Conflict of Interest Policy




1. Introduction business

International House of Business LLC. (hereinafter “HFCM”) is required to maintain and operate effective organizational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage conflicts of interest. HFCM has put in place a policy to safeguard its clients’ interests. The key information is summarized below. Detailed information is obtainable on request from the client’s Account Manager.

2. Our Conflicts of Interest Policy

HFCM is a capital management company specialized in, Asset management, Managed accounts and investment advisory services. Like any capital management company, HFCM is potentially exposed to conflicts of interest in relation to various activities. However, the protection of our clients’ interests is our main concern:

3. Conflicts of interest

Conflicts of interest’ are impossible to rule out. Our policy defines conflicts of interest as:

We have identified such conflicts of interest in our business. These could include:

4. Our measures

The measures we have adopted to manage identified conflicts are summarized below. We consider them appropriate to our efforts to take reasonable care that, in relation to each identified potential conflict of interest, we act impartially to avoid a material risk of harming your interests.

       

    a. Policies and procedures

We have adopted many policies and procedures throughout our business to manage potential conflicts of interests. Our employees receive guidance and training in these policies and procedures, and they are subject to monitoring and review processes.

   b. Information barriers

Our employees respect the confidentiality of client information and do not disclose it or use it inappropriately. For particularly sensitive cases, we have established walls and adopted wall procedures to prevent unauthorized exchange of information between employees and to organize the separation of staff members concerned.

   c. Separate supervision/functions

Two departments or businesses which, if run together, could encounter conflicts of interest will be managed by different senior staff members.

   d. Pay

Pay and bonuses are linked to the profits of HFCM or the business or department where an employee works. Pay and bonuses linked to the performance of another department, with possible conflicting interests, will be avoided at all times.

   e. Inducements

Inducements from third parties in relation to a service provided to you are acceptable to HFCM only if (1) the inducement is disclosed to you and (2) it is either the payment of a normal fee or commission to continue the quality of our services to you and does not impair our duty to act in your best interests.

   f. Personal account dealing

To prevent conflicts arising from the use of information obtained from clients, and market abuse in general, all employees are subject to personal account dealing rules.

   g. Employees’ activities outside HFCM

Our employees are subject to rules designed to avoid conflicts of interest with activities they undertake outside HFCM

   h. Gifts

HFCM employees will not accept any gifts other than those considered normal in their line of business. Excessive gifts from clients may result in a conflict of interest, something we are committed to avoiding.

   i. Disclosure

Where there is no other way of managing a conflict, or where the measures in place do not sufficiently protect your interests as a client, the conflict will be disclosed to allow you to make an informed decision on whether to continue using our service in the situation concerned.

   j. Declining to act

We may decline to act for a client in cases where we believe the conflict of interest cannot be managed in any other way.