CONFLICT OF INTEREST MANAGEMENT POLICY


INTRODUCTION 

This document outlines the commitment of LIQUID BRIDGE FUND (PTY) LTD to doing business ethically and honestly by acting in the interests of its clients. Employees and Reps may encounter situations that result in a conflict between the interests of the employee, the Rep, LIQUID BRIDGE FUND (PTY) LTD and the interests of a client. Therefore, all employees and Reps of LIQUID BRIDGE FUND (PTY) LTD are bound by this Policy.

This policy is intended to guide the decision-making and the behaviour of employees and Reps when faced with such situations. The general guiding principle is that employees and Reps are required to always avoid conflict of interest.

 

“Client” means the persons whose funds we may hold in terms of FAIS and our FSP license: 53058

 

CONFLICT OF INTEREST

A conflict of interest may arise out of the employee’s or Rep’s relationship with a third party, or from an ownership interest the employee or financial adviser has with a third party, or from a financial interest the employee or Rep has or may have in a third party.

 

When interacting, irrespective with whom, it is imperative that employees and Reps ask themselves the questions below:

1.       If my client knew this, would they still do business with me or complete the transaction?

2.       Does this situation influence the objective performance of my obligations to my client?

3.       Does this situation prevent me from rendering an unbiased and fair financial service to my client?

 

The receipt or the offer of a financial interest is prohibited where this interferes with or may interfere with the employee’s or Rep’s ability to render a financial service to a client in an unfair, biased, or subjective manner.

 

Dealing with Conflict of Interest

When an employee or Rep is in a potential conflict of interest situation this must be reported to the Compliance Officer as soon as practicably possible. The Compliance team will give guidance and advice to assist the employee or Rep to avoid or mitigate the conflict. 

 

To ensure that we’re able to identify conflicts of interest as much as possible, we do checks where we evaluate whether we or any of our employees, or Rep we do business with:

1.       are likely to make a financial gain, or avoid a financial loss, at the expense of the client;

2.       have a financial or other incentive to favour the interests of either a financial adviser or another client over the interests of a client;

3.       have an interest in the outcome of a service provided to the client, which is distinct from the client's interest in that outcome;

4.       will receive a financial or cash-equivalent benefit (beyond the standard commission or fee) from any person other than the client in relation to a service provided to the client.

 

LIQUID BRIDGE FUND (PTY) LTD, its employees, and Reps receives no commission on its financial services and product, LIQUID BRIDGE FUND (PTY) LTD may only receive an administration fee which is disclosed to the client on our onboarding documents and where consent for such fee to be received.

Commissions and Referral fees are offered from the Bridging Finance Division which is of no effect to our clients

If there are ever commissions or fees received in relation to financial transactions with clients, those fees will be within regulations and disclosed to the client.

 

Avoiding and Preventing conflicts of interest

We will evaluate and manage a potential conflict of interest as soon as we become aware of it.

Measures put in place to manage conflicts of interest include:

1.       Training – All employees and Reps will be educated about this Policy as well as other FAIS relative codes of conduct on an ongoing basis.

2.       Monitoring – We will do random and ad-hoc checks on transactions conducted to ensure that were and are done in accordance with this policy.

3.       Reporting – We have clear channels of reporting anything with regards to this Policy, and those channels are reporting directly to the Principal and/or manager who oversees the employee or Rep

4.       Consequences – Failure to adhere to this policy will result in strict disciplinary action in accordance with FAIS and our own employment and agency contracts.

5.       No Circumvention – No person may avoid or attempt to avoid, limit, or circumvent, compliance with this Policy, either directly or by association.

6.       Accountability – all employees and Reps are personally responsible for reporting identified potential and actual conflicts of interest to their designated reporting lines (management/ Principal), failure to do so and any breach of this policy may result in disciplinary action in accordance with FAIS and own employment contracts

7.       Information Protection – We have IT systems setup in a manner that restricts certain access and functionalities (such as accessing personal email and copying data to an external source from our hardware) in order to protect client information in accordance with POPI Act. All persons with access to confidential information are legally obligated to treat such information in accordance with the POPI Act and our internal policies.

8.       Gifts and Entertainment – we have an internal gifts and entertainment policy that contains limits and restrictions to ensure impartiality and good ethics 

 

Unavoidable Conflicts of Interest

 

Should there be a conflict of interest, which can’t be avoided, we will immediately advise the affected parties about the conflict in writing. We will outline the nature and extent of the conflict of interest and, where appropriate, give the affected parties the opportunity to decide whether to continue using our services.

Liquid Bridge Fund (Pty) Ltd.

A licensed and authorised financial services provider, FSP no. 53058

 

Liquid Bridge Fund is a Crypto Asset Service Provider (CASP) subject to and in compliance with the FSCA's regulatory regime of South African CASPs. 

Liquid Bridge Fund is an authorized Credit Representative of  Borro Money (Pty) Ltd, a licensed credit provider (NCRCP14706). 

Bank accounts provided by Standard Bank (FSP11287). 

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