This conflicts of interest policy forms part of the agreement between you and Huddlestock Systems and you and DAB BNP PARIBAS . References in this conflicts of interest policy to
“we”, “us”, or “our” are references to Huddlestock Systems and DAB BNP PARIBAS together, except where the context requires otherwise.
We have to establish, implement, and maintain a written conflicts of interest policy. We have arrangements in place to identify, monitor, manage and resolve conflicts of interests that may arise between you and us, or two or more of our clients, to ensure they do not damage our clients’ interests. This policy highlights the potential conflicts of interest that may arise and how we intend to deal with them.
2. Types of conflict
Conflicts of interest may occur between you and us in situations where we:
are likely to make a financial gain, or avoid a financial loss, at your expense;
have an interest in the outcome of a service provided to you or of a transaction carried out on
your behalf, which is distinct from the your interest in that outcome;
have a financial or other incentive to favour the interest of another client or group of clients
over your interests;
carry on the same business as you; or
receive or will receive from a person other than you an inducement in relation to a service
provided to you, in the form of monies, goods or services, other than the standard commission or
fee for that service.
Conflicts of interest may also arise between you and one or more of our clients where your interests
3. Policies and procedures
We have adopted policies and procedures to manage potential conflicts of interest, identify new conflicts of interest as they emerge and ensure your data remains safe and secure. We maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to prevent the conflicts of interest set out above from giving rise to a material risk of damage to your interests as a client.
Our employees receive guidance on these policies and procedures and our senior management are responsible for ensuring that our systems, controls and procedures are robust and adequate to identify and manage any conflict that may arise.
We have effective procedures in place to prevent and control the dissemination or exchange of information that may harm the interests of our clients.
In the circumstances where our internal functions involve carrying out activities or services for clients who represent different interests that may conflict, we will ensure that separate supervision and reporting lines are in place in respect of those internal functions.
If our policies and procedures do not ensure a sufficient level of independence, then we will make sure that additional or alternative measures are adopted and practiced to reduce any risk of damage to the interests of our clients.
Where we think it is necessary to establish and maintain an information barrier to protect certain information, we will do so. Where an information barrier has been established and is being maintained, we may withhold and not use the information held and we may permit employees (including directors) to do the same.
We maintain an up to date register of all conflicts and how these are managed so that we can control potential conflicts and provide an effective way of preventing clients’ interests being unfairly affected. This is in addition to our general records which we keep to demonstrate compliance with our conflicts of interest requirements.
5. Examples of conflicts that may arise
5.1. Investment Ideas
Strategy vendors may contract with Huddlestock Systems to provide investment strategies and investment research to Huddlestock Systems. Huddlestock Systems then reviews those investment strategies or the investment research to create its own investment ideas that are promoted to our users. A strategy vendor could also be a user and vice versa. Potential conflicts of interests could, therefore, arise between our strategy vendor clients and our other clients and between Huddlestock Systems and its clients. To manage this conflict of interest our financial analysts who review the investment strategies and research and, if suitable, prepare the investment ideas, will not be supervised by, and will not report to, our sales and distribution staff or the trading team. There will be physical separation between these teams to enhance the information barriers, restricting the flow of information and achieving functional separation.
5.2. Order aggregation
We may decide to aggregate your order with those of other clients in order to obtain the best results for those trades by, for example, reducing the cost of the overall trade or increasing the speed of the trade. All trades are made in accordance with our best execution policy, and we will not aggregate a trade to the advantage of any client over another. best
execution policy, and we will not aggregate a trade to the advantage of any client over another.
5.3. Distribution of investment ideas
A conflict of interest could arise if we only distributed investment ideas to selected clients. We manage this conflict by ensuring our investment ideas are distributed to all clients who have an investment mandate which matches the particular investment idea and for whom such an investment idea is suitable. The investment idea will be distributed to the relevant clients at the same time, and each client will have the same length of a decision window in which to decide whether to follow the investment idea.
