Many conflicts of interest are blatant and distasteful, but potential conflicts exist all around us in everyday life. For example; we want to you to buy independent financial advice from us, therefore a notional conflict arises before we’ve ever met. So, it’s in our interest if you engage our services, but is it in yours? Everyone knows the theory that our relationship should be mutually beneficial, but how do we test that?
We are committed to a process of open dialogue and continuous improvement. This document formalises our corporate position in this respect.
Here are a few examples of the practical application of our Conflicts of Interest Policy:
A ‘conflict of interest’ is a situation where the firm or an employee, or other associates of the firm has competing professional or personal interests, which may prevent services being provided to clients in an independent or impartial manner.
We are committed to identifying, monitoring and managing all actual and potential conflicts of interest that can or may arise between us and our clients and any person directly or indirectly associated with the firm. We are required to establish, implement and maintain a written Conflicts of Interest policy.
This document provides information in relation to the policies we have in place to manage conflicts of interest.
We take all reasonable steps to identify and to prevent conflicts of interests that arise or may arise, in the course of the provision of service(s) to clients, between:
Types of Conflicts
We will take into account whether the firm, or a relevant person, or a person directly or indirectly linked to the firm:
Below is a summary of the principal conflicts that could arise in our business and the steps we take to mitigate them.
Gifts & Inducements
In accordance with the Rules of our Regulator, we are prohibited from accepting a fee, commission or other non–monetary benefit which is likely to conflict with the duty the firm owes to its clients.
The firm may receive non–monetary benefits from product providers or other third parties. Such benefits are typically of a modest nature and generally relate to the provision of literature, participation in seminars, training and hospitality. The provisions of such benefits are designed to enhance the quality of the services we provide to our clients.
We may occasionally receive gifts from clients and providers in recognition of services provided. We take care to ensure that these gifts are of a modest nature and do not create any obligations or debt.
Details of any gifts or inducements must be reported and recorded within our ‘Gifts and Inducements’ Register. Where relevant we will disclose the amount of any benefit to clients and provide further details on request.
We may also receive some form of benefit if we introduce business to a product provider or another firm. We will tell you before the transaction if we are likely to receive some form of benefit from recommending any product to you, or from working with any product provider or firm.
Business Interest and Suitability
We offer advice in accordance with that disclosed to you in our Client Agreement. Occasions may arise where we or one of our other clients have some form of interest in business being transacted for you. If this happens or we become aware that our interests or those of one of our other clients conflict with your interests, we will write to you and obtain your consent before we carry out your instructions, and detail the steps we will take to ensure fair treatment.
When we make a personal recommendation we will take reasonable steps to ensure that the recommendation is suitable for the client’s needs and circumstances.
Mandates and Power of Attorney
To uphold the highest levels of integrity, we will not normally place ourselves as a Trustee, Executor or act as Power of Attorney over your financial affairs.
In exceptional circumstances, should we hold a mandate against your title, we will detail to you how we will manage this to avoid any conflicts that may arise.
We will never act on your behalf or execute any instructions without your prior knowledge and consent.
Disclosure of Conflicts of Interest
Where we identify that an actual or potential conflict of interest exists we will notify you in writing of that fact, outlining the general nature or sources of conflicts of interest, or both, the risks that arise as a result of the conflicts of interest, and the steps taken to mitigate those risks, to enable you to make an informed decision about whether or not you wish to proceed.
Where we believe, as a result of the conflict, we cannot act in your best interests, we will immediately inform you in writing that we can no longer act on your behalf.
Recording Conflicts of Interest
We will keep and maintain a record of circumstances in which a conflict of interest may arise, or has arisen, as a result of the activities carried out by the firm.
To ensure we manage our conflicts of interest effectively, our compliance officer will have the overall responsibility to ensure that the firm identifies, records and manages any conflicts of interest appropriately effectively, and in line with the Regulator’s rules and guidance.
All of our employees are made aware of this policy to highlight and emphasise the importance of identifying and managing conflicts of interest.
Our process of continuous improvement is continuous, but we’ll formally review our conflicts of interest policy least annually.
document reference: Conflicts Policy v1.1
Investment & Retirement Solutions Ltd is authorised and regulated by the Financial Conduct Authority
Registered in England & Wales (6884783) at Ransom Hall, Ransom Wood, Nottinghamshire, NG21 0HJ