Conflicts of Interest Policy
Summary
Santander UK plc ("Santander UK")
1.
Introduction
Santander UK has a policy on the management of conflicts of
interest. This document summarises those aspects of Santander UK's
Conflicts of Interest Policy which are relevant in the provision of
financial services by Santander UK to its customers. The policy
applies to all employees of Santander UK, including the Retail
Distribution network, and further information is available on
request.
2. What
is a Conflict of Interest and when may it arise?
A conflict of interest may arise where a company, or one of its
employees, is providing a financial service to its customers and
may entail a material risk of damage to those customers interests,
and where the company or its employee:
- Is likely to make a financial gain, or avoid a financial loss, at the expense of the 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;
- Has a financial or other incentive to favour the interest of another customer, or group of customers, over the interests of the customer;
- Carries on the same business as the customer; or
- 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.
3. How we manage conflicts of
interest
The following are examples of conflicts of interest and how we
manage these conflicts:
- Contracts, proposed contracts and similar transactions or
arrangements
- A conflict of interest may arise where an employee has a direct or indirect interest in a transaction. This may be where the employee has a connection with the other party to the transaction, or where the employee's family has a connection. The connection may be from a directorship, significant shareholding, employment or consultancy.
- Santander UK requires disclosure of any connection which could, or could be seen to have the effect of compromising the judgment of any of our employees. Employees are required to notify Santander UK of any such potential conflicts of interest, who will then decide if the employee can be involved in the transaction. Santander UK will also ensure that the relevant Companies Act provisions have been met.
- Gifts, Hospitality & Inducements
- Inducements, gifts and hospitality are all issues that could lead to potential conflicts of interest. Santander UK has a strict policy regarding such issues.
- Market Abuse
- There maybe instances where an employee (an "insider" as defined in the Financial Services & Markets Act 2000) may have information that is not in the public domain but is likely to have a substantial impact on the price of a listed security. These instances are covered in separate Santander UK policies.
- Chinese Walls
- The FSA requires a regulated firm to manage a conflict of interest fairly, both between itself and its customers and between one customer and another. Santander UK manages conflicts of interest by establishing and maintaining internal arrangements restricting the movement of information within the company, usually referred to as Chinese walls. Santander UK's current policy is to establish and maintain Chinese walls where any individuals or business areas are in receipt of price sensitive information.
4. Santander UK's policy
Santander UK has a clear policy on Conflicts of Interest:
- Conflicts of Interest should always be avoided, wherever possible.
- Conflicts or potential Conflicts of Interest must always be disclosed by employees to Santander UK.
Santander UK plc. Registered Office: 2 Triton Square, Regent's Place, London NW1 3AN, United Kingdom. Registered Number 2294747. Registered in England. www.santander.co.uk. Authorised and regulated by the Financial Services Authority except in respect of its consumer credit products for which Santander UK plc is licensed and regulated by the Office of Fair Trading. FSA registration number 106054. Santander and the flame logo are registered trademarks.