Conflict of Interest

Introduction

In accordance with applicable regulations, Shares Financial Assets ("SFA", "we" or "us") has established a policy that aims to prevent and manage conflicts of interest, which may arise when providing investment services or related services, or a combination of both, to one or more of its clients.

Regulatory references :

• Decree of 25 February 2021 amending the Decree of 3 November 2014, Article 38.

REGULATION (EU) 2017/565, articles 29 section 3, art 33, 34, 35 and 39.

Definition

A conflict of interest is defined as: “a conflict / competition between a number of interests that may negatively affect outcomes in the course of the business”. SFA has set up a framework under the responsibility of Investment Services Compliance Officer (ISCR), who independently ensures that preventive and control measures are implemented to deal with conflicts of interest.

Various conflict of interest situations are likely to arise in the course of SFA's business.

• Conflict of interest between the company and a client
• Conflict of interest between an employee and a client
• Conflict of interest between a partner or business relationship and the company or customers
• Conflict of interest between two clients

Prevention

SFA ensures that its employees comply with the professional obligations to which they are subject in the exercise of their missions, as well as with the regulatory obligations applicable to these activities. This framework operates at several levels.

Internal rules and professional ethics

SFA's code of conduct, to which all its employees are subject, aims to ensure compliance with the principles relating to the primacy of clients' interests and the prevention of conflicts of interest. Every SFA employee is obliged to behave loyally and act fairly in the interests of clients, while respecting the integrity, transparency and security of the market.

Risk Mapping and Register

SFA has identified certain situations that could give rise to a conflict of interest, taking into account its size, the organisation of the company and the nature and complexity of its activities.  Conflicts of interest are also recorded in a register, which is updated when an event occurs and lists the remedial measures taken by SFA.

Control framework

With its second and third lines of defences, permanent internal control and independent outsourced periodic control, SFA controls the following matters :

• Separation of business lines
• Circulation of confidential information
• Compliance with specific provisions related to personal account dealing, especially by employees with sensitive information or roles
• Risk mapping of the conflicts of interest
• Registration of all conflicts of interest encountered

Client information

In the event that SFA finds that the measures implemented are insufficient to guarantee, with reasonable certainty, that the risk of harming the interests of our clients can be avoided, SFA will clearly inform the client in question, in sufficient detail and on a durable medium, before acting on his behalf, of the general nature and/or source of these conflicts of interest so that the client can make an informed decision.

Policies and procedures

In addition to this policy, SFA has put in place a comprehensive system to prevent and/or manage conflicts of interest:

• A compliance monitoring plan
• A whistleblower protection policy
• Staff training
• An anti-bribery and corruption policy
• A complaints handling policy

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