Conflicts of Interest Policy
DRS Markets Limited (“We”) are authorised and regulated by the Financial Conduct Authority (“FCA”). We will manage all conflicts of interest in accordance with FCA rules and have put in place a conflicts of interest policy to ensure that our clients are not exposed to any risk. This policy applies to all directors and employees.
The FCA requires firms to adhere to Systems and Control “SYSC”. Section 10 of SYSC states to us:
- A firm must take all reasonable steps to identify conflicts with a client or between clients
- Keep and regularly update a record of the types of service or activity we provide that may give rise to a conflict
- Maintain and operate effective organisational arrangements with a view to prevent conflicts of interest or that may give rise to such a risk to a client
- Establish, implement and maintain an effective written conflicts policy
We have identified the types of conflicts that may arise and confirm that a conflict may arise where we are likely to make a financial gain or avoid a loss at the detriment of a client, where we have an interest in the outcome which is contra to what a client may wish for, where we put one client or the firm’s interest ahead of client’s interest, where we carry on the same business as the client, where we receive other from a client an inducement in the form of monies or goods other than the standard commission, where we design or market a product without informing the client of alternatives that may be more suitable and are in the interests of the client.
Systems and Controls that Guard against a Conflict of Interest
To avoid a conflict of interest we:
- Prohibit Personal Account Dealing unless permitted in accordance with FCA rules
- We do not provide personal recommendations or investment research that may influence our clients
- “ Know”our directors and agents may be in possession of confidential information such as a client’s trade position and this will not be disclosed. Directors and employees are required to handle information relating to a client whether personal details or trading information in strict confidence.
- We restrict access to information and electronic data by means of passwords and IDs. Our computers are locked down and directors and employees are reminded of data protection requirements.
- Gifts and inducements: we do not permit acceptance of gifts or an inducement which may influence our judgement or that could create a conflict with any client except in accordance with our gift policy (gifts and hospitality register). For example we would permit entertainment but not entertainment which is lavish or excessive.
- We segregate operations within the firm to ensure that roles do not conflict with our clients interests and our staff are regularly assessed for competency by undertaking prescribed FCA courses each year
- We encourage a Whistleblowing Policy and are committed that malpractice is prevented. Our staff are aware who they should report matters to internally.
- If we believe that a conflict cannot be identified we will inform the client and not proceed with the transaction, though believe our systems and controls will generally mitigate such an issue (if any).
Our Risk Disclosure Notice reflects our intention to disclose fully to each client of the risks arising and the fact that we also may take the opposite side of a client’s trade.
We regularly review our Conflicts of Interest Policy to make sure that it is current and covers those conflicts that may arise from time to time and any significant change to such a policy can only be signed off by the Board of Directors.