Conflicts of Interest
INFOR Financial Inc. (“IFI” or the “Firm”) takes reasonable steps to identify existing and reasonably foreseeable conflicts of interest between a client and the Firm or any individual acting on the firm’s behalf. IFI takes reasonable steps to identify, avoid, address, and disclose material conflicts of interest with clients and/or potential clients. A conflict of interest may arise while IFI is carrying out business activities, either for a client or on its own account, that may conflict with the interests of another client if it is not managed or controlled in an appropriate manner.
Potential conflicts of interest
Below is a non-exhaustive list of scenarios where conflicts of interest may exist in IFI’s normal course business activities:
- IFI may act as an underwriter in a new issue while recommending the new issue to potential purchasers;
- IFI may possess material non-public information relating to an issuer which it can not disclose to our clients;
- Selling securities of companies that are connected to IFI;
- IFI may be required to select specific clients that it will offer securities of a new issue to, in the event that the transaction is over-subscribed.
Mitigating conflicts of interest
IFI has established internal Policies and Procedures to manage existing and potential material conflicts of interest. The policy requires that all transactions, activities, interests, or associations of IFI and its employees which might create or appear to create a material conflict of interest must be managed, controlled, disclosed, or avoided.
If a conflict of interest cannot be avoided or resolved, it will be disclosed to the client or potential client. In the case of material conflicts of interest, IFI may decline to provide services to a client or potential client. All conflicts of interest are dealt with in a fair, equitable and transparent manner in the best interest of the client.
For further information on conflicts of interest management procedures, please contact IFI’s Compliance Department.