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A ‘conflict of interest’ is a situation which may prevent services being provided in an independent or impartial manner. Conflicts of interest can arise in a number of circumstances, including between Iress / an employee / any associate of Iress, and any of its clients; or between two or more of Iress’ clients.
Examples of ‘conflicts of interest’ include situations where Iress, or an employee of Iress, or a person associated with Iress:
Anyone who believes that they have or might have a personal conflict of interest or who believes that their actions will or might conflict with the contractual, legal or regulatory duties they have to Iress, Iress’ clients or Iress’ suppliers must inform the Managing Director in the jurisdiction in which they operate or a member of the Leadership Team (an “Executive”) without delay and must not thereafter participate in, or in any way seek to influence, any negotiations, discussions or decisions relating to the relevant transaction which is the subject of the conflict without the approval of the Managing Director or Executive.
For the above purposes, a personal conflict of interest arises where an employee of Iress (or any connected person of such employee) has or appears to have a personal interest in any transaction.
In relation to this statement:
Where a personal conflict is identified it must be managed promptly. This may involve the individual removing themselves from dealing with a particular issue, client or supplier, or it may be that the conflict can be managed by disclosure to all parties and close monitoring. Each occurrence will need to be judged on its own merits.
Anyone who believes that there is or might be a conflict between the interests of Iress and one of its clients or who believes that Iress’ actions will or might conflict with the contractual, legal or regulatory duties Iress has to its clients must inform an Executive without delay.
For the above purposes, a conflict of interest arises between Iress and its client where there is a conflict between the interests of Iress and the contractual, legal or regulatory obligations that it owes to its client.
In relation to this statement:
A conflict may also arise where Iress becomes aware of sensitive information through dealings with clients that could be of use when negotiating contracts with other organisations. If this should occur the employee concerned must inform an Executive without delay. The Executive may decide that the sensitive information or the existence of it should be declared to the relevant client and remove the employee from the negotiations (if appropriate) to ensure there can be no accusations of dishonest practice. It may be possible to manage minor conflicts as long as they are disclosed to all parties. Conflicts of interest may be unavoidable, however it is vital to the interests of Iress that when they occur they are identified promptly and action is taken to ensure that the conflict is managed.
When reporting a conflict, the following procedure should be followed:
Board and Committees
A standing agenda item at Iress Limited Board meetings requires the Board to consider, and the Minutes of the meeting to record, any conflict of interest arising for a Director, including the type of conflict and how the conflict was managed by the Board.
In addition, all Australian Financial Services Licensees are required to maintain records for at least 7 years of:
Conflict of Interest (‘COI’) Report
Iress is a technology company providing software to the financial services industry.
Our software is used by more than 9,000 businesses and 500,000 users globally.