In the course of business, circumstances may arise whereby the interests of a client conflict with the interests of the firm, members of staff or the interests of another client. At Tilney, our overriding principle is that employees must always place clients’ interests first, before their own and those of Tilney or Tilney directors and employees.
Maintaining integrity, exercising good judgement and discretion are fundamental to support Tilney’s ability to demonstrate good governance and risk management over situations of conflict. Such situations may arise in the course of employee dealing, where Tilney employees undertake deals on their own behalf, or where our employees may give or receive hospitality from clients in the course of conducting business: Tilney has internal policies and processes in place to manage such situations. Investment advice and order execution services that are undertaken on behalf of our clients are also subject to policies and processes, ensuring suitability and best execution.
Tilney is committed to the fair treatment of all our clients.
When a Conflict of Interest has been identified, it must be reported to Risk and Compliance, who will provide guidance in terms of what actions are required to mitigate or manage the conflict and who will then record the conflict and how it has been addressed in the centralised register.
The Executive Committee supports Risk and Compliance in the oversight and management of Conflicts of Interest, specifically to receive and review the Conflicts of Interest register on a periodic basis, at least annually, and to review the nature and number of conflicts identified in order to consider any additional controls that should be put in place to ensure that clients’ interests continue to be put first.