Conflict Of Interest

Conflict Of Interest

We provide here a summary of the policy we maintain in order to manage conflicts of interest in connection with the duties we owe to our clients. You may request further details of our Conflicts Policy. Our policy applies from 3 January 2018.

A conflict of interest can arise between the Ikon Finance Limited (“IKON”) group companies and associates, the directors and staff of such companies and you as a client or between your interests and those of another client of ours.

We maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to prevent conflicts of interest from giving rise to a material risk of damage to the interests of our clients.

FINANCIAL CONDUCT AUTHORITY (“FCA”) RULES

The FCA sets out obligations in SYSC 10 and Principle 8 of the FCA Handbook to which this document is prepared. Whilst the FCA rules are important to be adhered to by all of IKON’s staff, they are non-exhaustive, and certain other additional rules may apply to employees who are members of professional associations, or by virtue of their job role. Failure to follow any of the rules whether by express breach, or failure to follow any of the spirit of identifying, mitigating and managing conflicts of interest may also be a breach of an employment contract.  Disciplinary action may be taken by IKON, or in serious cases by the FCA, or the Department for Business, Innovation & Skills.  The FCA Principles 3, 6, 7 and 8 are particularly relevant when considering issues around conflicts of interest.

PRIN2.1.1R states:         

3

Management and control

A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems

6

Customers’ interests

A firm must pay due regard to the interests of its customers and treat them fairly.

7

Client Communications

A firm must pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading

8

Conflicts of interest

A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client

 

OUR POLICY

We monitor for, and keep a record of, potential conflicts of interest in our business and also maintain procedures to manage actual or potential conflicts. This includes procedures to maintain appropriate independence between members of our staff who are involved in different activities, for example, through the operation of information barriers, physical separation of staff, the segregation of duties and responsibilities and maintenance of a policy of independence which requires our staff, when providing services to a client, to act in the best interests of the client and to disregard any conflicts of interest.  In some circumstances, where it is impossible to properly manage a conflict of interest we may decide not to act for a client or potential client.

DISCLOSURE

Notwithstanding the procedure which we maintain to manage potential conflicts of interest, sometimes these are not sufficient to ensure, with reasonable confidence, that the risks of damage to clients' interests will be prevented. In some circumstances, where it is impossible to properly manage a conflict of interest we may decide not to act for a client or potential client. In other cases, we will disclose, in the required level of detail prescribed by the regulations, the nature and/or sources of conflicts before carrying on business for a client. This is to allow the client to consider whether to ask for more information and whether to continue with the service.

PREVENTION AND MANAGEMENT

IKON has identified specific potential conflicts of interests which may arise in relation to its activities.  The general nature and/or source of these conflicts will be disclosed to affected clients before undertaking business in sufficient detail to enable the client to make an informed decision about the service in the context in which the conflict has arisen. For each potential situation, IKON has analysed whether or not the risk is actual or potential for one or more of its clients.

It is not always possible to prevent actual conflicts of interest from arising. In that case IKON will try to manage the conflicts of interests by segregating duties or establishing information barriers (often known as “Chinese Walls”). In the event that IKON is unable to manage a conflict of interest using any of the above it may decline to act on behalf of a client.

Given the business upon which IKON  operates (Spot Forward FX & CFD’s), it is very unlikely that anyone in the firm would be privy to inside information. However, the firm does maintain an Insider List in the unlikely event that an employee does become an insider. Chinese Walls are maintained so as to limit or withhold the use of information that is price-sensitive, or confidential. 

IKON maintains and periodically updates the Restricted List of financial instruments that are prohibited or restricted from investment as a result of a conflict of interest or inside information. If IKON considers developing new products or services or making other changes to its business model or operations, senior management will consider whether any additional potential conflicts of interest arise.

Senior management will update the Conflicts of Interest Policy and Register of Potential Conflicts of Interest as necessary on an ongoing basis and formally consider the continued adequacy of the arrangements annually.

Record Keeping

Under SYSC 10.1.6 IKON must keep and regularly update a written record of the kinds of investment or ancillary services or activities carried out by or on behalf of the firm in which a conflict of interest entailing a material risk of damage to the interests of one or more clients has arisen or, in the case of an ongoing service or activity, may arise. These records will be for a minimum of five years from the date of creation and are maintained on an ongoing basis by the Compliance Officer.

Further Information

IKON will review and update this Conflicts of Interest Policy as necessary. Please direct questions and further information request on this policy to info@ikonfinance.com

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IKON Finance Limited is incorporated in England and Wales, Company number 7251305 and authorised and regulated by the Financial Conduct Authority ("FCA"), FRN 525113.


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