Description of the Policy on Prevention of Conflict of Interest
To prevent possible conflict of interest, which may arise providing Investment services, Renesource Capital implemented “Policy on Prevention of Conflict of Interest” (Policy).
Policy observes the regulatory principles of the MIFID II, as well as standards of best practice.
Conflict of Interest (definition):
Circumstances in which several persons are in position to receive personal benefit from actions or decisions made in their official capacity, when providing Investment Services.
The types of Conflict of interest and situations:
Conflict of interest may arise between:
(a) Employee and a Client;
(b) an Individual, who has direct or indirect control of the Renesource Capital, and/or a Client;
(c) Clients of the Renesource Capital;
(d) Client and a Relevant person;
(e) a Relevant person and a Renesource Capital;
(f) Tied agent and Renesource Capital and/or Client;
Situations when Conflict of interest may arise:
(a) an execution of FI (financial instruments) orders on behalf of more than one Client at the same time;
(b) an execution of orders related to FI distributed by Renesource Capital;
(c) Renesource Capital is interested in increasing revenues from Portfolio management, as well as increasing Portfolio value in result of the sale/purchase of FI issued by Renesource Capital;
(d) an execution of the limit order related to FI;
(e) Renesource Capital simultaneously manage two or more Client’s Portfolios and makes investment decision in respect of them;
(f) Renesource Capital paying or being paid any fee or commission, providing or being provided with Inducement from third parties, regarding the provision of Investment services to the Clients;
(g) In other cases.
The core principles on prevention and management of Conflict of interest:
(a) assessment of the risk damage to the interests of the Client;
(b) restrictions on the execution of Personal transactions with FI;
(c) keeping and maintaining the register of Personal transactions;
(d) supervision of Relevant persons, whose principal functions involve carrying out activities on behalf of Client, or providing Investment services to the Client;
Measures on prevention and management of Conflict of interest:
When preventing and managing the Conflict of interest the reasonable and proportional measures on prevention of Conflict of interest applies at least to:
a) Clients orders on transactions with FI;
b) Custody (holding) of FI;
c) Portfolio management;
d) Investment research;
e) Receiving and paying Inducements;
f) Transactions with FI issued by the Company;
Additionally, Renesource Capital implemented restrictions on Personal transactions, which are related to all Renesource Capital employees.
Renesource Capital is prohibited from receiving and paying Inducements, except the cases determined by law, when such Inducements may be received.
For more detailed information regarding applicable policy of Renesource Capital in respect of Inducements, please follow the link
The full text of the “Policy on Prevention of Conflict of Interest” available there