Information regarding the management of conflicts of interest
In an investment firm providing a multitude of investment and consultancy services to clients, conflicts of interest are sometimes unavoidable. In compliance with MIFID requirements, we would therefore like to provide you the following information regarding our extensive procedures for managing these conflicts of interest.
Such conflicts of interest may arise between Intermonte Holding SIM, our management, our employees, or other persons connected with us and our clients - or between our clients.
Specifically, conflicts of interest may arise:
- from our different business activities, especially in relation to the buying or selling of emissions units on the company’s account and the buying or selling of derivative instruments linked to these units on behalf of third parties;
- as a result of obtaining non-public information;
- from personal relationships of our employees or management or persons connected to them;
- in the course of such persons' participation on supervisory or advisory boards.
In order to avoid any conflicting interests exerting an influence on the provision of consultancy services or the execution of orders, we have adopted specific internal procedures to manage potential conflicts of interest. These procedures, which involve the provision of specific information and training to employees, are reviewed and updated on a regular basis.
Our firm has a Compliance Officer reporting directly to management, which is responsible for identifying, avoiding and managing conflicts of interest. The specific measures we have in place include:
- the creation of organisational procedures in order to protect clients' interests in investment advice, such as approvals procedures for research;
- provisions on giving and receiving incentives as well as their disclosure;
- the creation of Chinese walls, the separation of responsibilities and/or physical separation;
- maintaining an insider or observation list for purposes of monitoring sensitive information and preventing any abuse of insider information;
- disclosure to the Internal Auditor of any transactions carried out by employees on their own behalf;
- employee training.
Where conflicts of interest cannot be avoided, we undertake to disclose these to the relevant clients prior to executing any transaction or providing any advisory service.
We also provide information on relevant potential conflicts of interest on our website, in accordance with applicable rules (CONSOB – Issuers Regulations).
We would be happy to provide you with further details regarding these principles upon request.
Intermonte Holding SIM S.p.A. - Corso Vittorio Emanuele 13, 20122 Milano, Italia – Tel. +39 02 77115.1 – Fax +39 02 77115.300
Capitale Sottoscritto e Versato € 3.290.500 Part. IVA, Cod Fiscale e Isc. Registro Imprese n. 06108080968 - Cod. LEI: 8156007125B2DED00348