In application of the European Directive "MIF" (Market of Financial Instruments), HTL CAPITAL has formalized a policy of management of conflicts of interest and set up specific processes in terms of organization (means and procedures) and controls to prevent, identify and manage situations of conflict of interest that may affect the interests of its clients.

As such, it is recalled that HTL CAPITAL gives the greatest importance to the interests of its customers. The purpose of this policy is to indicate the main measures to achieve this conflict of interest management objective. Nevertheless, if any conflicts of interest arise, they will be managed in the interest of the customer, in a fair way and by providing him with complete and adapted information.

Thus HTL CAPITAL is authorized according to the situations of conflicts of interests to:

• carry out the activity or transaction if the organization adequately manages the potential conflict of interest situation;
• inform the client in case certain conflicts of interest remain and provide him with the necessary information on their nature and origin;
• if need be, do not carry out the activity or the transaction causing a conflict of interest.

HTL CAPITAL must manage any conflict of interest, from detection to appropriate treatment. As such, HTL CAPITAL has set up an organization allowing:

• to prevent the emergence of conflicts of interest, by raising the awareness of all its staff on the rules and codes of good internal conduct and place, and by setting up strict rules and procedures:
  • establishment of an internal control system;
  • separation of functions that can generate potential conflicts;
  • always ensure that the offer of products and services that HTL CAPITAL offers its customers corresponds to the profile and their expectations, and is never in contradiction with their interests;
  • prohibition of personal operations which do not comply with the rules laid down by the company;
  • training or raising awareness among all staff of good practice in the profession;
• identify conflict of interest situations that may affect the interests of clients, by establishing a risk map of these conflicts of interest. This mapping specifies activities or operations for which a conflict of interest is likely to occur. The role of HTL CAPITAL's RCCI is to ensure that this map is up-to-date;
• manage situations of potential conflicts of interest:
  • by informing clients in a complete and objective way, refraining from using biased arguments and pointing out the constraints and risks associated with certain products or operations;
  • by informing clients in a complete and objective way, refraining from using biased arguments and pointing out the constraints and risks associated with certain products or operations;