The ibs policy on conflicts of interests

The IBS policy on conflicts of interests
Introduction
Pursuant to laws and regulations, IBS Asset Management B.V. (hereafter: "IBS") has to take and enforce adequate organisational and administrative measures with the aim to identify, chart and control conflicts of interests. A policy is in place within IBS in order to meet these requirements. Below is a general description of our policy and the information which clients need in order to understand the measures taken by IBS to secure its clients' interests. IBS' policy regarding conflicts of interests
IBS' policy regarding conflicts of interests explains how IBS: identifies circumstances that may give rise to conflicts of interests entailing a material risk of harm to clients' interests sets up appropriate mechanisms and systems in order to control these conflicts; and enforces these systems in order to prevent actual harm to clients' interests as a result of conflicts identified. What is a conflict of interests?
A conflict of interests is a conflict occurring in any area of the provision of services by IBS to its clients whereby IBS (or another client for whom IBS is acting) may obtain benefit, while material harm may be caused to a client to whom IBS is providing a service. This policy only relates to conflicts of interests that may occur when IBS performs an investment service, an investment activity or an ancillary service for its clients. A conflict may exist if IBS (or someone affiliated to IBS, including third parties associated with IBS): will probably achieve a financial gain (or avoid a financial loss) at its client's expense; has an interest in the result of a service performed for its client in which IBS' interest differs from its client's interest; has a financial or other motive for putting one client's interests above another client's interests; conducts the same business as the client; receives money, goods or services from third parties - other than the standard fees or commission - in relation to services provided to a client. IBS has established the conflicts of interests existing within its operations and has taken measures which, in IBS' view, adequately help it chart, control and monitor these conflicts and their potential impact on its clients. conflicts between clients with contrary interests; conflicts between clients and IBS, whereby their respective interests may differ in a particular outcome; conflicts between personal interests of IBS staff and the interests of IBS or its clients insofar as these interests are different. In principle, the measures applied at IBS in order to control the conflicts identified in the best possible way fall into one of the following categories: Guidelines and procedures
IBS has many internal guidelines and procedures in place that enable it to control the conflicts of interests identified. Monitoring and maintaining these guidelines and procedures is part of our standard processes. Protection of information
Procedures are in force within IBS to prevent or control information flows between IBS units and staff in the event that the interests of one IBS unit's or staff member's clients may conflict with the interests of another unit's or staff member's clients, or with the interests of IBS itself. Separate supervision and segregation of duties
Where necessary, IBS has arranged for separate supervision of those staff members whose duties may involve a conflict of their interests and those of the clients, or a conflict of clients' interests and those of IBS. In addition, IBS has taken steps to prevent the staff member concerned from being involved in the simultaneous or successive provision of services to the parties involved in a way which would preclude the adequate control of these conflicts of interests. Disclosure
If a conflict of interests turns out to be inevitable despite the organisational and administrative measures taken by IBS, IBS will inform clients accordingly. On this occasion, IBS will provide such a degree of detail as to enable the clients to make an informed and well-considered decision with regard to the investment service, investment activity or ancillary activity in connection with which the conflict of interests has arisen. Refusal to act
IBS may refuse to provide services to a particular client if it believes that it is unable to control the conflict of interests in any way. If you require more information about the IBS policy on conflicts of interests, please do not hesitate to contact us. We will be happy to help you.

Source: http://ibsam.nl/template/docs/2013-07-01_ibs_policy_on_conflicts_of_interests.pdf