149. As to conflicts of interest at the staff level, competent authorities should be satisfied that …

As to conflicts of interest at the staff level, competent authorities should be satisfied that the policy covers at least the situations envisaged in paragraph 109 of the EBA Guidelines on internal governance⁵⁵ , and that it envisages ‘procedures, measures, documentation requirements and responsibilities for the identification and prevention of conflicts of interest, for the assessment of their materiality and for taking mitigating measures’.

9.3.3 Whistleblowing, market abuse, product governance, consumer protection, complaints handling

⁵⁵ Paragraph 111 of the EBA Guidelines on internal governance reads: ‘The policy should cover at least the following situations or relationships where conflicts of interest may arise: a. economic interests (e.g. shares, other ownership rights and memberships, financial holdings and other economic interests in commercial customers, intellectual property rights, loans granted by the institution to a company owned by staff, membership in a body or ownership of a body or entity with conflicting interests); b. personal or professional relationships with the owners of qualifying holdings in the institution; c. personal or professional relationships with staff of the institution or entities included within the scope of prudential consolidation (e.g. family relationships); d. other employment and previous employment within the recent past (e.g. five years); e. personal or professional relationships with relevant external stakeholders (e.g. being associated with material suppliers, consultancies or other service providers); and f. political influence or political relationships’.

1. Overview

1.1 References

1.2 Identified Requirements

1.3 Related Standards

2. Identified Requirements

3. Related Standards

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