(Effective: 22nd June 2023)
This policy covers conflicts that may arise between the company or an employee of the company and
its clients, as well as between clients. The firm’s senior management is responsible for ensuring that
the systems, controls and procedures in place are robust and adequate to identify and manage a
conflict as and when it arises. These procedures are regularly reviewed by the Compliance
Department in order to ensure that they are up to date, reflect best practice and that all the necessary
activities and regulations are covered.
Guarding Against Conflicts of Interest
Different systems and procedures have been put in place to minimise any potential for conflicts of
This list, although not exhaustive, includes:

Personal account dealing requirements within the firm

Chinese walls preventing the flow of information between individual departments where a
conflict may exist

A gifts and inducements policy

Segregation of duties where a potential conflict of interest may arise if duties are carried out
by the same individual

A public disclosure policy (“whistleblowing”) for the firm
Where we are aware of a conflict we will disclose it to our clients prior to undertaking investment
business for the clients or, if we do not disclose it, we will manage the conflict in line with our policy
and procedures. In some cases we may decide not to proceed with a transaction which has given rise
to a conflict of interest.
Any further questions on this matter should be addressed to our Compliance Department.
Compliance Department
Intraday Group Ltd
Ocean Centre
Montagu Foreshore
East Bay Street
P.O Box SS-19084