Information regarding the management of conflict interest
In an investment firm providing clients a multitude of investment services as well as corporate financing and consulting services, conflicts of interest are sometimes unavoidable. Therefore, in compliance with the requirements of MIFID II Directive, we would 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, 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, particularly from the Firm's interest in profits from proprietary tradings;
- from our relations with issuers of financial instruments, for example, such as in the case of co-operations;
- in the context of producing investment research concerning securities negotiated;
- 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 having conflicting interests influence, for example, the Firm's advisory services, order execution, or investment research, we and our employees have undertaken to uphold high ethical standards. We expect at all times due and proper, fair and professional conduct, compliance with market standards and, in particular, with clients' interests.
Our firm has a Compliance Officier reporting directly to management, which is responsible for identifying, avoiding and managing conflicts of interest. The specific measures we have in use include:
- the creation of organisational procedures in order to protect the clients' interest in investment advice, such as approvals procedures for research;
- provisions on giving and receiving inducements 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;
- maintaining a restricted list, which serves, among other things, to counter potential conflicts of interest by prohibiting the execution of transactions, the provision of advisory services or the production of investment research;
- disclosing securities transactions to the Internal Auditor by those employees with respect to which conflicts of interest could arise in the course of their work;
- training our employees;
- where conflicts of interest cannot be avoided, we will 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 in the investment research produced by us, according to applicable rules (CONSOB – Issuers Regulations).
We would be happy to provide you with further details regarding these principles upon request.
Galleria De Cristoforis, 7/8
20122 - Milan - Italy
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Intermonte SIM S.p.A. - Galleria De Cristoforis 7/8, 20122 Milano, Italia – Tel. +39 02 77115.1 – Fax +39 02 77115.300
Capitale Sociale € 45.950.000 - Part. IVA, Cod. Fisc e Iscr. Reg. Imprese n.01234020525 - Cod. LEI: YMUU1WGHJKORF9E36I98 -
Soggetta all’attività di direzione e coordinamento di Intermonte Holding S.p.A. Aderente al Fondo Naz. di Garanzia
Intermonte SIM S.p.A. - Corso Vittorio Emanuele 9, 20122 Milano, Italia – Tel. +39 02 77115.1 – Fax +39 02 77115.300 Capitale Sociale € 45.950.000
Part. IVA, Cod. Fisc e Iscr. Reg. Imprese n.01234020525 Soggetta all’attività di direzione e coordinamento di Intermonte Holding S.p.A. Aderente al Fondo Naz. di Garanzia