Conflicts Management at Moneybox
Moneybox is committed to maintaining the highest professional standards and, therefore, we endeavour to identify, consider and manage potential conflicts of interest to ensure that we treat all of our customers fairly and in accordance with the Financial Conduct Authority’s rules and principles.
2. WHAT IS A CONFLICTS POLICY?
A conflict of interest is a situation in which Moneybox (or any of its personnel) finds itself in a position where its own interests conflict with the duties and obligations it owes to its customers or, a situation in which Moneybox’s duty to one customer conflicts with the duties and obligations to another.
For the purposes of identifying the types of conflict and potential conflicts that arise which may entail a material risk of damage to the interests of a customer, we must take into account whether any director, officer, employee or contractor of Moneybox or Moneybox Mortgages (“Moneybox Personnel”) or any other person linked by control to Moneybox or Moneybox Mortgages:
- is likely to make a financial gain, or avoid a financial loss, at the expense of a customer;
- has an interest in the outcome of a service provided to a customer or transaction carried out on behalf of a customer, which is distinct from the customer’s interest in that outcome;
- has an incentive to favour the interest of another customer or group of customers over the interests of the customer;
- carries on the same business as a customer; or
- receives or will receive from a person other than a customer an inducement in relation to a service provided to the customer, in the form of remuneration, goods or services.
3. CONFLICT SITUATIONS
We have identified a number of situations that may give rise to a potential conflict of interest. These situations include, but are not limited to, the following:
- Moneybox Personnel receive gifts, entertainment or other monetary and non-monetary benefits from our service providers or business partners (for example, the fund managers of the funds we make available to customers through the Moneybox app), which could give rise to a conflict with respect to the duties that we owe to our customers.
- Moneybox Personnel who have outside commitments (e.g. directorships or other outside business interests) may be influenced to act in a manner that conflicts with the interests of Moneybox or its customers.
- Where Moneybox Personnel invest for their own account in certain investments which are retained as investments for customer accounts.
4. CONFLICT AVOIDANCE
We seek to organise our business in such a way as to avoid conflicts of interest arising.
5. CONFLICT MANAGEMENT
For conflicts of interest that are unavoidable, we have put in place procedures that are designed to ensure that the management of any conflict takes place in such a way that Moneybox (and the Moneybox Personnel) are not advantaged and that no customer is disadvantaged. All of our employees are provided with training in these procedures and the standards of conduct expected of them. Moneybox’s Board of Directors remains responsible for ensuring that such procedures are appropriate and that employees act accordingly. Specifically, we have put in place the following procedures to assist in our identification and management of conflicts of interest:
Conflicts Log: we maintain a list of all potential conflicts of interest identified. With respect to each conflict, the log details the measure put in place to monitor and manage the conflict of interest.
Gifts & Entertainment Policy: we ensure that all Moneybox Personnel are subject to appropriate restrictions and monetary limits for any gifts or entertainment received.
Personal Account Dealing Policy: we ensure that all Moneybox Personnel pre-clear and report any personal trading activity which may conflict with the interests of our customers.
Pre-approval process for all Outside Business Interests: we ensure that our personnel’s external commitments do not conflict with the interests of Moneybox or its customers.
Separation of functions: where our internal functions might give rise to conflicts of interest, we put in place arrangements to separate such functions and ensure that separate management and reporting lines are established.
6. CONFLICTS OF DISCLOSURE
If we are not reasonably confident that we are able to manage a particular conflict to adequately protect the interest of a customer, the general nature and/or source of conflicts of interest will be clearly disclosed before we undertake any business.