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CONFLICTS OF INTEREST DISCLOSURE

1. Introduction

At Wise Assets UK Ltd ("Wise Assets"), we are dedicated to upholding the highest standards of professionalism. We are committed to identifying, assessing, and effectively managing potential conflicts of interest to ensure fair treatment of all our customers in accordance with the rules and principles set forth by the FCA.

2.What is a Conflict of Interest?

A conflict of interest refers to a situation where Wise Assets (or any of its personnel) faces a conflict between its own interests and the duties and obligations owed to its customers. It can also arise when Wise Assets's duty to one customer conflicts with the duties and obligations owed to another.

To identify the various types of conflicts and potential conflicts that may pose a significant risk of harm to a customer's interests, we consider whether any director, employee, contractor, or any other person linked to Wise Assets through control:

  • Stands to gain financially or avoid financial loss at the expense of a customer;
  • Has an interest in the outcome of a service or transaction that is separate from the customer's interest;
  • Has an incentive to prioritise the interests of another customer or group of customers over the interests of the customer;
  • Engages in the same business as a customer; or
  • Receives or will receive an inducement, such as remuneration, goods, or services, from someone other than the customer in relation to a service provided to the customer.

3. Conflict Situations

We have identified several situations that may give rise to potential conflicts of interest. These situations include, but are not limited to, the following:

  • Wise Assets Personnel may have interest in competitors, customers or suppliers that may create an incentive to act in ways that serve the interests of those entities to the detriment of Wise Assets’ customers.
  • Wise Assets Personnel receiving gifts, entertainment, or other benefits (monetary or non-monetary) from our service providers or business partners, which could potentially conflict with our duties to customers. A Gifts and Hospitality Policy is in place to ensure that these are not excessive and do not create an obligation or debt that impair the employee’s ability to act in the best interest of Wise Assets' clients.
  • Wise Assets Personnel with external commitments, such as directorships or other business interests, that may influence actions conflicting with the interests of Wise Assets or its customers. It is not permitted to participate in outside employment or business interests outside the scope of employment/services, including personal investments, which interfere with work or which may put Wise Assets Personnel in a position of conflict with the interests of clients.
  • Conflicts could also arise if the remuneration structure of employees is all variable and linked to metrics that encourage excessive risk taking. There are limited opportunities for imprudent risk taking and our approach to variable remuneration ensures that Wise Assets Personnel consider risk across the whole business in their decision-making processes. All decisions regarding remuneration are taken in consideration of the long-term interests of the Wise Group (which include Wise Assets Ltd), its staff members and customers, specifically in the context of identifying and managing all potential conflicts of interest.

4. Conflict Avoidance

We strive to structure our business operations in a manner that minimises the occurrence of conflicts of interest.

5. Conflict Management

For unavoidable conflicts of interest, we have implemented procedures to manage them in a way that does not advantage Wise Assets (or its personnel) and does not disadvantage any customer. All our employees receive training on these procedures and the expected standards of conduct. The Board of Directors of Wise Assets Personnel remains responsible for ensuring the appropriateness of these procedures and ensuring employees' compliance. Specifically, we have established the following procedures to assist in identifying and managing conflicts of interest:

  • Conflicts Reporting: We maintain a comprehensive list of potential conflicts of interest and the measures in place to monitor and manage each conflict which in certain cases includes reporting of personal trading activity
  • Gifts & Entertainment Policy: We impose appropriate restrictions and monetary limits on gifts and entertainment received by Wise Assets Personnel.
  • Approval process for all Outside Business Interests: We ensure that personnel's external commitments do not conflict with the interests of Wise Assets or its customers.
  • Protection of Information: We have implemented safeguards to protect sensitive or confidential information that could give rise to conflicts of interest. Our privacy policy provides further details on these measures.
  • Separation of Functions: Where internal functions may pose conflicts of interest, we establish arrangements to separate such functions and establish separate management and reporting lines.

6. Conflicts of Disclosure

If we determine that we cannot adequately manage a particular conflict to protect a customer's interest, we will clearly disclose the general nature and/or source of the conflict of interest before engaging in any business with the customer. The FCA makes clear that disclosure of conflicts should not be seen as an alternative to managing/mitigating conflicts – specifically, an over-reliance on disclosure without adequate consideration as to how conflicts may appropriately be managed is not permitted.

Like all other client communications, the disclosure must be clear, fair and not misleading. In addition, it must:

Be made in a durable medium; and Be made before business is undertaken for the client; and Include sufficient detail, taking into account the nature of the client, to enable the client to make an informed decision with respect to the service in respect of which the conflict arises.