Conflicts of Interest

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1. Introduction

1.1 Wombat is committed to maintaining the highest professional standards and, therefore, we endeavour to identify, consider and manage potential conflicts of interest to ensure that we treat all of our customers fairly and in accordance with FCA Rules and principles.

2. Nature of a conflict of interest

2.1 In essence, a conflict of interest is a situation in which Wombat (or any of its personnel) finds itself in a position where its own interests’ conflict with the duties and obligations owed to its clients or, a situation in which Wombat’s duty to one client conflicts with its duty to another. Identifying conflicts of interest for the purposes of identifying the types of conflict and potential conflicts that arise which may entail a material risk of damage to the interests of a client, we must consider whether Wombat or its directors, employees or contractors (“Wombat Personnel”) or any other person linked by control to Wombat:

• is likely to make a financial gain, or avoid a financial loss, at the expense of a client;
• has an interest in the outcome of a service provided to a client or transaction carried out on behalf of a client, which is distinct from the client’s interest in that outcome;
• has an incentive to favour the interest of another client or group of clients over the interests of the client;
• carries on the same business as a client, or
• receives or will receive from a person other than a client an inducement in relation to a service provided to the client, in the form of remuneration, goods or services.

3. Conflict Situations

3.1 We have identified a number of situations which may give rise to a potential conflict of interest. These situations include, but are not limited to, the following:

We receive gifts, entertainment or other monetary and non-monetary benefits from our service providers or business partners (for example, the Issuers of the Investment Products we make available to clients through the Mobile App), which could give rise to a conflict with respect to the duties that we owe to our clients;

Wombat Personnel who have outside commitments (e.g. directorships or other outside business interests) may be influenced to act in a manner that conflicts with the interests of Wombat or its clients; and where Wombat Personnel invest for their own account in certain investments which are retained as investments for client accounts.

4. Conflict Avoidance

4.1 We seek to organise our business in such a way as to avoid conflicts of interest arising.

5. Conflict Management

5.1 For conflicts of interest which are unavoidable, we have put in place procedures which are designed to ensure that the management of any conflict takes place in such a way that Wombat (and its personnel) are not advantaged and that no client is disadvantaged. All of our employees are provided with training in these procedures and the standards of conduct expected of them. Wombat’s Board of Directors remains responsible for ensuring that such procedures are Appropriate and that employees act accordingly. Specifically, we have put in place the following procedures to assist in our identification and management of conflicts of interest:

• Gifts & Entertainment Policy: we ensure that all Wombat Personnel are subject to Appropriate restrictions and monetary limits for any gifts or entertainment received;
• Personal Account Dealing Policy: we ensure that all Wombat Personnel pre-clear and report any personal trading activity which may conflict with the interests of our clients;
• Pre-approval process for all Outside Business Interests: we ensure that our personnel’s external commitments do not conflict with the interests of Wombat or its clients;
• Protection of information: we maintain Appropriate safeguards to protect sensitive or confidential information which could give rise to conflicts of interest. These measures are designed to prevent unauthorised access, inappropriate use, or inappropriate dissemination of such information; and
• Separation of functions: where our internal functions might give rise to conflicts of interest, we put in place arrangements to separate such functions and ensure that separate management and reporting lines are established.

6. Conflicts Disclosure

6.1 If we are not reasonably confident that we are able to manage a particular conflict to adequately protect the interest of a client, the general nature and/or source of conflicts of interest will be clearly disclosed before we undertake any business. The following conflicts are managed through disclosure:

We may aggregate your personal data (including, if you sign up to the Round Up Service, your transactions) with that of other clients and license or sell it to third parties in anonymised form.

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