Conflict of Interest Policy

Last updated: 27 February 2025

1. Introduction

Multrees Investor Services Limited (“Multrees”, “the Company”, “the Firm”) offers custody and administration services to Investment Adviser Clients (“Clients”) and underlying retail customer (“Customers”) and can find itself in a situation where the interests of one Customer or Client may be in competition with those of another, or where the interests of a Customer or Client may be in competition with the interests of Multrees, or members of staff at Multrees.

It is Multrees’ policy to take all reasonable steps to identify and manage conflicts entailing a material risk of damage to a Customer’s interests.

Senior management within Multrees are responsible for ensuring that the systems, controls and procedures are adequate to identify and manage conflicts. Compliance assist in the identification and monitoring of actual and potential conflicts.

Definition and Scope

Conflicts of interest arise when personal relationships, access to information, or financial interests have the potential to impair an employee’s impartiality or professional judgment. Multrees employees are expected to act with honesty and integrity, ensuring that decisions remain impartial and free from bias.

All employees, full-time, part-time and contractors / temporary, are within scope of the provisions of this policy. In scope conflicts are those between Multrees and Clients, Customers or Staff, and also between any of these parties. When the policy refers to Customers, it should, depending on context, be viewed as referring to Clients as well.

Key Points to Note

The following are the high level points to note for this policy:

Staff who believe they may have a conflict of interest with Multrees, third party providers (Suppliers), Clients or Customers should consult Compliance;
Staff must declare any directorships, employment, or other relevant relationships which could give rise to conflicts of interest impacting Multrees.
Barring ‘de minimis’ levels, gifts and hospitality given or received must be pre-approved where possible and logged centrally;
Receipt of hospitality from Suppliers or potential Suppliers is prohibited unless it meets criteria described in this policy. Approval may be required, and gifts and hospitality should be logged as appropriate;
Staff are limited in the value of gifts and hospitality they may receive in a calendar year;
In scope PA deals (e.g. trades in shares, bonds or ETFs) must be approved by Compliance prior to execution;
Detailed procedures are available on SharePoint.

As a common platform firm, the regulatory requirements per Appendix 1 apply to Multrees.

2. Conflicts of Interest

All employees are expected to:

Maintain the highest possible standard of integrity in all your business relationships, both inside and outside the organisation in which you work.
Reject any business practice which might reasonably be deemed improper (including improper practices which might benefit the Company).
At all times, act with impartiality, independence and integrity.
Ensure that outwith the expected performance of your role you do not use your position to further either your own personal interests or the personal interests of others.
Avoid being, or giving the appearance of being, in a position which may result in an actual or perceived detriment to the Company’s reputation and/or interests.
Always alert the Compliance Team to any actual or perceived conflict of interests.

Declaration of Interests

Employees must declare any directorships, employment, or other relevant relationships they or their close family members hold, or have held in the past five years, which could give rise to conflicts of interest. This information will be recorded and reviewed as part of the Firm’s annual conflict management process.

The declarations should be updated to reflect any changes in personal or professional circumstances that may give rise to conflicts.

Identifying Conflict of Interest

In identifying conflicts, Multrees will consider, amongst other facts, whether Multrees (or its staff):
Is likely to make a financial gain or avoid a financial loss at the expense of the Customer;
Has an interest in the outcome of a service provided to the Customer or of a transaction carried out on behalf of the Customer, which is distinct from the Customer’s interest in that outcome;
Carry on the same business as the Customer;
Receives or may receive from a person other than the Customer, an inducement in relation to a service provided to the Customer in the form of monies, goods or services other than the standard commission or fee for that service;
Has an interest in the outcome of the selection of a Supplier to Multrees outside standard commercial considerations (e.g. other inducements or outside links, in the case of staff members).

Potential Conflicts

Multrees is involved in a limited number of activities that could lead to a conflict; that is one of our unique selling points, i.e. we do not offer any banking services, do not manage or advise Customers, do not carry out any research, and do not have any investments on our balance sheet apart from our Nominee companies. Therefore, the potential for any material conflicts is low.

