Compliance Risk Management: CFM Indosuez Wealth Protects Clients’ Interests

Implementing a Comprehensive Conflicts of Interest Policy

In line with Monegasque regulations, CFM Indosuez Wealth has implemented a comprehensive conflicts of interest policy to ensure the integrity of its operations and protect its clients’ interests. The Bank’s approach is guided by the principles of loyalty, fairness, competence, and diligence.

Compliance with Prudential and Good Conduct Rules

According to Law No. 1.338 of 07 September 2007 on Financial Activities, authorised companies such as CFM Indosuez Wealth are required to comply with prudential and good conduct rules aimed at guaranteeing the protection of investors and the regularity of transactions. The Bank’s conflicts of interest policy is designed to identify potential situations that may affect its clients’ interests and to manage these situations in a way that prioritizes clients’ needs.

Identifying Conflicts of Interest

The Bank has identified several types of conflicts of interest, including those arising from:

• Personal considerations
• Pressure from third parties

Situations that may generate conflicts of interest include:

• Where the Bank or an individual linked to it stands to gain financially at the expense of a client
• When the Bank has an interest in the outcome of a service provided
• When the Bank is encouraged to prioritize another client’s interests

Organisational Structure and Internal Procedures

To identify potential conflicts of interest, CFM Indosuez Wealth has established:

• An organisational structure
• Internal procedures and controls
• Staff training through its Code of Conduct and related presentations
• Segregation of tasks and activities to minimize the potential for conflicts

Detection and Management of Conflicts of Interest

The Compliance Department plays a key role in detecting and managing potential conflicts of interest, particularly during participation in various committees that govern the Bank’s operations. Members of the Board of Directors and Authorised Management are required to:

• Report all mandates they hold
• Specify why they do not believe they are affected by conflicts of interest

Managing Conflicts

In cases where conflicts arise, CFM Indosuez Wealth’s Head of Compliance is responsible for:

• Putting into practice the principles of primacy of clients’ interests over those of the Bank or linked individuals
• Reporting to line managers and the Head of Compliance
• Proposing solutions based on client interests
• Recording the conflict in a specific register

Commitment to Client Protection

The implementation of this policy aims to inform clients of the possibility that conflicts of interest may arise and provide them with an opportunity to refer to a specialised function within the Bank. CFM Indosuez Wealth is committed to ensuring compliance with fundamental ethical principles and protecting its clients’ interests through effective risk management practices.