Section SYSC 10 of the FCA Handbook and FCA Principle 8, deal directly with identifying and managing conflicts of interest between clients and the firm. This area is high on the list of regulatory requirements for the FCA and they have given clear guidance and robust rules that must be followed.
They advise that ALL firms subject to conflicts of interest must have a Conflict of Interest Policy and subsequent procedures which help to identify, mitigate against and manage any such conflicts. All conflicts must be handled in a fair and transparent manner and expectations are high on what the FCA want firms to do.
KYC have developed this Conflict of Interest Policy which meets the requirements, standards and expectations as laid out by the FCA in their handbook rules and also gives you a robust and structured foundation on which to build your procedures.
As Conflict of Interest procedures are bespoke to each firm and business sector, we have not included them in our policy template, however you will find a summary of the measures and controls which apply to all firms when identifying and manages conflicts and we have also provided a standalone Conflict of Interest Register to record essential interests and mitigating actions. All documents are in a fully customisable Word.doc format.
The KYC Conflicts of Interest Policy & Register contains (8 pages):–