However, the following conflicts or potential conflicts could exist:

Gifts and hospitality offered or received;
External directorships and outside interests / employment / links;
Personal account dealing;
Bribery or corruption;
Gains and losses on Customer accounts;
Remuneration.

Managing Conflicts of Interest

Multrees has arrangements in place to identify, prevent and manage actual or perceived conflicts of interest. These arrangements govern the activities of employees as well as ensuring that the activities of the Firm are conducted appropriately to avoid conflicts of interest.

When a new conflict is identified, the Chief Risk and Compliance Officer will decide in consultation with other members of Senior Management whether it is a material conflict or not. The decision will be documented and reported to the next Risk Committee for challenge. Potential conflicts will be logged and the material conflicts log will be provided to the ARC at least annually for review.

Multrees adopts a number of approaches to manage conflicts of interest; the following is a non-exhaustive list of these controls:

Segregation of duties (and supervision) to mitigate the ability of staff to gain from actual conflict situations;
The exchange of sensitive information in cases where conflicts arise is restricted and/or controlled;
Remuneration policy reviewed by Compliance and approved by the Remuneration Committee, to align where relevant the interests of staff, Multrees and Customers, and mitigate the risk of these being in direct opposition to each other;
Periodic attestations by staff to promote ongoing compliance;
Induction training given on conflicts and periodic reminders issued;
Procurement policy reviewed by Finance and Suppliers monitored for potential conflicts of interest;
Periodic monitoring of conflicts and attestations;
Maintaining a register of all staff disclosures.

Training

Training regarding the Conflict of Interest policy is provided to all new members of staff as part of their Compliance induction.

Ongoing training / awareness is provided via two avenues:

Email refreshers are sent to all staff when policies are updated, and responses are tracked to evidence the review.
The HR and Compliance teams ensure that all staff have completed their required annual training referenced above.

Disclosure of Conflicts

Where Multrees considers that the arrangements in place to manage potential or actual conflicts of interest are not sufficient to avoid material risk of damage to a Customer’s interest, Multrees will disclose the conflict to the Customer before undertaking any business for the Customer and obtain their consent to act.

If the Customer does not consent, then Multrees will refuse to act for that Customer or for the particular business which causes the conflict.

Attestations

Every month, all staff are required to attest to having complied with the following aspects of this policy:

Gifts & Hospitality;
PA Dealing.

This attestation serves as a prompt for staff who may have forgotten to log items in the above areas to do so, albeit outside the timeframes set out in this policy. Any instances of late reporting must have a suitable explanation.

Staff are required to attest on an annual basis that they have notified Compliance of any potential conflicts of interest.

Enforcement

Failure to adhere to the terms of this policy may be regarded as a disciplinary offence and would be subject to the relevant HR policy.

3. Gifts & Hospitality

The objective of this policy section is to ensure that Multrees conducts all of its business on a sound and ethical basis, free from outside influence and in full compliance with all applicable legislation (including the Bribery Act 2010 and any accompanying guidance issued from time to time by the Ministry of Justice).

It is the Company’s policy not to allow staff to give or receive gifts and/or hospitality which might be perceived as compromising their personal judgement or integrity. Staff are prohibited from using their position to further either their own personal interests or the personal interests of others.

This policy lays down the company’s underlying principles of accepting and refusing gifts and/or hospitality, it also sets out the procedure to be followed for recording such instances.

This policy prescribes the amount of gifts and/or hospitality which staff are permitted to accept. This policy also imposes an obligation on all staff to ensure that any such gifts and/or hospitality are recorded in the appropriate manner. All gifts and/or hospitality given and received should be recorded, even if they fall outside of the limits detailed in the policy.

