Conflict of interest Policy

Rigensis Bank AS (hereinafter referred to as the “Bank”) performs all the necessary and practicable measures to identify and prevent conflicts of interest that might arise among the Bank, its employees, the customers or counterparties in transactions in the course of provision services. The management and employees of the Bank perform out their duties with the utmost good faith, maintain objectivity in dealings and decision making and observe regulatory requirements and high ethical standards.

The Bank’s Council approved the Policy for the Prevention of Conflicts of Interest in Provision of Investment Services and Ancillary Investment Services whereby the measures for the identification, prevention and management of the conflicts of interest are defined.

In providing investment services, it is the obligation of employees of the Bank to comply with the Policy for the Prevention of Conflicts of Interest in Provision of Investment Services and Ancillary Investment Services (hereinafter referred to as the “Policy”) and take care of the protection of the customer interests and equal treatment of all customers of the Bank.

A conflict of interest may arise in any field of banking operations between the customer and Bank, its employees, counterparty and persons who are directly or indirectly linked with the Bank, or between two or more customers.

In the Policy, the Bank defines the following main types of a conflict of interest situations or activities when conflict of interests can arise:

  • In the provision of investment services and ancillary (non-core) investment services:

    • In executing customer orders concerning transactions with financial instruments and simultaneously carrying out transactions with financial instruments on their own account,
    • In selling and buying financial instruments on behalf of the Bank simultaneously with the execution of customer orders.
    • Providing incomplete or inexact information on the investment services and ancillary (non-core) investment services that the Bank provides, on the essence of a specific transaction or of a type of transaction, on the possible risks and results,
  • Where the aim of the activity (operation, provision or non-provision of information) is to prevent (to reduce) the gain or the loss of a financial (material) benefit regarding one of the counterparties (employee, customer or persons linked with them),
  • Where an employee carries out his/her own private transactions on the basis of the information which has become available while performing the duties of the job at the Bank.
  • In several other cases, in connection with the Bank employees, their job performance and the possible prevalence of personal interests over the interests of the Bank.

While cooperating with the customers, the Bank complies with the principles of equal rights, good faith and veracity, and provides services on the basis of the concluded contracts, confirmed rates and open regulations. The information that the employees provide to the counterparties, customers and potential customers shall be clear, exact, true and not misleading.

The conditions of banking transactions that are performed with the persons who are linked with the Bank and with other employees authorised to be involved in the programming of the banking operations, the management and control of the Bank and are responsible for them, as well as with their spouses, parents, children and commercial companies where these persons are substantially involved, do not differ from the conditions of similar transactions that are carried out with the persons who are not linked with the Bank and do not contradict the interest of the Bank.

The Policy imposes restrictions and prohibitions on the distribution and use of inside information and commercial information. In order to ensure a timely identification and prevention of a possibility that a situation arises where there is a potential conflict of interest, the Bank has established an appropriate organisational body, has developed a strict procedure of transaction execution, set the principles by which duties are distributed among the employees and has defined the restrictions on decision making, as well as created mechanisms for the governance of confidential (classified) information (the “Chinese Walls”) which reduce the risk of unauthorised use of confidential information or of the information that may have an impact on the price of the respective financial instrument.

The employees of the Bank abstain from taking outside jobs and of holding more than one job, as well as from undertaking commercial activities if these can give rise to the suspicion of a potential, virtual or real conflict of interest with the Rigensis Bank AS or in a private undertaking. The Bank ensures that the organisational units which carry out transactions and among which a conflict of interest arises or may arise are mutually independent.

The employees of the Rigensis Bank AS perform their duties professionally and avoid the situations of the conflict of interest but in case such situations should arise, inform about them and disclose them in compliance with the established procedure. The employees decline any gifts from counterparties or customers unless these are souvenirs by nature, and do not accept invitations to participate in an event if there is a suspicion of a potential conflict of interest or of damage to the reputation of the Rigensis Bank AS.

The Bank tends to direct its activities towards the best unconditional protection of customer interest, the professional performance of duties and services. The Bank shall ensure the provision of information to the customer in the event where it is impossible to prevent a conflict of interest and there exists a probability that the interests of the customer may be subject to an impact.