Tuileries

Conflicts of Interest

 Conflicts of interest register

 Subject 

 Personal securities trading 

 This document sets forth possible cases where conflicts of interest may arise at ASW

 Circumstances in which a conflict of interest could arise 

 Risk mitigants 

Personal trades executed by ASW employees, with the inherent risk that they give precedence to their own transactions or improperly use confidential or insider information 

Internal rules and personal trades carried out by staff monitored. 

 Personal securities trading 

Best execution policy 

In cases where ASW acts as broker, trades executed in violation of the principles laid down in the best execution policy for orders, leading to preference being given to ASWs interests over those of the Client

Two-tier controls applied to the main brokerage desks of the ASW. 

 Error management 

Poor diligence in error management with a view to avoiding financial losses within ASW or at entities of ASW. 

ASW records each incident in a database, using which it can take all necessary measures depending on the risks represented by each incident as far as both ASW and Clients are concerned.

 Error management 

Poor diligence in error management with a view to avoiding financial losses within ASW or at entities of the ASW. 

ASW records each incident in a database, using which it can take all necessary measures depending on the risks represented by each incident as far as both the Bank and Clients are concerned.

 Extra custodian services 

Asset management/Product selection 

Front-office incentives 

Churning 

Front running 

Insider information 

Acceptance/payment of benefits by the Bank 

Acceptance of benefits or gifts by staff 

Central Administration services within the ASW 

Clients offered services that are not needed or do not provide an obvious financial benefit, as a way of earning extra commission. 

ASW reviews new relationships and ensures that the services offered are in keeping with Clients’ expectations and ASWs own capabilities.

 

Services provided to Clients are furthermore subject to clearly defined contract terms. 

In cases where ASW also provides portfolio management or investment advisory services, or other products: the risk of giving preference to the ASW products over those of third parties that could be more beneficial. 

ASW reviews new relationships and ensures that the services offered are in keeping with Clients’ expectations and ASWs own capabilities.

Services provided to Clients are furthermore subject to clearly defined contract terms. 

Bonuses paid to the sales staff of the ASW, which might be heavily influenced by the sale of specific products, thus leading to transactions that are not necessarily in the  Client’s interest. 

The remuneration policy regarding these employees is based on several objective criteria. As such, employees have full freedom to offer those products best suited to the Client’s needs. Monitoring of asset breakdowns, especially in terms of portfolio concentration. 

Commissions generated by the excessive buying and selling of financial instruments (i.e. churning) against the interests of Clients. 

Portfolio rotation monitored to detect possible cases of churning. 

“Front running” trades conducted by ASW employees. 

Directive on personal securities trading by staff, with half-yearly audit of at-risk transactions. 

Use of insider information by ASW or its employees. 

An internal directive lays down specific risk-avoidance measures. ASW  has no investment banking business. 

Acceptance by ASW, or payment to business partners, of shared commission. 

Client receives written information in cases where this is applicable; strict compliance with MiFID rules. The Investment Committee takes no account of commission-sharing amounts in its analyses, and advisory services cannot be influenced by commission sharing nor by the level thereof. 

Acceptance by ASWs employees of gifts that may sway their impartiality. 

Internal rules limiting scope for accepting gifts. 

Poor diligence or lack of independence in the monitoring of investment management / central administration activities within ASW, resulting in the interests of ASW’s entities being favoured over those of Clients. 

Internal rules and Code of Conduct in place for safeguarding independence, monitoring outsourced operations and ensuring separation in terms of roles, reporting line and contractual relationship within the ASW.