Gift: any item, irrespective of value, that serves no business purpose, and is received by a member of staff from a third party: only those received in the course of business or as a consequence and related to their employment with Multrees are relevant to this policy. Third parties include Suppliers, clients and any underlying retail client. Hospitality may be invitations to attend events (including sporting, shopping and cultural events), meals outside working hours or other similar occasions.

Incidental Expenses: Travel and accommodation expenses must not be accepted or offered as part of any hospitality. Staff may arrange and pay for their own travel and accommodation costs if the hospitality is approved.

Payments in Kind: e.g. wine received for making a speech or giving a presentation on work related subjects should be logged as gifts given or received. This approach ensures that the company’s principles of openness and transparency are maintained.

Causes of Conflict: The following are examples of instances that are regarded as potential causes of conflict and unlikely to be approved:

Gifts and/or hospitality at times when business decisions are being made (for instance on tenders, selection of new Suppliers, contract renewals or during project evaluation phases);
Cash, cash equivalents (e.g. gift vouchers) or loans;
Personal services, such as use of another company’s vehicles, use of holiday homes, home improvements, personal discounts, etc.;
Anything where the person offering the gift or hospitality is not present (e.g. tickets to an event where the person paying does not attend);
Anything involving an employee’s partner or other family members;
Paying for a gift and/or hospitality personally, so the employee avoids having to declare it;
Any gift and/or hospitality that involves significant conference fees, travel and/or accommodation; if staff have a genuine business need to attend or stay overnight, Multrees should meet all the costs involved;
Any gift or hospitality involving a sporting event, even if in a charitable or teambuilding context;
Any gift offered to, or accepted from, government officials or representatives, politicians or political parties;

Gifts / Hospitality Received

Accepting gifts and/or hospitality can help to develop working relationships. However, it is important to consider whether there is a clear business justification, if the timing is appropriate, and how accepting the gift and/or hospitality may be perceived.

No member of staff should accept gifts and/or hospitality either directly, or through a third party (e.g. a family member or friend) that would, or might appear to place them under any obligation to an individual or organisation. In accordance with accepted custom in the UK, invitations solely for business purposes (e.g. working meals, meeting for coffee, seminars or presentations) are not regarded as inducements and therefore do not require either approval or logging as per the policy.

Additional hospitality over and above normal business meetings (e.g. meals outside working hours, invitations to drinks receptions, invitations to awards dinners, and tickets to sporting fixtures or other events, golf days etc.) is subject to all policy requirements. For the avoidance of doubt, the acceptance of additional hospitality from Suppliers or potential Suppliers is prohibited; any exception to this prohibition requires approval from a member of the executive team or the Chief Risk and Compliance Officer.

If the member of staff wishes to accept a gift or hospitality, the following principles must be applied:

The member of staff must have a clear business reason, rather than it being for personal benefit;
The gift or hospitality should be timed appropriately (e.g. not before or during a tender or contract renewal);
The member of staff should consider the intentions behind the offer (e.g. would accepting this gift or hospitality influence, or appear to influence, any business decision);

Where possible, approval is needed from an Executive team member or the Compliance team prior to accepting hospitality valued at above £50, or equivalent amount in another currency. When this has not been possible, retrospective approval should be sought. Upon receiving any gift and/or hospitality, staff must adhere to the following principles:

Staff must log any gifts and/or hospitality received within five business days;
If a member of staff does not retain the gift for personal use, then it does not count towards his/her total, referred to above, and does not need to be logged, e.g. sweets shared in the office;
If a member of staff does not want to retain the gift, then they may pass it to Floor Support for donation to charity.

Discounts given, e.g. at a retail hospitality event, are acceptable under the policy where they are provided by a retail store under their normal event provision. For instance, when invited to a ‘shopping evening’, the hospitality may be provided by one third party, but the discount given is provided by the retail store.

This policy cannot cover every situation that might arise; Compliance can advise on any ambiguity.

