More specifically such measures include the following:

(1) A ‘need to know’ policy governing the dissemination of confidential or inside information within the Company.

(2) Chinese walls, which serve as information barriers, such that restrict the flow of confidential and inside information within the Company, and physical separation of departments.
(3) Procedures governing access to electronic data.

(4) The appointment of an Internal Auditor to ensure that appropriate systems and controls are maintained and report to the Company’s Board of Directors.

(5) Segregation of duties that may give rise to conflicts of interest if carried on by the same individual.

(6) Personal account dealing requirements applicable to Relevant Persons in relation to their own investments.

(7) A gifts and inducements log registering the solicitation, offer or receipt of certain benefits.

(8) Material information will be confined only to persons who have a need to know that information in order to carry out their responsibilies.

(9) A policy designed to limit the conflict of interest arising from the giving and receiving of inducements.

(10) The establishment of a Compliance Department which is responsible for the monitoring and reporting on the above to the Company’s Board of Directors. Additionally, it is also reviewing the Company’s and the Company’s employees transactions and ensures the priority of client interests.

(11) The Company’s Compliance Department is also responsible for identifying and managing potential conflicts of interests. The above will also update the relevant internal procedures and ensure compliance with such procedures.

(12) Establishment of the Four-Eyes principle in supervising the Company’s activities.

    vi) The Company also undertakes ongoing monitoring of business activities to ensure that internal controls are appropriate.

vii) If not possible to avoid or manage a conflict of interest, the Company shall disclose the general nature and/or sources of interest to the client before undertaking business on its behalf and the Company reserves its right to decline to provide the requested Services.

5.Miscellaneous:

The Company reserves the right to review and/or amend its Policy and arrangements whenever it deems this appropriate.
 
Should you have a question about conflicts of interest please direct your questions to our in house Compliance Department at [email protected]

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