5.4. Broker relations
A conflict of interest may arise where we choose third-party brokers to execute your trades based on criteria which may benefit us to a greater extent than providing you with the best possible result for your trades. We will mitigate this risk by ensuring that we only follow the selection criteria set out in our best execution policy when choosing the third-party brokers to execute your orders, and we will not select a third-party broker solely based on the amount of any fees or commission we may or may not receive.
5.5. Dealing ahead of investment idea distribution
A conflict of interest may arise where our financial analysts circulate an investment idea to our employees before it is disseminated to our users. We manage this conflict of interest by ensuring that our financial analysts do not disclose the timing or content of an investment idea to our sales and distribution staff before the investment idea is disseminated to our clients. There is a prohibition on our employees dealing ahead of an investment idea being published on our website.
5.6. Inducements, gifts and benefits
If any of our employees receive gifts, entertainment or other forms of hospitality this could lead to a potential conflict between the interests of the donor and the recipient of the hospitality and the interests of one or more of our clients. We have a policy in place requiring our employees to declare and seek approval for any form of gift or entertainment over a certain level in order to ensure we maintain impartiality. We will not accept inducements or other benefit from anyone with a material interest in the subject matter of the strategy, including a vendor that has produced a particular strategy.
We will only accept reasonable non-monetary benefits from product providers where permitted to do so and will disclose these to clients where regulations require us to do so.
A conflict of interest may arise if any of our employees were paid based on investment performance. We pay our employees a basic salary, and our employees will not be paid based on the performance of the underlying financial instrument about which they have either produced or disseminated an investment idea.
To ensure independence within our teams, we have also removed any direct links between the remuneration of one team to another where such a link may give rise to a conflict of interest.
We also operate a discretionary bonus scheme which is based on the company’s performance, the employee’s department’s performance and/or individual performance. We ensure our bonus arrangements do not cause conflicts of interest.
5.8. Personal transactions and other outside business interests
Our employees may trade securities or other instruments for their own account, which could put those employees or us in conflict with the interests of one or more of our clients. We manage this potential conflict of interest through our personal account dealing policy. Our personal account dealing rules also seek to prevent market abuse. Our employees will not trade in any security or financial instrument about which they possess confidential, non-public information.
Our employees may hold outside business interests, such as directorships or shareholdings, in service providers or other firms. This could create a conflict between the personal interest of the employee and our client(s). That is why we require all employees to disclose all outside business interests to us.
5.9. Single product provider
A conflict of interest could arise if we entered into an arrangement with a product provider to only invest in their products. This could prevent us from obtaining the best possible result for you. Currently we have no such an arrangement.
5.10. Developing and maintaining our technology
We are a technology company and we will always look to develop and enhance our technology to provide you with the best possible service. We may accept payments from third parties (including product providers) for developing facilities that enable us to integrate with the third parties’ technology. We will only do this where we expect to generate cost savings for us and our clients, it does not impair our duty to act in your best interests and we reasonably expect the quality of service you receive will be enhanced.
Client information security
- We will not use your information other than to provide you with our services. We do not share your specific information with any third party without your consent, except where we are required to do so by law or regulation. Please refer to our Data Protection Policy for details.
5.12. Client complaints
All complaints are handled impartially and our employees are not incentivised based on the outcome of
the complaint and do not have an interest in a certain outcome.
6. Disclosure and declining to act
- 6.1.We will notify you [by email or through your account portal] in the event that we are unable to
sufficiently manage a conflict of interest. This will enable you to consider whether it is appropriate to
continue using our services in respect of the relevant conflict.
- 6.1.We will notify you [by email or through your account portal] in the event that we are unable to
7. Client complaints
- 7.1.All complaints are handled impartially and our employees are not incentivised based on the outcome of the complaint and do not have an interest in a certain outcome. Please refer to our Terms of Business with regards to how to file a complaint.
8. Disclosure and declining to act
- 8.1.We will notify you [by email or through your account portal] in the event that we are unable to sufficiently manage a conflict of interest. This will enable you to consider whether it is appropriate to continue using our services in respect of the relevant conflict.
- 8.2.We may inform you of our decision not to act on your behalf where we consider there to be no alternative option.