Conflict of Interest Policy

1. Scope

This policy sets out AB Money's approach to managing and mitigating Conflicts of Interest (CoIs) in line with FCA regulations and industry guidance. It applies to all employees, supervisors, senior management, board members, vendors, and third-party representatives who may have access to information or are involved in activities that could create or appear to create a CoI.

2. What are Conflicts of Interest?

A CoI arises when AB Money's interests or those of its employees’ conflict with the interests of its clients. CoIs can be actual, potential, or perceived and can arise in different forms, such as financial, non-financial, personal, or business. AB Money is committed to identifying, managing, and mitigating CoIs to ensure that its clients are treated fairly and with integrity.

3. Approaches to Conflicts Management

AB Money will adopt a proactive approach to identifying and managing CoIs, including:

  • Establishing a Conflicts Management Framework that includes policies, procedures, systems, and controls to identify, manage and mitigate CoIs.
  • Providing training and awareness programs to all employees to ensure they understand CoIs and their responsibilities in managing them.
  • Conducting regular reviews of its operations to identify potential CoIs and implementing appropriate measures to mitigate them.

4. Employee Responsibilities

Employee Responsibilities of All Employees, Supervisors, Senior Management and AB Money Board Members: All employees, supervisors, senior management, and AB Money Board members have a duty to act in the best interests of AB Money's clients and avoid or manage CoIs.

Their responsibilities include:

  • Identifying potential CoIs and disclosing them promptly to the Compliance Team.
  • Seeking guidance from the Compliance Team if they are unsure about whether a CoI exists or how to manage it.
  • Ensuring that their personal interests do not conflict with the interests of AB Money’s clients.
  • Ensuring that any outside business interests are declared and managed appropriately.

5. Disclosure and Client Consent

AB Money will disclose any potential CoIs to clients in a clear, concise, and timely manner. In cases where AB Money cannot manage or mitigate a CoI, it will seek the client's informed consent before proceeding with any transactions or services.

6. Escalation and Reporting

Employees must report any potential or actual CoIs to their supervisors or the Compliance Team. The Compliance Team will investigate, manage and escalate CoIs as necessary. If a CoI involves a member of the senior management team or the board, it must be reported directly to the CEO.

7. Whistleblowing

AB Money encourages employees to report any potential or actual CoIs without fear of retaliation. Employees can raise concerns through the Whistleblowing Policy, which outlines the steps for reporting concerns, the confidentiality of the reporting process, and the protection against retaliation.

8. Remuneration Practices

AB Money's remuneration practices will not incentivize or reward employees for actions that may create or appear to create a CoI. AB Money will ensure that remuneration practices align with its values and do not compromise its commitment to managing and mitigating CoIs.

9. Outside Business Interests

Employees must declare any outside business interests, including directorships, shareholdings, or partnerships that may create or appear to create a CoI. The Compliance Team will assess the potential CoI and determine appropriate measures to manage or mitigate the risk. AB Money will not allow any outside business interests that compromise its commitment to managing and mitigating CoIs.

10. Vendors and Third Party Representatives

AB Money will conduct due diligence on vendors and third-party representatives to identify any potential CoIs. AB Money will only work with vendors and third-party representatives who have adequate policies and procedures in place to manage CoIs. AB Money will ensure that vendors and third-party representatives understand and adhere to AB Money's Conflicts of Interest policy.

11. Conflict of Interest Log

AB Money will maintain a Conflict-of-Interest Log to record all potential and actual CoIs. The log will include the nature of the CoI, the measures taken to manage or mitigate the risk, and the outcome of the CoI assessment.

12. Review Cycle

The review frequency for the Conflicts of Interest policy and related documents should be determined by the risk appetite and tolerance of AB Money, as well as regulatory requirements.

As a general guideline, it is recommended that the policy and related documents be reviewed on an annual basis or more frequently if significant changes occur within the organization or the regulatory environment. Additionally, the policy should be reviewed whenever a new

product or service is introduced, or there is a significant change to the organizational structure or business model.

It is important to ensure that the review frequency is adequate to identify and address any new or emerging conflicts of interest and that the policy and related documents remain up- to-date and effective in managing and mitigating conflicts of interest.

Annex 1

Conflicts of Interest Relationships, Scenarios, and Specific Examples with examples for remittance service firm: AB Money will maintain an Annex to this policy that outlines examples of potential CoIs that may arise in its operations.

Examples:

  1. AB Money offers remittance services to customers and also has a financial interest in a remittance service provider. This creates a conflict of interest, as AB Money may be incentivized to recommend its own provider over others, even if it may not be the best option for the customer.
  2. An AB Money employee is responsible for referring clients to remittance service providers and also has a family member who owns a remittance service provider. This creates a conflict of interest, as the employee may feel pressure to refer clients to their family member's provider over other providers, even if it may not be the best option for the client.
  3. AB Money offers remittance services to customers and also has a partnership with a bank that offers remittance services. This creates a conflict of interest, as AB Money may be incentivized to recommend the bank's services over others, even if it may not be the best option for the customer.

Annex 2

Description of Organisational Arrangements Relating to Conflicts of Interest

Example:

  1. AB Money has appointed a Conflicts Management Officer (CMO)/MLRO to oversee the Conflicts Management Framework and manage conflicts of interest.
  2. AB Money has established a Code of Ethics and Conduct that outlines the expectations for employees' behaviour in relation to conflicts of interest. This includes requirements for employees to disclose any potential conflicts of interest.
  3. AB Money has implemented controls, such as segregation of duties, to mitigate the risk of conflicts of interest. For example, employees responsible for referring clients to remittance service providers are not responsible for receiving commissions or incentives related to those referrals.

Annex 3

Description of Policies, Procedures, Systems and Controls Relating to Conflicts of Interest with Examples for Remittance Service Firm: AB Money will maintain an Annex to this policy that outlines its policies, procedures, systems, and controls relating to CoIs.

  1. AB Money has implemented a Conflicts Management Policy that sets out its approach to managing and mitigating conflicts of interest. This policy outlines requirements for employees to disclose any potential conflicts of interest and provides guidance on how to manage conflicts of interest.
  2. AB Money has established a Remuneration Policy that aligns with its commitment to managing and mitigating conflicts of interest. This policy outlines the criteria used to determine employee compensation, including requirements for compensation to be based on objective criteria rather than sales performance.
  3. AB Money has implemented systems and controls to monitor and review its operations for potential conflicts of interest. For example, AB Money regularly reviews its list of remittance service providers to ensure that there are no conflicts of interest related to employees outside business interests or vendor relationships. Additionally, AB Money reviews its partnerships with banks and other financial institutions regularly to ensure that there are no conflicts of interest.

Conclusion

AB Money is committed to managing and mitigating CoIs in its operations to ensure that its clients are treated fairly and with integrity. AB Money will regularly review and update this policy to reflect changes in regulatory requirements and industry best practices.

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