Conflicts of Interest Policy
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Era Finances Group is committed to acting in the best interests of its clients at all times. This policy sets out our framework for identifying, managing, and where necessary disclosing conflicts of interest that may arise in the conduct of our business across all operating entities and jurisdictions.
Scope
This policy applies to Era Finances Group Ltd and all its regulated subsidiaries, including Era Finances Capital Management (FCA), Era Finances (Hong Kong) Limited (SFC), Era Finances Private Investment (CSSF), Era Finances Family Office Services (FINMA), and Era Finances Trading Strategies (CIMA).
What Is a Conflict of Interest?
A conflict of interest arises when the interests of Era Finances Group, its employees, or its affiliates diverge from the interests of a client, or when the interests of one client diverge from those of another client.
Common sources of conflicts include: proprietary trading alongside client portfolios; receipt of third-party inducements; cross-selling of group products; personal account dealing by employees; and the allocation of investment opportunities across multiple client mandates.
Identification of Conflicts
Era Finances Group maintains a Conflicts Register, updated at least annually and whenever a new business activity or relationship is established. The Head of Legal & Risk is responsible for maintaining the register and for escalating material conflicts to the Board.
Management of Conflicts
Where a conflict is identified, Era Finances Group will seek to manage it through one or more of the following measures.
Information Barriers
Physical and procedural barriers are maintained between business areas that handle information that could give rise to conflicts. Access to sensitive information is restricted on a need-to-know basis.
Independent Oversight
Material conflicts are subject to independent review by the Compliance function or, where appropriate, by the Board or an independent committee.
Personal Account Dealing Controls
All employees are subject to a Personal Account Dealing Policy that restricts trading in securities held in client portfolios. Pre-clearance is required for all personal account transactions in relevant securities.
Fair Allocation
Investment opportunities are allocated across client mandates in accordance with a documented allocation policy designed to ensure fair and equitable treatment.
Remuneration Structures
Employee remuneration structures are designed to avoid incentivising behaviour that is contrary to client interests. Variable remuneration is subject to risk adjustment and deferral arrangements.
Disclosure of Conflicts
Where a conflict of interest cannot be adequately managed, Era Finances Group will disclose the nature of the conflict to the affected client before undertaking the relevant business. Disclosure will be made in writing.
Third-Party Inducements
Era Finances Group does not accept inducements from third parties that are not permitted under applicable regulation. All material inducements are disclosed to clients.
Multi-Family Office Arrangements
In the context of multi-family office services, conflicts may arise between the interests of different client families. Era Finances Family Office Services manages such conflicts through strict segregation of client information and transparent disclosure.
Review and Training
This policy is reviewed at least annually by the Head of Legal & Risk and approved by the Board. All relevant employees receive training on conflicts of interest identification and management.
Compliance Enquiries
[email protected]