Limits

In each calendar year, staff are allowed to retain gifts up to a total value of £50 from any one third party and £200 in total from all third parties;
The total annual limit for hospitality an individual member of staff can receive is £1000 per year.

Gifts not Retained by Recipient

Depending on the gift, one of the following courses of action will be carried out for a non-retained gift:

Use it for the benefit of the company as a whole (e.g. wine or chocolates etc.);
Gift it straight to charity;
Raffle it off within the Company and the proceeds of the raffle donated to charity (which will be the most appropriate option in the case of perishable food such as smoked salmon etc.).

Gifts / Hospitality Given

In each calendar year, each member of staff is allowed to give gifts up to a total value of £50 to any third party and £200 in total to all third parties. This is subject to prior senior manager approval for the expenditure. Each individual recipient of a gift must be noted and there is a limit of 10 individuals per firm to whom gifts can be given to by Multrees staff per calendar year.

Branded Multrees goods, e.g. umbrellas, card holders, moleskin notepads etc. are usually subject to this limit; however this excludes branded items below the value of £10, for example branded pens, branded post-it note pads etc. Any exceptions should be agreed by the Executive Director or Chief Risk and Compliance Officer.

Any hospitality offered (excluding meals and drinks) with a monetary value over £50 must be approved by the Executive Director prior to the invitations being sent. The value of hospitality given to each guest at an event must not exceed £200, and a valid reason for the hospitality being given must be recorded as part of the approval process.

In-House Hospitality

Any working meal on office premises (Multrees or any third-party office) does not need to be recorded. Working meals held at a restaurant or any other venue away from office premises needs to be recorded.

Monitoring

It is the duty of each member of staff to record and monitor gifts and/or hospitality given and received, and to be aware of their individual limits. Oversight of the Gifts and Hospitality policy is undertaken by Compliance and Finance, including periodic reviews of relevant logs.

Recording

Details of any gifts and/or hospitality, given and received, should be recorded on SharePoint using the Gifts and Hospitality Log, completing all relevant fields.

Record Retention

In addition to the live record for the current year, records on the Gifts & Hospitality Register will be retained for three calendar years before being destroyed.

Charity Donations

Staff may ask clients and/or Suppliers for charitable donations for sponsored events being undertaken, and similarly the Company itself and/or its staff may sponsor Clients and/or Suppliers for charitable events. In each such instance involving Clients and/or Suppliers, the details should be recorded on the log to ensure transparency.

Enforcement

Failure to adhere to the terms of this policy may be regarded as a disciplinary offence and would be subject to the relevant HR policy.

4. Anti-Bribery and Corruption

Multrees conducts its business with high ethical standards, openness, and transparency.

Multrees prohibits the offering, giving, solicitation and acceptance of bribes, whether cash or other inducements:

To or from any person or company;
In order to gain any commercial, contractual or regulatory advantage for the Firm in a way that is unethical;
Or in order to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.

In addition to being unethical, such behaviour is potentially illegal or would constitute a regulatory breach.

UK Bribery Act 2010
The UK Bribery Act 2010 is the applicable legislation in relation to bribery and corruption. A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Act, namely: giving or offering a bribe; receiving or requesting a bribe; or bribing a foreign public official.

Employee Responsibility
The prevention, detection and reporting of bribery is the responsibility of all employees of Multrees. Suitable reporting channels of communication by which employees can report any suspicion of bribery confidentially can be found in the Whistleblowing policy.

Monitoring
Finance provides oversight of corporate payments, staff expenses, and investigates any items that appear irregular or unusual.

Allowable Activity
This policy is not intended to prohibit the following provided they are carried out in line with the Gifts & Hospitality section of this overall policy:

Normal and appropriate hospitality;
Giving of gifts and entertainment;
Sponsorship for a charity event or activity.

Enforcement
Failure to adhere to the terms of this policy may be regarded as a disciplinary offence and would be subject to the relevant HR policy.

