Conflicts of interest are inevitable while providing services to customers. The Firm and its employees are required to identify and manage conflicts/potential conflicts of interest in line with our conflicts of interest policies.

What are Conflicts of Interest?

Conflicts of interest occur where, the interest of Kaldi (or another company with which the Firm is associated), and/or the interests of Kaldi’s staff, are in conflict with the interests of one or more customers. A conflict of interest can also arise between Kaldi and its employees.

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There are various instances where a conflict of interest may occur. Conflicts could be between various persons, such as:

• Kaldi and the customer;
• One customer and another customer;
• An employee of Kaldi and a customer;
• An employee and Kaldi.

Below are some examples of situations that may cause conflicts of interest to occur, where the company:

• would make a financial gain, or avoid a financial loss, at the expense of a customer;
• has an interest in the outcome of a service provided to the customer or of a transaction carried out on behalf of the customer, which is distinct from the customer’s interest in that outcome
• holds knowledge in confidence for one customer which would benefit another;
• has a financial or other incentive to favour the interest of another customer or group of customers over the interests of the customer;
• may be remunerated in a way which encourages it to act against its customers’ interests; and
• receives or will receive from a person other than the customer an inducement in relation to a service provided to the customer, in the form of monies, goods or services, other than the standard commission or fee for that service.

Preventing and Managing Conflicts of Interest

In line with applicable regulation, Kaldi takes necessary and appropriate steps to prevent and manage conflicts of interest. To achieve this, Kaldi maintains and operates effective policies and processes to ensure it is able to take reasonable steps to prevent and manage conflicts of interest to prevent them from negatively affecting the interests of customers.

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If Kaldi’s arrangements to manage a potential conflict of interest do not provide reasonable confidence that the risk of damage to a customer’s interests is prevented, Kaldi will disclose the conflict to the customer. Kaldi may decline to act in situations where conflicts of interest are unavoidable.

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