Conflict of Interest Policy
Introduction
At J. Knobel Investor Services Limited, we are committed to maintaining the highest ethical standards and ensuring that we act in the best interests of our clients at all times. This Conflict of Interest Policy sets out how we identify, manage, and disclose any conflicts that may arise during the course of providing our services. It also details how clients can raise concerns or submit complaints if they feel a conflict of interest has affected their service.
This policy is in compliance with the requirements set out under MiFID II, ESMA Guidelines, and CySEC regulations.
- What is a Conflict of Interest?
A conflict of interest may arise when the interests of J. Knobel Investor Services Limited, our employees, or other clients conflict with the best interests of a client. Examples of potential conflicts include, but are not limited to:
- Financial interests: Situations where our financial interests may influence the advice or service provided to a client.
- Employee relationships: Employees or representatives with personal or financial relationships with other clients or businesses that could impact their judgment.
- Third-party payments: Accepting fees or commissions from third parties that could affect the objectivity of our investment advice.
- Non-independent advice: Recommending limited investment products (e.g., a model portfolio) where a broader range of options could exist.
- Identifying Conflicts of Interest
We take proactive steps to identify conflicts of interest by:
- Monitoring all investment advice to ensure that recommendations are always in the client’s best interests.
- Maintaining a register of potential conflicts, reviewed regularly by our compliance team.
- Internal training and supervision to ensure that employees understand how conflicts can arise and how to avoid them.
- Managing and Mitigating Conflicts
To ensure that conflicts are managed and mitigated effectively, we employ the following procedures:
- Separation of duties: Different functions are assigned to separate employees to prevent conflicts from arising within roles.
- Disclosure: When a conflict of interest is unavoidable, we will disclose the nature of the conflict to you and explain how it could affect your interests.
- Fair treatment of clients: We prioritize the fair treatment of all clients and do not allow any conflicts to affect the quality of our services.
- Independence in advice: Even in cases where we provide non-independent investment advice (e.g., when recommending model portfolios), we ensure that all recommendations are suitable for the client’s needs and risk profile.
- Disclosure of Conflicts of Interest
If we identify a conflict of interest that could materially affect our ability to provide fair and objective services, we will:
- Notify you of the conflict in writing and explain how it may affect your interests.
- Provide you with options regarding how you would like to proceed in light of the disclosed conflict.
- Offer an alternative service or solution if necessary to avoid compromising the quality of advice or execution of your orders.
- Monitoring and Review
Our conflict of interest policy is regularly monitored and reviewed to ensure that it continues to meet regulatory standards and the needs of our clients. This includes:
- Annual reviews of the conflict of interest register and policy.
- Internal audits to assess the effectiveness of our procedures.
- Feedback from clients to identify areas where potential conflicts may have been overlooked.
- Client Complaints
We take client complaints regarding conflicts of interest seriously. If you believe that a conflict of interest has affected the quality of our service, you are encouraged to submit a formal complaint through our Complaints Form below. We will thoroughly investigate your concern and provide a response in line with regulatory timelines.
Complaints Form
If you have a complaint regarding a conflict of interest or any other aspect of our service, please complete the form below. We aim to resolve all complaints swiftly and fairly.