5. Confidentiality, Inside Information and Ethical Walls

The risk of any Multrees staff member becoming aware of insider information or Multrees needing to set up Ethical Walls, is very low. However, in order to protect the integrity of financial markets, Multrees is required to have a policy in place that outlines how these situations would be dealt with.

Ethical Wall
An Ethical Wall is a process for avoiding conflicts of interest by limiting disclosure of information to certain individuals within a firm, in effect keeping a separation between the holders of information and colleagues who represent interests or hold opinions which conflict.

Inside Information
Inside information can be defined as news which, if it were to become public, would have a considerable impact on asset prices. In other words, it refers to information that a reasonable investor would likely use to inform their investment decisions. Therefore, it should be understood that any news which has the ability to impact asset prices also has the potential to be inside information.

Principle of Confidentiality
Firm Confidentiality – Proprietary information makes reference to property that is owned by Multrees.
Employees of Multrees will have access to proprietary information which is confidential in nature and must be protected from unauthorised or inadvertent disclosure. The sources of information can vary, and some common examples include Business strategies and practices, Financial information, Structure of services, IT Infrastructure, and more.

It is the responsibility of all staff at Multrees to safeguard such information, including any proprietary or copyright conditions that exist.

Client Confidentiality – The first and main responsibility for staff is to respect the confidentiality of the information within an Ethical Wall.

Client confidentiality is a standard always maintained at Multrees and is therefore already a part of the culture whether the information to hand is ‘confidential’, ‘inside information’ or otherwise.

Additionally, Multrees and individual employees are obliged by regulation and the law not to disclose any inside information or encourage others to trade on it. As well as being a part of the Conflicts of Interest policy, this forms a part of the terms of employment. Ultimate legal sanctions for insider trading are severe (including potential criminal liability, i.e. a fine and imprisonment of up to ten years, prohibition of trading for up to five years, potential civil liability i.e. an unlimited fine and the liability to compensate any third party who has suffered a loss or loss of profit).

If staff have inside information, however received, they need to be extremely careful not to signal, indicate or make reference to such information to other employees in the course of their normal communications. This could be considered to be ’tipping off’ and may constitute a breach of insider dealing law.

If discussion of sensitive issues is inevitable, do not discuss sensitive issues outside of the Ethical Walls; avoid taking part in any discussions that arise relating to subjects that are currently sensitive.

Note: An employee’s duty to maintain client confidentiality may only be waived when it conflicts with legal or regulatory requirements, for example making regulatory reports. Such disclosures should be made via Compliance with consultation of the Data Protection Officer as required.

If Inside Information Is Received
Staff must inform Compliance immediately in the following cases:

If an Ethical Wall has not been set up, or if the staff member works on the public side of an Ethical Wall (i.e. as part of business as usual), and receive what may be inside information from any source;
If they work within the private side of an Ethical Wall (i.e. one that has been specifically set up as a result of prior receipt of inside information) and receive further inside information under circumstances not in the ordinary course of business.

If inside information is received and no Ethical Wall has yet been set up, Compliance will assess the situation and decide whether Ethical Walls are needed.

Communicating Inside Information
Inside information should only be communicated within the private side of Multrees on a strict ’need-to-know’ basis. It should not be communicated with the public side.

Specifically, information regarding transactions may be shared among members of a specific deal team, but must not be shared generally with other employees unless a legitimate business ‘need-to-know’ reason exists.

Duty to report suspicious transactions
Any person professionally arranging transactions in financial instruments who reasonably suspects that a transaction or orders to trade might constitute insider dealing or market manipulation is under an obligation to notify the FCA of this without delay. As a person professionally arranging transactions, Multrees must submit such a report to the FCA, and this report should contain the following information:

Description of the transaction: Details of the financial instrument(s), including the ISIN code of the instrument; the market(s) concerned; the original order’s entry date/time, price and size; the times and sizes of the transaction(s); the type and characteristics of the order;
Reasons for suspecting that the transaction(s) might constitute insider dealing/market manipulation;
Identities of persons carrying out transaction(s): Names, address, telephone number, date of birth, account number, client identification code used by the firm;
Identities of any other persons known to be involved in the transaction(s): Names, address, telephone number, location, date of birth, relation to person carrying out transaction; position held, role played;
Capacity in which the person performing the transaction(s) acts e.g. broker, underwriter, agent;
Further information which may be of significance.

