Prevention of Conflict of Interest

In accordance with effective regulations, ABLV Bank, AS in liquidation (hereinafter referred to as the Bank) has developed and implemented Policy on prevention of conflict of interest in providing investment services and managing open-end investment funds (hereinafter referred to as the Policy) that is applicable to investment services and open-end investment funds management provided both by the Bank and ABLV Capital Markets, AS, and ABLV Asset Management, IPAS (hereinafter referred to as the Companies).

The Policy objective is to prevent occurrence of conflict of interest, i.e. inconsistency between the Bank (or the Companies, the Bank’s and the Companies’ employees and their related persons) and a customer (or customers) in connection with property rights or other interests that arise or may arise under rendering of investment services or supplementary investment services or under open-end investment fund management performed by the Bank or the Companies, where the Bank’s or the Companies’ action or failure to act results in losses for the customer or causes other adverse effects, or the customer is given priority or provided privileges at the expense of other customers.

The Policy principles provide for the following:

  • employees of the Bank and the Companies are responsible for avoidance of conflict of interest and also have to inform responsible persons at the Bank and the Companies about possible conflict of interest;
  • in their relations with customers, the Bank and the Companies ensure equality of rights, good faith, and veracity, informing customers on all transactions involving the customer’s financial instruments and funds, as well as on associated risks;
  • the Bank and the Companies do not take advantage of the customer’s incompetence or condition, and they also provide equal professional services to all customers, regardless of their ethnic group, gender, political or religious views;
  • in any case, the customer’s interests are given priority over interests of the Bank or the Companies and their employees.

For prevention of conflict of interest, the Bank and the Companies use the following methods:

  • identification and assessment of conflict of interest situations;
  • control (supervision) of identified conflict of interest situations;
  • avoidance of conflict of interest;
  • disclosure of conflict of interest.

More detailed information about the policy on prevention of conflict of interest can be supplied to the client upon specific request.