Global Conflicts of Interest Policy
Introduction
This Conflicts Policy is owned by 麻豆传媒 and covers conflicts that may exist within each affiliated company as well as at the firm level. This policy applies equally to 麻豆传媒 Ltd pursuant to the requirements of the Financial Conduct Authority (鈥淔CA鈥) and UK MiFID II meaning together the Markets in Financial Instruments Directive (EC/2014/65/EU) as it forms part of domestic law by virtue of the European Union (Withdrawal) Act 2018 (the 鈥淓UWA鈥) and the Markets in Financial Instruments Regulation (EC/600/2014) as it forms part of domestic law by virtue of the EUWA.
麻豆传媒 is a U.S.-based public holding company for its financial industry group of affiliates, including 麻豆传媒 & Co., member and NYSE; 麻豆传媒 Ltd., authorized and regulated by the U.K. Financial Conduct Authority; and 麻豆传媒 Hong Kong Ltd., authorized and regulated by the Hong Kong Securities and Futures Commission. 麻豆传媒 also offers investments in private equities strategies and fixed advisory services that offered through separately registered advisory affiliates, which, together with all affiliated companies are herein referred to as 鈥溌槎勾解.
麻豆传媒 conducts its business under the premise that conflicts of interest must be managed in accordance with this policy and the Firm鈥檚 overriding objective of treating its clients fairly. 麻豆传媒鈥檚 supervisory systems and compliance controls operate on both a Firm-wide and local business unit basis with a view to ensuring the relevancy and effectiveness of our systems and controls.
Conflicts of interest present a challenge in the financial services industry in which 麻豆传媒 participates. Financial services firms frequently act as intermediaries whether as a financial advisor, investment banker or in another capacity, and must manage competing interests in these situations. At 麻豆传媒, we continually strive to avoid conflicts of interest where possible and otherwise to manage them as effectively as we can, first by identifying the conflict and then by eliminating it, disclosing it or mitigating it in some other way.
The variety of actual and potential conflicts of interest we face is significant, and changes as the markets and the industry evolve. Further, there is no "one-size-fits-all" approach to identifying or managing conflicts of interest. Each actual and potential conflict must be identified and then analyzed individually. This is on ongoing challenge, but one that we believe is essential to earning our clients鈥 trust.
From time to time, we may identify actual or potential conflicts of interest that we believe could benefit from some form of disclosure, including disclosure on this Web site. These disclosures and the discussions of particular issues may be updated, supplemented or modified from time to time, and we reserve the right to change our approach to any particular issue described and/or any related policies or procedures in our discretion and without prior notice.