The purpose of the Policy is to set out the requirements for the company in respect of the potential conflicts of interest. The Policy is designed to give guidance on expected behaviors in relation to conflicts and may need to be read in conjunction with other documents, such as the Personal Account Dealing Policy, as indicated from time to time. Who does the Guidance Apply to? It applies to all staff employed or seconded to JMI Brokers LTD (JMI). It also applies to all management and those working on long term contracting arrangements. It may also apply to JMI Brokers personnel where a conflict arises involving the Group. Other Documents Which Need to be Considered. In order to have a comprehensive understanding of your requirements to manage conflicts of interest you should also refer to: Personal Account Dealing Policy Compliance Manual Principles and Approved Persons Trading Guidelines Relevant Rules & Regulations Company Approach The company respects its employees' privacy and therefore does not normally take an interest in personal conduct outside of work. However, when there is a potential conflict between and employee's personal conduct has the potential of interfering with the employee's loyalty and objectivity towards the group, a 'conflict of interest' may exist that must be satisfactorily resolved. You need to consider if the appearance of a conflict of interest can be harmful to you or the group. We would remind you that you should always treat our counterparties, brokers and other third parties fairly, professionally and with integrity. Mitigations/Controls It is a mitigating factor through identification and management of the potential conflicts both senior management and individual employees. It is therefore essential that you read and consider the material presented to you and if you are in any doubt seek advice from you line manager or compliance. You should also ensure you document and keep records of any training you receive whether internal or external.
What is a conflict of interest? In the widest sense, a conflict of interest occurs where one person (A) owes a duty to another party such as a counterparty or employer (B) and that duty is compromised by either A's own interests or by a duty owes a third party. Such duties may arise, for example, where A acts as an agent for B, where A owes fiduciary obligations to B or as a result of a regulator imposing such duties.
'Employee conflicts' where the personal interests of any employee conflict with the interests of the company itself or with a counterparty; JMI counterparty conflicts where the interests of an JMI Brokers company and its counterparties either directly conflict or are more generally incompatible; 'Counterparty conflicts' where the interests of two or more counterparties either directly or are generally incompatible; 'Internal conflicts' where the interests of one internal entity conflicts with another internal entity.
We understand the importance of safeguarding your personal information and do not sell, trade, or otherwise transfer it to third parties without your consent, except as described in this Privacy Policy. We may share your information in the following circumstances:
3.1 Service Providers: We may engage trusted third-party service providers to assist us in operating our Website and providing our services. These service providers have access to your personal information only to perform specific tasks on our behalf and are obligated to protect your information.
3.2 Business Transfers: If JMIBrokers undergoes a merger, acquisition, or sale of all or a portion of its assets, your personal information may be transferred as part of the transaction. We will notify you via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information.
3.3 Legal Requirements: We may disclose your personal information if required to do so by law or if we believe in good faith that such disclosure is necessary to:
We employ industry-standard security measures to protect the personal information you provide to us. However, please note that no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
5.1 Accessing and Updating Information: You have the right to access, update, or delete your personal information. If you would like to do so, please contact us using the information provided at the end of this Privacy Policy.
5.2 Cookies: You can manage your cookie preferences by adjusting the settings in your web browser. Please refer to our 'Cookie Policy' for more information on how to manage cookies.
Our Website may contain links to third-party websites. This Privacy Policy does not apply to those websites, and we encourage you to review their respective privacy policies. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party websites or services.
Our Website is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe that we have inadvertently collected personal information from a child, please contact us, and we will take immediate steps to delete the information from our records.
We may update this Privacy Policy from time to time to reflect changes in our information practices. We will notify you of any material changes by posting the updated Privacy Policy on our Website and updating the effective date at the top. We encourage you to review this Privacy Policy periodically for any updates.
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at: JJMI Brokers Holding AG Company - the city of zug - Bahnhofstrasse - - 21-6300 ZUG - Downtown United Arab Emirates. +971 44096705 Fax: +971 44096740 Thank you for taking the time to read our Privacy Policy.
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