MMC Limited (“MMC”) takes seriously its responsibilities as a regulated UK financial services company. One of these responsibilities involves identifying, avoiding, and managing any conflicts of interest that may occur in the course of business between us and our client or clients, between different clients and between any connected persons with MMC. MMC has put in place arrangements which ensures fair treatment for all parties concerned and ensures it does not adversely affect the interests of its clients.
How does MMC address conflicts?
MMC takes all reasonable steps to maintain and operate effective organisational and administrative arrangements to identify and manage relevant conflicts. Senior management within the organisation are responsible for ensuring that MMC’s systems, controls and procedures are adequate to identify and manage conflicts of interest. These include:
• Controls over the handling and flow of confidential and inside information
• An allocation policy to ensure that conflicts are managed across the Fund range
• Bespoke pricing models
How does MMC identify and manage conflicts?
MMC has in place business specific procedures that address the identification and management of actual and potential conflicts of interest that may arise during its day to day business. These procedures include:
• Maintaining a restricted trading list and associated Personal Account dealing policy
• Information barriers and a clear separation of reporting lines
• Pricing models which identify conflicts or material interest at an early stage of any deal or transaction
• Accepting and receiving gifts and benefits which identify and manage potential conflicts
• Maintaining a separate oversight of remuneration arrangements
MMC address specific conflicts by:
• Declining to act in certain circumstances where a conflict is apparent
• Applying unique procedures to ensure that the fair treatment of all parties is achieved
• Disclosing the conflict or material interests to the client at the beginning of any deal/transaction and getting their consent to proceed
If any arrangement made by MMC to manage conflicts of interest as shown above are not sufficient to ensure, with reasonable confidence, that risks to the interests of a client/customer will be prevented, then the business area must clearly disclose the general nature and/or sources of conflicts of interest to the client before undertaking business for the client.
The disclosure must be in writing and include sufficient detail to enable the client to take an informed decision.
Governance and review
MMC’s compliance with the Conflicts of Interest policy will be reviewed as part of MMCs compliance monitoring programme on at least an annual basis.