Conflict of Interest Policy

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Conflict of Interest Policy



Our Conflict of Interest Policy Template is designed for regulated entities, however it is suitable for any type of business. It can be customised by following the instructions in the enclosed “Terms of Use-Customisation Instructions” document.


The board of directors of a Cyprus Investment Firm (CIF) should define, oversee and is responsible for the implementation of the governance arrangements that ensure effective and prudent management of the Company, including the segregation of duties in the Company and the prevention of conflicts of interest, and in a manner that promotes the integrity of the market and the interest of clients.

A Cyprus Investment Firm (CIF) must take all reasonable steps to identify and to prevent or manage conflicts of interest between itself, including its managers, employees and tied agents, or any person directly or indirectly linked to it by control, and its clients or between one client and another, that arise in the course of providing any investment and ancillary services, or combinations thereof, including those caused by the receipt of inducements from third parties or by the CIF’s own remuneration and other incentive structures.

A CIF shall establish, implement and maintain an effective conflicts of interest policy set out in writing and appropriate to the size and organisation of the CIF and the nature, scale and complexity of its business. Where the CIF is a member of a group, the policy shall also take into account any circumstances, of which the CIF is or should be aware, which may give rise to a conflict of interest arising as a result of the structure and business activities of other members of the group.

The market abuse regulation (MAR) provides for a number of rules against certain conduct by persons who have in their possession “inside information”, rules in relation to the responsibility for disclosure of interest and conflicts of interest when producing recommendations and obligations of persons who professionally arrange transactions.

Areas Covered

Our comprehensive template covers the following areas:

  • The relevant legislation.
  • The objectives of the Conflict of Interest Policy.
  • The application of the Conflict of Interest Policy.
  • The identification of Conflicts of Interest.
  • The potential Sources of Conflicts of Interest.
  • How to manage Conflicts of Interest.
  • Information barriers.
  • Segregation of Company’s assets from client’s assets.
  • Policies and procedures – Training.
  • Remuneration Policy.
  • Separate supervision/functions.
  • Pay.
  • Inducements.
  • Personal account dealing (Personal Transaction).
  • Employees’ activities outside the Company.
  • Gifts.
  • Disclosure.
  • Declining to act.
  • Amendment / review.

What is included?

  • 19-pages Conflict of Interest Policy Template
  • Terms of Use-Customisation Instructions
  • Conflicts of Interest Register Template