Article 115
The Company, in proportion to the nature, scope and complexity of its activities, adopts and applies, and regularly
updates an effective policy for managing conflict of interest.
The policy from the preceding Paragraph of this Article shall contain:
1. established circumstances which represent or may lead to a conflict of interest to the detriment of one or more clients,
and in connection with an individual service provided by, or for, the Company.
2. if the Company is a member of a group, all circumstances known to the Company, or which should have been known,
and that can lead to a conflict of interest arising from the structure and business activities of other members of the group;
3. Procedures and measures that the Company is obliged to apply for managing conflict of interest that
may be at the expense of one or more clients.
Article 116
Procedures and measures for managing conflicts of interest must:
1. prevent or hinder any person to unduly influence the manner in which relevant persons are providing investment
services;
2. eliminate any direct links between income of relevant persons who are largely involved in one business activity, and
income or gain obtained by other relevant persons who are largely included in another business activity, if conflict of
interest may occur in connection with these activities.
3. preventing or providing the controlled exchange of information between relevant persons if the exchange of
information could be harmful to the interests of one or more clients.
4. preventing or providing supervision of the simultaneous or consecutive participation of relevant persons in different
services, if such participation could have a negative impact on conflict of interest management.
5. providing separate monitoring of relevant persons whose primary function includes business activities for a client, or
providing services to clients, whose interests may come into conflict or who in another manner represent different
interests which may be in conflict, including the interests of the Company itself.
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Article 117
The Company has a duty to, before provision of services, acquaint the client with the possible types and sources of
conflict of interest.
The notice referred to under Paragraph 1 this Article shall contain, taking into account the classification of clients,
sufficient information which will allow the client to make decisions with respect to services within whose framework
conflict of interest appears.
Article 118
The Company shall keep and regularly update information about the services conducted in the name of or on behalf of the
Company, in which conflict of interest appeared that may have adverse consequences for the interests of one or more
clients or, in the case of jobs underway, which may occur.
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