This Conflict of Interest Policy explains how METRA identifies, manages, mitigates and, where appropriate, discloses conflicts of interest that may arise in the course of providing its services.
Identification of Conflicts
Conflicts of interest may arise between METRA and a client, between different clients, or between employees and clients.
Examples include personal account dealing conflicts, preferential treatment of certain clients, or conflicts between proprietary activities and client interests.
METRA maintains processes to identify actual and potential conflicts in its products, services and organisational structure.
Management and Mitigation
Measures to manage conflicts may include segregation of duties, information barriers, independent oversight, restrictions on certain activities or declining to act in particular circumstances.
Employees are required to disclose personal conflicts of interest and to follow internal guidance on outside business interests and personal account dealing.
Disclosure of Conflicts
Where conflicts cannot be fully eliminated or mitigated, METRA may provide clear, fair and non-misleading disclosure to affected clients so they can make informed decisions.
Disclosure is not a substitute for effective internal management and is used in combination with other controls.
Governance and Oversight
Senior management and Compliance oversee the effectiveness of conflict of interest controls, including periodic reviews and updates.
Conflicts and their treatment may be documented and recorded in accordance with regulatory and internal governance requirements.
