CIPR 3.5.2 Conflicts of interest and material interests — policy

(1) An authorised firm must have, and must operate in accordance with, a policy on conflicts of interest and material interests. The policy must be appropriate to the nature, scale and complexity of the firm's regulated activities.
(2) The policy must have been approved by the firm's governing body and must be recorded in a durable medium. The policy:
(a) must identify, with reference to the regulated activities carried out by or on behalf of the firm, the circumstances that constitute or may give rise to conflicts of interest or material interests that create a risk of damage to its customers' interests; and
(b) must set out systems and controls to manage actual and potential conflicts of interest and material interests.

An authorised firm should also consider whether there are circumstances in relation to licensed but unregulated activities that might give rise to conflicts of interest in carrying out regulated activities.
(3) The systems and controls must ensure that the firm's customers are not adversely affected or treated unfairly because of a conflict of interest or material interest.
Derived from QFCRA RM/2019-2 (as from 1st January 2020).