EUROCORP

Prevention of Conflict of Interest

Markets in Financial Instruments Directive
Brief Presentation of the Prevention of Conflict of InterestPrevention of Conflict of Interest Policy

Introduction

In the context of applying the Markets in Financial Instruments Community Directive (MiFID), EUROCORP GROUP implements specific measures to ensure, control and handle avoidance of all cases of conflict of interests. EUROCORP has developed a specific policy to promote its client’s interests, which are described below. For more information please refer to the client service executives of our company.

Our policy on conflict of interests
EUROCORP designed the conflict of interest policy with the sole objective of promoting the interests of its clients:

  • In relation to our investment services and activities, we have defined all the cases or circumstances, which comprise or may lead to conflict of interests, which implies a substantial risk for damage on our client’s interests.
  • We apply appropriate mechanisms and systems to handle and avoid cases of conflict of interests.
  • We ensure the operation of the relevant mechanisms and systems so as to prevent any possible conflict of interests that may be damaging to our clients’ interests.

Conflicts of interest
Our policy is applied to the following conflicts of interest (definition criteria):

  • Conflicts of interest between EUROCORP and its clients, as for example when we provide a service and apart from such, we have material interest or benefit or we are involved in any way in the transaction, the product or the service. The definitive criteria in this case concern the ability of EUROCORP to realize profit or avoid a loss at the expense of its client’s interests.
  • Conflicts of interest between our clients, in the cases when acting on behalf of one client and on behalf of another client and the interests of the two clients are materially in conflict.

In relation to all our provided services and activities, we have defined the possible areas of conflict of interest:

  • The simultaneous provision of investment services within the context of different operations.
  • Cases where the provision of advisory services or management services are affected by other interests of the company or its employees.
  • Cases of sales or purchases of products from the company’s proprietary account to our Clients.
  • Our participation in making a transaction by acting on behalf of different clients.
  • The provision by our company of investment advice on financial products of an issuer to which we are connected through a business relationship.
  • Performing proprietary transactions on financial instruments for which we also perform transactions on your behalf or for which we provide advisory services.
  • Holding confidential information from other clients and which could affect the services we provide to you if such information was disclosed or used.
  • The fact that executives or partners of our company may accept gifts or benefits that may be considered contrary to our obligations towards our clients.
  • The fact that partners of EUROCORP may exercise other activities or develop personal connections that may possibly become damaging for our client.
  • Personal relationships that may exist between our company’s partners and clients and that may be a source of conflict of interests.

Measures for prevention of conflict of interest
Below we present the measures applied to identify and handle conflicts of interest.

  • Policy and procedures
    We have established procedures that hold and apply to all our activities and all our partners, executives and employees with a view to preventing and handling any possible conflict of interest. The relevant procedures are subject to continuous evaluation and review.
  • Confidentiality of information
    Our cooperating companies, executives and employees have a specific and explicit obligation to preserve confidentiality of information that is related to and concerns our clients or their transactions and may not provide such information to any third party and in any way. Moreover, and in some sensitive areas and fields of our activity we have set Chinese walls and specific procedures that aim at obstructing the transfer of confidential information between partners, executives and employees while at the same time we have organized and separated partners that hold such information.
  • Distinction of supervision and controls
    In cases where the fact that two different departments or units have common management may create a conflict of interest, such departments will be managed by different individuals.
  • Fees and remuneration
    Fees and other remuneration may be linked to the results of EUROCORP SECURITIES S.A. or the unit to which the partner or executive or employee belongs. However, the cases where the relationship between fees or any kind of remuneration of the above with the result of another unit or department to which such belongs, may create a conflict of interest, are explicitly prohibited.
  • Benefits
    Commissions, fees, discounts or other monetary benefits that may or not be offered from or to third parties and are related to a service provided to clients, are not accepted unless:

    • Special reference and information regarding commissions, fees or other benefits are provided to our clients.
    • Such refer to commissions or normal fees that aim at improving the quality of the provided service in favor of the client.
  • Personal transactions
    In order to prevent any cases that may lead to conflicts of interest resulting from access to privileged information or other confidential information related to clients or transactions with or for clients, all cooperating companies, executives and employees of our company are subject to special provisions regarding personal transactions set out under the law or issued by the Hellenic Capital Market Commission.
  • External activities
    All our partners are obliged to comply with the procedures we have established in order to avoid possible conflicts of interest in relation to their possible activities outside the framework of EUROCORP.
  • Gifts
    Our partners, executives and company employees may accept only small gifts or gifts of negligible value below a level defined by the company.
  • Disclosure of information
    In the cases where it is impossible to handle the conflict of interest and therefore we cannot properly ensure avoidance of risk to our client’s interests, EUROCORP will clearly disclose the nature of the conflict of interest and the sources of this conflict so you can decide, having full knowledge of the circumstances, whether you wish to continue receiving our services or not under the specific circumstances.
  • Right to refuse provision of services
    When we believe we cannot avoid the conflict of interest during the provision of a service, we can refuse the provision of the specific service to a client in order to protect his interests in the best possible manner.
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