conflicts in sufficient detail so as to allow the client to take an informed decision in relation to the service offered.
If our arrangements to manage a conflict of interest are not sufficient to ensure with reasonable confidence that the risk of damage to that client’s interests is prevented, we will inform the client in writing.
Job Descriptions and staff assessment
Employment duties are designed to limit the potential for conflicts of interest and all FCI’s staff are issued with job descriptions to help prevent an officer from exercising inappropriate influence over the way any other officer or group of officers carries out services or activities. All employees are regularly assessed for competency in their roles and are required to follow the internal procedures detailed in FCI’s Compliance Manual.
Policies & Procedures
Systems and controls are documented in the Compliance Manual, which are reviewed by the Board at least annually to ensure they are fit for purpose.
Record of Conflicts of Interest
FCI maintains an up to date Register of Conflicts of Interest in which to record any identified conflicts of interest that have arisen, or which may arise, leading to a material risk of damage to the interest of one or more clients, resulting from services or activities carried out by or on behalf of FCI.
Training
FCI provide training to staff on conflicts of interest, and FCI’s policies and procedures for preventing them.
Chinese walls
Wherever necessary FCI establishes and maintains a ‘Chinese wall’ in order to create a barrier so that information held by one part of the business is withheld from, and cannot used by, persons in another part of the business, the operation and effective of which are overseen and monitored by the Compliance Officer and senior management.
Personal account dealing
All FCI’s staff are bound by the requirements of FCI’s Personal Account Dealing rules which have been established to ensure that personal account dealing by members of staff comply with the FCA rules. Under the Personal Account Dealing rules staff can only undertake personal investment activities with first prior written general permission to do so, and which then:
FCI Markets is a trading name of Foreign Currency Innovations Limited and is regulated by the Financial Conduct Authority under FCA Register number: 616985. Foreign Currency Innovations Ltd, a company registered in England under company number 7274218. enquiries@fci-markets.co.uk
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