UNIQFINANCIAL S.A. - Conflict of Interest Policy
- Purpose
The purpose of this Conflict of Interest Policy is to protect the integrity of UNIQFINANCIAL S.A. and to ensure that decisions made by its employees, officers, directors, and representatives are based solely on the best interests of the company. This policy provides guidelines for identifying, disclosing, and managing conflicts of interest.- Scope
This policy applies to all employees, board members, officers, contractors, and any individuals involved in the decision-making processes of UNIQFINANCIAL S.A..
- Definition of Conflict of Interest
A conflict of interest arises when personal, financial, or other interests of an individual could potentially interfere with their ability to make unbiased decisions on behalf of UNIQFINANCIAL S.A.. Examples of conflicts of interest include, but are not limited to:
- Financial Interests: Holding a financial stake in a company that engages in business with UNIQFINANCIAL S.A..
- Personal Relationships: Making decisions that could benefit a family member, friend, or associate.
- Outside Employment: Engaging in work or activities that could compromise the individual's commitment or impartiality to UNIQFINANCIAL S.A..
- Gifts and Hospitality: Accepting gifts, services, or favors from individuals or entities that do business or seek to do business with UNIQFINANCIAL S.A..
- Disclosure of Conflicts of Interest
All individuals covered by this policy must disclose any actual, potential, or perceived conflicts of interest as follows:
- Initial Disclosure: Upon joining UNIQFINANCIAL S.A., each individual must complete a Conflict of Interest Disclosure Form, identifying any relationships, activities, or financial interests that could potentially lead to a conflict of interest.
- Ongoing Disclosure: If a potential conflict arises at any time, it must be promptly disclosed to the appropriate authority within UNIQFINANCIAL S.A. (e.g., the Compliance Officer or the Board of Directors).
- Procedures for Managing Conflicts of Interest
- Review and Assessment: Once a conflict of interest is disclosed, the [Board of Directors/Compliance Officer/Conflict of Interest Committee] will review the details to determine whether a conflict exists and assess its significance.
- Decision-Making Process: Individuals with a conflict of interest must recuse themselves from any discussions, deliberations, or decisions related to the matter in question. In certain cases, they may be asked to withdraw from involvement in the matter entirely.
- Documentation: All decisions and actions taken concerning the management of conflicts of interest must be documented, including the nature of the conflict, the individual’s disclosure, and the measures taken to manage or mitigate the conflict.
- Violations of the Policy
Failure to disclose a conflict of interest or to comply with this policy may result in disciplinary actions, which could include termination of employment, removal from the board, or other sanctions as deemed appropriate by UNIQFINANCIAL S.A..
- Annual Review
All covered individuals are required to review and update their Conflict of Interest Disclosure Form on an annual basis to ensure continued compliance with this policy.
- Acknowledgment
All employees, officers, directors, and relevant contractors must sign an acknowledgment confirming that they have received, read, and understood this Conflict of Interest Policy, and agree to comply with its terms.
Effective Date: 20.5.2024
Approved By: Board of Directors
Date of Approval: 19.7.2024