Conflict of Interest Policy
The nature of the financial services market frequently gives rise to conflicts of interest. When we provide advice, make recommendations, arrange transactions, or act on the client's behalf, we, or another entity associated with or connected to us, may have a material interest, relationship, or arrangement related to the investment, transaction, or service concerned. We endeavour to ensure that no conflict arises, but if it does, we will seek to manage it fairly and always act in the client's best interests.
If conflicts are not properly identified and managed, they could lead to a loss of revenue, damage to our reputation, legal action, public censure, or a fine from the regulator against the firm and relevant employees. It is essential to identify and manage conflicts of interest that may arise in the course of providing a service, as their existence can lead to a material risk of harm to a client's interests. This document outlines Axis Financial Consultants' policy for effectively managing conflicts of interest that may arise when providing services to clients while engaging in regulated activities.
Whilst detailed, the policy is not intended to be a comprehensive list of all conflicts and/or situations which may give rise to such conflicts. Inevitably, circumstances will arise that are not specifically covered. A conflict may arise whenever two or more parties have differing interests in an undertaking. Conflicts may arise between a firm's interests and those of a client, between two or more clients, or even between a firm's employees and clients.
The following list outlines some of the circumstances in which conflicts may arise. This list is not exhaustive; we monitor all areas to identify potential conflicts of interest. The circumstances which should be treated as giving rise to conflicts of interest include all cases where there is a conflict between the interests of Axis Financial Consultants, a member of staff, certain persons directly or indirectly connected to Axis Financial Consultants, and the duty Axis Financial Consultants owes to a client. All staff must take into account whether any of the persons described above:
Is likely to make a financial gain or avoid a financial loss at the expense of the client
Has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client's interest in that outcome
Has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client
Carries on the same business as the client
Receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monies, goods or services, other than the standard commission or fee for that service
No employee may accept from or give to any person any gift or other benefit that cannot properly be regarded as justifiable in all the circumstances. Staff members may not accept gifts from, or provide gifts or inducements to, an individual or firm with whom they conduct, or intend to conduct, business on behalf of Axis Financial Consultants unless it can be demonstrated that doing so creates no conflict of interest.
Entertainment accepted by a member of staff should be appropriate and not create a conflict of interest. This rule applies even if the direct recipient of the gift or other benefit is the employee's spouse or a child of the employee. The provision or acceptance of gifts and entertainment should be consistent and proportionate to the nature of the corporate relationship.
How staff members are remunerated is also considered to ensure that remuneration structures do not create a conflict between the incentives given to staff and the best interests of clients.
Members and employees may only undertake personal investment activities that do not breach applicable laws or regulations, do not unduly distract from their employment responsibilities, and do not create an unacceptable risk to the company’s reputation. Transactions should also be free from business and ethical conflicts of interest. Employees must never misuse proprietary or client-confidential information in their personal dealings and must ensure that clients are never disadvantaged as a result of their interactions.