Conflict of Interest | Connective Lending

Introduction

Connective Lending is responsible for taking all reasonable steps to identify and manage any conflicts of interest in the business that might arise, in particular in relation to the operation of the Platform. We are obliged to maintain and operate arrangements to prevent any conflict from giving rise to a material damage to the interests of Connective Lending Members.

Connective Lending is a company that wishes to attain the highest standards of ethical behaviour and is proud of its reputation. We are committed to maintaining the highest of ethical standards and complying fully with our regulatory and legal obligations.

We must also establish, implement and maintain an effective conflicts of interest policy. This document is our conflicts of interest policy (“Conflicts Policy”) in so far as it applies to the operation of the Platform.

Identification of Potential or actual Conflicts

A conflict that arises, or may arise, in the course of providing a service and whose existence may entail a material risk of damage to the interests of a client, Connective Lending Limited will take into account, as a minimum, whether the company or a relevant person or any person directly or indirectly linked to them by control to Connective Lending Limited:

(1) Is likely to make a financial gain, or avoid a financial loss, at the expense of the client.
(2) Has an interest in the outcome of a service provided to the client or a transaction carried out on behalf of the client which is distinct from the client’s interest in that outcome.
(3) Has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client.
(4) Carries on the same business as the client.
(5) Receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monies, goods or services other than the standard commission or fee for that service.

Gifts and Entertainment

The issue of inducements, gifts and hospitality can also introduce an element of Conflict into the business. We have strict policy regarding such issues.

Employees

A conflict of interest may arise where an employee has a direct or indirect interest in a transaction. This may include where the employee has a connection with the other party to the transaction or where the employee’s family has such a connection – in particular a connection with a Member. Employees are required to disclose any connection which could, or could be seen to have the effect of compromising the judgment of any employees. Employees are required to notify us of any material interests of this kind that they may have.

Managing Conflicts of Interests and Disclosure

Connective Lending shall use all reasonable efforts to manage conflict of interest. We maintain appropriate systems and controls and ongoing monitoring to identify conflicts which arise.

If we believe there is a significant risk of damage to Members we will consider appropriate disclosure.

Further Information

We will maintain and update the Conflict of Interest policy. Questions regarding this policy should be emailed to: customerservice@connectivelending.com