Once a conflict of interest has been identified it needs to be appropriately and adequately managed.
Group Compliance assess each conflict, including whether the conflict is actual or perceived, what the value of the conflict or exposure is and the potential reputational risk. Compliance and management then agree on the controls that need to be put in place to manage the conflict.Investec has various internal controls to manage and mitigate Conflicts of Interests, including:
- Group business practices - Confidentiality and Representation within the Group
- Information barriers (“Chinese Walls”) - Restrictive access control to certain areas; separate IT systems and IT folders, IT access control policy and “Clean Desk” policy
- Disclosure - Clear and concise disclosure to enable the recipient to fully understand its relevance.
Specific instances of conflict may require management intervention in addition to the documented controls already in place. These can include escalation to a management forum, like the Executive Risk Review Forum (ERRF), for a decision on how the conflict should be managed, for example, disclose to the client or decline to act.
Investec additionally has various internal policies to manage and mitigate Conflicts of Interests, including:
- Personal Account Dealing Policy
- Policy on Outside Business Interests
- Gifts and Entertainment Policy
- Employee Participation
Compliance maintains records of all conflicts of interests identified and their resolution, including the persons involved and the controls used. This information is included in reports to management.