Where information is not available at the time of notification, the notification shall include at least the reasons why the notifying persons suspect that the transactions or the orders for trading might constitute insider trading or market manipulation.

Compliance is responsible for FCA notifications, making a “Suspicious Transaction and Order Report” (STOR) via FCA Connect, and for any follow-up activity. Any staff member who suspects a suspicious transaction has been made should contact Compliance immediately.

Please note this process is distinct from a Suspicious Activity Report under Anti-Money Laundering rules, which should be made to MLRO@multrees.com.

6. Personal Account Dealing

Although Multrees primarily carries out custody and administration services for clients and underlying customers, a subset of clients also use Multrees for Execution Services, facilitating trading in investments such as equities, bonds or exchange traded funds. However, the operational processes for Execution Services mean that the opportunities for staff to front run or pre-position ahead of customers is limited.

Again, because of the nature of the activities carried out by Multrees, it is highly unlikely that any member of the Company will ever have any inside information – please see the Ethical Walls policy.

Scope

This policy applies to all employees of Multrees (permanent, temporary and contract), it does not apply to non-executive directors as the activities carried out by Multrees will not give rise to potential conflicts with non-executive directors for PA dealing.

Connected Persons

Connected Persons are defined as the following:

Immediate Family: Spouses, Partners; Minor children;
Any other person over whose financial affairs the staff member may be considered to have influence (e.g. power of attorney).

Staff must not influence any Connected Person to enter into a prohibited transaction or a transaction that they would otherwise be required to report. As such, Connected Persons are also subject to the restrictions and reporting requirements contained in this policy.

Any membership of an investment club must be declared to Risk & Compliance, together with a copy of the relevant membership agreement. Unless they operate on a fully discretionary basis, any dealings by the club will be subject to the same dealing requirements applicable to staff.

Acting as trustee or settlor of a trust, where the staff member or connected person has a beneficial interest, is also in scope of this policy.

Securities

Transactions in the following asset classes are in scope of this policy:

Listed assets – e.g. stocks, exchange traded funds, investment trusts;
Bonds, excluding government bonds (e.g. Gilts);
Derivatives where the underlying is an asset covered above (including linked spread bets).

Exemptions

The personal account dealing requirements do not apply to:

Dealings on any investment accounts run on a fully discretionary basis (i.e. where the staff member has no influence on the investment decisions);
Pensions (provided assets are not in the asset classes covered above);
Life policies (provided assets are not in the asset classes covered above);
Commodities;
Spot contracts in currencies or cryptocurrencies. However, this exemption would not apply to Financial Instruments (derivative contracts) that have currencies or cryptocurrencies as the underlying asset;
Dealings in regulated collective investment schemes (e.g. unit trusts and OEICS), – N.B. Investment Trusts are not regulated collective investment schemes;
Vesting or exercise of employee share options;
Shares in unlisted companies (e.g. Multrees shares);
Corporate action decisions, including reinvestment of dividends. Mandatory transactions, such as those covered below, are exempt from the Prohibitions and pre-authorisation requirements, but must still be reported post-transaction with an explanation:

Disposals due to Multrees staff being subject to another firm’s policies (as a connected person of employees of other firms);
Investments by a connected person as part of incentive schemes.

Prohibitions

Where clients have submitted orders for execution by Multrees, staff are prohibited in dealing in these securities between the time the order is received and 24 hours after the order is filled.

As approval to deal is time limited (see below), limit orders are not permitted.

