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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.
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.
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.
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