11 Conflict of interest policy at institutional level

The management body should be responsible for establishing, approving and overseeing the implementation and maintenance of effective policies to identify, assess, manage and mitigate or prevent actual and potential conflicts of interest at institutional level, e.g. as a result of the various activities and roles of the institution, of different institutions within the scope of prudential consolidation or of different business lines or units within an institution, or with regard to external stakeholders.

Institutions should take, within their organisational and administrative arrangements, adequate measures to prevent conflicts of interest from adversely affecting the interests of its clients.

Institutions ’ measures to manage or, where appropriate, mitigate conflicts of interest should be documented and include, inter alia:

• a. an appropriate segregation of duties, e.g. entrusting conflicting activities within the processing of transactions or when providing services to different persons, or entrusting supervisory and reporting responsibilities for conflicting activities to different persons;
• b. establishing information barriers, e.g. through the physical separation of certain business lines or units.