Where relevant, Compliance will incorporate awareness of who has inside information into any decisions to approve / prohibit personal account dealing. Staff in possession of inside information will be prohibited from dealing in the applicable securities until this information is in the public domain.

Approval

Staff should notify Compliance in advance of placing an in-scope deal in order to obtain pre-approval. Compliance will review the proposed deal against customer activity and respond as soon as possible. Unless otherwise specified, pre-approval will be valid until the end of the next working day.

In the event of no response being received after 3 hours, the member of staff should contact the Settlements team and check the potential trade against open and recent customer trades and may proceed if the proposed transaction is not prohibited. Evidence of the attempted approval, and contact with Settlements, will be audited and must be provided as part of trade confirmation.

When a deal has been completed the contract note should be submitted to Compliance within 5 working days.

Regular Investing

Where a regular transaction is being instructed, the notification need only be approved once, with the additional comment that it is a regular event and note the end date or that there is no end date. There is no approval needed to cancel a regular investment.

Monitoring

Compliance will maintain a log of personal deals and will review periodically for evidence of any conflicts or potential conflicts. This may include additional retrospective comparison of staff deals against client orders via Execution Services.

Brokers

At present staff are not required to have their brokers automatically send contract notes to Compliance. However, this may change in future. Multrees does not require staff to use specific brokers for their PA dealing activity.

Enforcement

Failure to adhere to the terms of this policy may be regarded as a disciplinary offence, and would be subject to the relevant HR policy. As well as the potential sanctions set out in that policy, other sanctions could be considered including:

Banning further PA dealing;
Forced sale of assets;
Donation of profit to charity.

7. Appendix I

	Applicable rule or guidance	Rule / Guidance	Applicability
Provision of services	SYSC 10.1.2G	The requirements in this section only apply where a service is provided by a firm. The status of the client to whom the service is provided (as a retail client, professional client or eligible counterparty) is irrelevant for this purpose.	Conflict of interest can arise irrespective of the status of the client/customer.
Identifying conflicts	SYSC 10.1.3R	A firm must take all appropriate steps to identify and to prevent or manage conflicts of interest between: (1) the firm, including its managers, employees and appointed representatives (or where applicable, tied agents), or any person directly or indirectly linked to them by control, and a client of the firm; or (2) one client of the firm and another client that arise or may arise in the course of the firm providing any service referred to in SYSC 10.1.1R including those caused by the receipt of inducements from third parties or by the firm’s own remuneration and other incentive structures.	FCA’s expectation in respect of how a firm chooses to manage instances where conflict can arise, for example by the receipt of inducements from third parties or by the firm’s own remuneration and other incentive structures.
Types of conflicts	SYSC 10.1.5G	The circumstances which should be treated as giving rise to a conflict of interest cover cases where there is a conflict between the interests of the firm or certain persons connected to the firm or the firm’s group and the duty the firm owes to a client; or between the differing interests of two or more of its clients, to whom the firm owes in each case a duty. It is not enough that the firm may gain a benefit if there is not also a possible disadvantage to a client, or that one client to whom the firm owes a duty may make a gain or avoid a loss without there being a concomitant possible loss to another such client.	The types of conflict of interest the firm must be alert to.
Managing conflicts	SYSC 10.1.7R	A firm must maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to prevent conflicts of interest as defined in SYSC 10.1.3R from adversely affecting the interests of its clients.	How to effectively manage conflict of interest.
Conflicts policy	SYSC 10.1.12G	In drawing up a conflicts of interest policy which identifies circumstances which constitute or may give rise to a conflict of interest, a firm should pay special attention to the activities of investment research and advice, proprietary trading, portfolio management and corporate finance business, including underwriting or selling in an offering of securities and advising on mergers and acquisitions. In particular, such special attention is appropriate where the firm or a person directly or indirectly linked by control to the firm performs a combination of two or more of those activities.	This section is not particularly applicable to Multrees as the firm is not involved in the activities mentioned in this section.