Conflicts of Interest Policy
March 2011 v1.1

Amendments to this Policy

From time to time this policy will be updated to reflect changes to CEI Compliance Limited’s regulated business or changes to the regulations to which CEI Compliance Limited is subject. The Compliance Officer will ensure that all appropriate amendments are made to this manual, and this will be overseen by the Compliance Director.  The dates of the amendments are recorded below.  Please ensure that you have the most up-to-date version of this manual by confirming the correct version number with Compliance.

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Introduction

CEI Compliance Limited have a responsibility to satisfy themselves that it, its  operations and outsourced functions are properly run and have appropriate corporate governance. One of the ways in which this is achieved is to set policies for each fundamentally affected areas of business, especially those subject to regulatory scrutiny.

It is a fundamental principle of CEI Compliance Limited that it will maintain the level of integrity expected to comply with the regulatory, statutory and industry requirements applicable to its business activities.  This conflicts of interest policy sets out CEI Compliance Limited’s approach to occurrence of this situation, which should ensure that CEI Compliance Limited complies with all of its legal and regulatory obligations.

For many reasons, CEI Compliance Limited considers it important to provide its staff with clear guidance on its archiving procedure.

Conflict of Interests

CEI Compliance Limited has or may have a material interest in a transaction or a relationship that might give rise to a conflict of interest. A conflict of interest may arise between:

• CEI Compliance Limited and a customer; or
• Two different customers.
• When identifying conflicts of interest, you must at least consider whether the party/parties involved:
• are likely to make a financial gain, or avoid a loss, at the expense of a customer;
• hold a differing interest in the outcome of a service or transaction provided to the customer, or of a transaction carried out on behalf of the customer, which is different to the customer’s interest;
• has a financial or other incentive to favour the interest of one customer(s) over the interests of another customer;
• carries on the same business as the customer; or
• receives or will receive from a person other than the customer an exceptional inducement in relation to the service provided.
• In the event that the procedures to manage the conflict may not prevent the risk of damage, CEI Compliance Limited will be required to disclose the general nature or sources of the conflict to the customer in good time to enable the customer to make an informed decision. Do not make any disclosures to the customer without consulting a Director first. If you have any queries on conflicts, speak to a Director.

Inducements

• CEI Compliance Limited may only pay or accept fees or commission, or provide or receive any non-monetary benefit, in relation to its regulated activities if they fall within the categories set out below:
• The fee, commission or non-monetary benefit is paid or provided to or by a customer.
• The fee, commission or non-monetary benefit is paid or provided to or by a third party or a person acting on behalf of a third party and:
• The existence, nature and amount of the fee, commission or benefit, or, where the amount cannot be ascertained, the method of calculating that amount, is clearly disclosed to the customer, in a manner that is comprehensive, accurate and understandable, prior to the provision of the service; and
• The payment of the fee or commission, or the provision of the non-monetary benefit is designed to enhance the quality of the service to the customer; and
• The payment of the fee or commission, or the provision of the non-monetary benefit does not impair compliance with CEI Compliance Limited’s duty to act in the best interests of the customer.
• It is a fee which enables or is necessary for the provision of the regulated activities, such as custody costs, settlement and exchange fees, regulatory levies or legal fees, and which by their nature cannot give rise to conflicts with CEI Compliance Limited’s duties to act honestly, fairly and professionally in accordance with the best interests of the customer.
• CEI Compliance Limited will have satisfied its disclosure obligation under section 2.2 if it:
• discloses to the customer the essential arrangements relating to the fee, commission nor non-monetary benefit in summary form; and
• undertakes to the customer that further details will be disclosed on request; and
• honours this undertaking.
• A record of each fee, commission or non-monetary benefit it paid and/or received to another FSA authorised firm will be maintained by the Operations Department for at least 5 years from the date on which it was paid. These records will be subject to random monitoring checks by the Risk and Compliance Department.

Annual Review

This policy must be reviewed by CEI Compliance Limited’s Board of Directors every year to ensure its alignment to appropriate legal and regulatory requirements as well as best practice compliance standards, the local whistle-blowing procedures, and its continued relevance to CEI Compliance Limited’s current and future operations. Every 12 months the Board of Directors must issue an up to date policy for CEI Compliance Limited. Any interim change to this policy must be proposed to the Board of Directors and, if agreed, requires the written approval of members of the Board of Directors.

This policy was approved by the Board of Directors of CEI Compliance Limited on 01 March 2011.

Anya Werrell
Company Secretary

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CEI Compliance Limited is registered with the Information Commissioner under the registration of Z1449155 in the name of CEI Compliance Limited. CEI Compliance Limited Directors are qualified by diploma with the Chartered Institute for Securities and Investment and are a member of the Association of Professional Compliance Consultants, The Compliance Institute & The Business Continuity Institute. CEI Compliance Limited is registered in England & Wales no. 6501824.

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