Summary of Conflicts of Interest Policy

The purpose of this statement is to summarise Hellostake’s Limited (“Stake”) conflicts of interest policy (“Policy”) and set out Stake’s approach in identifying and managing conflicts of interest which may arise during the course of its normal business activities. A high level overview of the systems and controls adopted to manage and mitigate such conflicts is also included.  For the purpose of this statement, Stake includes any related group entities and employees.

Conflicts of interests may exist between:

• Stake (including its managers, employees or any person directly or indirectly linked to them by control), and a client of Stake;

• Between two (or more) Stake clients

Stake’s policy is to take all appropriate steps to maintain and operate effective organisational and administrative arrangements to identify, and to prevent or manage potential and actual conflicts of interests.

Identification of conflicts of interests

A conflict of interest may arise when Stake:

• Is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
• Has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;
• Has a financial or other incentive to favour the interest of one client or group of clients over the interests of another client;
• 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.

Managing conflicts of interests

In general, the procedures and controls that Stake follows to manage the identified conflicts of interest may include the following (list is non-exhaustive):

• Undertaking ongoing monitoring of business activities to ensure that internal controls are appropriate and adequate;

• Having effective procedures are in place to prevent or control the exchange of information between related persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of a client;

• Conflicts of Interest Policy, Anti Bribery and Corruption Policy for gifts and entertainment reporting and Personal Account Dealing arrangements;

• Chinese walls restricting the flow of confidential information within Stake and procedures governing access to electronic data;

• Segregation of duties that may give rise to conflicts of interest if carried on by the same individual;

• Robust governance arrangements (e.g. establishment of a risk and compliance committee) as well as senior management oversight, management information and reporting;

• Employee Handbook which includes terms and conditions of employment;

Disclosure of conflicts of interests

If during the course of our business relationship, Stake considers that the organisational or administrative arrangements in place are not sufficient to avoid or manage a conflict of interest, we will then disclose the conflict of interest before undertaking further business with you.