top of page

Conflict of Interest Policy

Summary of Conflict of Interest Policy

​

CXM Prime Ltd (“CXM Prime”) CXM Prime Office No. 318 15 St Helen's Place, London, England, EC3A 6DQ, Registered in England and Wales, Company Number: 13407617 is authorised and regulated by the Financial Conduct Authority (“FCA”) FRN: 966753 and is, therefore, required to conduct its business in line with the FCA’s Principles for Businesses (“PRIN”). In relation to conflicts of interest, the following principles are of particular significance: 

CXM Prime’s conflicts of interest policy ("Policy") sets out the procedures and controls which help us identify, prevent, and appropriately deal with conflicts of interest, whether actual, apparent or potential, in respect of our obligations to clients.

 

Objective

The objective of this policy is to ensure that CXM Prime has appropriate systems and controls to enable it to take all reasonable steps to identify and prevent or manage, and where effective management cannot be achieved, to disclose, conflicts of interest arising out of the services it provides between:  

 

Application

This Policy applies to all of CXM Prime FCA regulated activities and activities in connection with or for the purposes of such regulated activities, including outsourced activities provided by a third party.

 

Identifying conflicts of interest

In assessing whether a conflict of interest has arisen, CXM Prime will consider, amongst other things, whether:

  • CXM Prime is likely to make a financial gain, or avoid a financial loss, at the expense of the client; or

  • an employee of CXM Prime is likely to make a financial gain, or avoid a financial loss, at the expense of the client; or

  • a client of CXM Prime is likely to make financial gain or avoid a financial loss at the expense of another client.

 

Managing conflicts of interest

A non-exhaustive list of a few of the arrangements CXM Prime adopts in order to manage conflicts of interest are:

  • Segregation of duties and supervision for persons engaged in different business activities including procedures for ensuring appropriate communication between business units;

  • Personal account dealing restrictions applicable to all staff and their associates;

  • Protocols to ensure that no improper inducements are given or received, and proper inducements are disclosed appropriately;

  • Gifts and personal benefits procedures including a gift register recording the solicitation, offer or receipt of certain benefits;

  • External directorship policy, including the requirement for all external directorships and outside business interests to be declared; and

  • The provision of training to directors and employees of   CXM Prime on conflicts of interest management.

 

Conflicts disclosure

If arrangements made by CXM Prime are not or cannot be sufficient to ensure, with reasonable confidence, that risks of damage to the interests of a client will be prevented, CXM Prime will disclose the general nature and/or source of conflicts of interest and the steps taken to mitigate those risk before undertaking business for/with the client.

 

V1.1 Sept 2024

bottom of page