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:
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:
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:
Annex 2
Description of Organisational Arrangements Relating to Conflicts of Interest
Example:
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.
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.