Conflicts Of Interest Policy
Under the FCA’s Principles for Businesses, Principle 8 states
that a firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client
Cube deals with retail clients and acts as a Receiver and Transmitter of orders in relation to financial instruments such as shares, derivatives, bonds and units.
Cube maintains and operates effective organisational and business arrangements taking all reasonable steps to identify, monitor and manage conflicts of interest. At Cube, we expect our business activities to be conducted honestly and with integrity. This policy comprises a list of criteria which help to identify the potential conflicts of interest which exist for Cube.
This policy does not create any third party rights or duties and does not form part of any contract between Cube and other party.
Identifying the Conflicts
A conflict of interest may arise where a company, or one of its employees, is providing a financial service to its customers and may entail a material risk of damage to those customers interests. When identifying the types of conflict of interest which may arise, we taken into account whether Cube or an employee:
- Is likely to make a profit or avoid a loss at the expense of a client;
- Has an interest in the outcome of a service to the client;
- Has a financial or other incentive to favour the interest of another client;
- Could be in a position where its ability to act in a client’s best interests is potentially affected by another matter.
Methods of Managing Conflicts
Cube actively manages such conflicts of interest in order to minimise any material risk of damage to its clients and deals with conflicts fairly.
Management of these risks is achieved by one or more of the following:
- Ethical Walls – where information held by a person in one part of the business is withheld from them, or not to be used for people in another part of the business;
- Removal of direct remuneration links for employees;
- Promoting a culture of integrity;
- Best Execution – our policies for acting in clients’ best interests when passing orders to third parties for execution are designed to ensure that we meet our best execution obligations.
- Gifts / Hospitality and Inducements – are all issues that could lead to potential conflicts of interest. Employees of Cube must not solicit or accept any inducements which may conflict with our obligations to clients. Employees will not accept any gifts other than those considered normal in their line of business. Excessive gifts may result in a conflict of interest, something that Cube are committed to avoiding. We keep a register of all gifts worth over £50 and a Director is required to give sign off.
Cube has a clear policy on Conflicts of Interest:
- Conflicts of Interest should always be avoided, wherever possible.
- Conflicts or potential Conflicts of Interest must always be disclosed by employees to Cube.
In the unlikely event that Cube is unable to manage or avoid a conflict of interest; we will disclose the conflict prior to conducting further business with the relevant clients.