Summary of Conflicts of Interest Policy
This document summarises the Greengage Conflicts of Interest Policy. It's important for individuals to know that we will use all reasonable endeavours to identify conflicts, manage them effectively and treat individuals fairly. We have a comprehensive Conflicts of Interest Policy which sets how Greengage manages its conflicts between itself, clients, service providers and its related companies within the Group.
Greengage is a non-bank Fintech firm which expects to operate as a bank within the UK and Gibraltar markets and therefore takes all reasonable steps to ensure in its dealings with counterparties of all kinds, that it treats them fairly and with respect.
The Board of Greengage is ultimately responsible for the oversight and the management of conflicts of interest although the senior management of the Firm is expected to identify and monitor those conflicts and ensure the Board is fully briefed on areas of potential conflict.
The reputational risk to the firm if a conflict of interest is not managed appropriately could be very serious. It may pose a risk of financial detriment to one or more of our clients, or to ourselves, our shareholders and other stakeholders or be in the form of reputational risk. Therefore all staff have a duty to avoid conflicts of interest if they can. Sometimes it's not possible and in that staff they have a duty to declare the conflict and deal with it fairly and transparently. Fines, penalties and legal action can arise from breaches of regulation and conflicts of interest. All staff are responsible for the implementation and conduct of the policy from the Board downwards.
The Firm has set a standard that it must identify and manage, using reasonable steps, material conflicts which may arise with clients. The approach is to have appropriate procedures and measures to identify any such material conflicts.
What is a Conflict of Interest?
A conflict of interest is a situation where there is a risk that objectivity, professional judgement or actions may be compromised by a competing interest. Conflicts can arise by the following
· The Firm and a Client
· A relevant person within the Firm and a Client
· Two or more Clients in the context of services or products the bank sells.
Clients of the Firm include current, prospective and prior clients to whom we may have any fiduciary responsibility.
Greengage is not yet regulated but it will endeavour to follow an appropriate policy which will broadly follow FCA SYSC 10 .2 rules and the EU regulation under Mifid.
How are Conflicts Managed?
Greengage will maintain and operate effective organisational and operational arrangements in order to undertake all appropriate steps to prevent conflicts of interest from adversely affecting the interests of clients including a Conflicts Risk register.
Greengage will maintain robust processes in order to identify conflicts of interest within the Group or with third parties, and for managing and monitoring any conflicts identified, supported by our policies and procedures.
Staff are provided with training to ensure awareness and understanding of how conflicts could arise and to enable staff to identify and adequately manage such conflicts. Where a potential or actual conflict is identified, this is reported in line with the Greengage Conflicts of Interest Policy, and an appropriate plan for mitigating the conflict is agreed.
Oversight and Governance
Overall responsibility for the oversight of conflicts resides with the Chief Risk Officer (CRO). The CRO assists the Board in discharging its responsibility for embedding an appropriate culture and acting consistently with its duty to deliver fair outcomes to clients. The highest standards of integrity and ethical conduct are expected at all times from Greengage's senior managers and all staff. Should you have any further questions with regard to the Greengage Conflicts of Interest Policy please contact us via firstname.lastname@example.org