Reuss Private Access AG (RPAc) is obliged under applicable legal provisions to inform about and disclose conflicts of interest. Below, we provide information on the comprehensive precautions and measures implemented for the handling of conflicts of interest:
Conflicts of interest may arise, for example, between RPAc, other entities of the Reuss Private Group, our executive management, our employees or other affiliated persons, tied agents contractually bound to us, and our clients – or between different clients themselves.
Possible Sources of Conflicts of Interest:
- In asset management, due to the company’s own (revenue-related) interest in the distribution of financial instruments – in particular, products issued by group entities;
- Through the use of tied agents operating under our MiFID Tied Agent;
- When receiving or granting inducements from or to third parties;
- Through performance-based remuneration of employees;
- Through performance-based remuneration of employees;
- Through the acquisition of information that is not publicly known;
- From personal relationships of our employees or executive management, or of persons associated with them;
- Through the involvement of such persons in boards of directors or other governing bodies.
Measures
To ensure that unrelated interests do not influence our services or actions, we are committed to high ethical standards. We expect diligence and integrity at all times from ourselves, our employees, and affiliated entities. This includes lawful and professional conduct, adherence to market standards, and—above all—putting the client’s interests first.
Specifically, we take, among others, the following measures to prevent conflicts of interest:
- Establishment of organisational procedures and processes;
- Policies on the acceptance and granting of inducements, including corresponding disclosure requirements;
- Establishment of confidentiality areas through the implementation of information barriers, separation of responsibilities, and/or physical separation;
- Maintenance of a continuously updated conflicts of interest register;
- Disclosure of securities transactions by employees to the Legal & Compliance department, where their role may give rise to potential conflicts of interest;
- Training of our employees;
- Ongoing monitoring and reporting of identified conflicts by the Legal & Compliance department.
- If a conflict of interest cannot be neutralised, measures will be taken up to and including the termination or non-establishment of a business relationship.
As of 01.02.2024
Disclaimer:
This English version is a non-binding translation of the original German text. It is provided for convenience only. In the event of any discrepancies or legal interpretation, only the German version shall be legally binding and authoritative.
