1. Identifying conflicts
We identify the circumstances that give rise, or may give rise, to a conflict of interest capable of damaging the interests of one or more clients, taking into account the services provided and the structure of the firm and its group.
2. Conflicts between ASTEO and the Client
Conflicts may arise where the firm, a director, an employee or a tied agent could gain, or avoid a loss, at the expense of the Client. Such situations are managed as a priority in the Client's interest.
3. Conflicts between clients
Where the interests of different clients conflict, we take measures to ensure fair treatment and to avoid unduly favouring one client over another.
4. Remuneration and incentives
Remuneration systems are structured so as not to incentivise conduct contrary to clients' best interests and not to create a direct link between staff pay and the sale of specific products.
5. Relationships with providers and partners
Relationships with counterparties, providers and partners are conducted on market terms and are subject to assessment of the potential conflicts that may result.
6. Orders and execution
The execution and aggregation of orders are governed so as not to disadvantage any client and in accordance with the Order Execution Policy.
7. Confidential information
We apply information barriers and access controls to prevent the improper flow of confidential or inside information between functions and individuals.
8. Gifts and inducements
Gifts, hospitality and non-monetary benefits are subject to limits, authorisations and recording, so that they cannot influence the objectivity of decisions.
9. Organisational measures
We apply segregation of functions, independent supervision, personal-transaction rules for staff and regular training as measures to prevent and mitigate conflicts.
10. Recording of conflicts
We maintain and update a register of identified conflicts and the related management measures, subject to periodic review by the Compliance function.
11. Disclosure to the Client
Where organisational and administrative arrangements are not sufficient to ensure with reasonable confidence that the risk of damage to the Client's interests is prevented, we disclose to the Client, before acting on their behalf, the nature and source of the conflict and the measures taken to mitigate it.
Questions on this document?
Write to our Compliance function at compliance@asteo.eu or to our Data Protection Officer at dpo@asteo.eu. Postal correspondence: ASTEO LUXEMBOURG S.A., 120 Boulevard de la Pétrusse, L-2330 Luxembourg, Grand Duchy of Luxembourg.
This document is provided for information purposes and constitutes a professional draft pending validation by ASTEO's Legal and Compliance function. In the event of any discrepancy between language versions, the English version prevails unless mandatory local law requires otherwise.
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