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Conflict of Interest Policy

Conflict of Interest Policy (TODO: englisch)

Basics

Pursuant to § 63 para. 2 sentence 1 WpHG, the general nature and origin of conflicts of interest and the organisational measures to limit them in the interest of the client shall be presented.

Conflicts of interest which may arise in the context of the securities service or ancillary securities service offered by the company are to be identified (analysis), and the measures taken to limit them are to be presented and disclosed.

Analysis of interests

Conflicts of interest may arise between our institute, our management, our employees and our clients or between our clients.

We have identified the following conflicts of interest:

  • Dealing with information which is not public (primary and secondary inside information).
  • the receipt of benefits from third parties in connection with the provision of investment services.
  • Variable remuneration of employees
  • Advantage, advantage taking

The following circumstances may arise in the context of the investment service offered by Eurobond-Sales AG to conflicts of interest between the interests of the customers (supply/demand), the company and the employees of the company (in particular due to the variable remuneration model of EBS).

  • Different supply and demand prices are available
  • Same supply or demand price is available several times

In addition, conflicts of interest arise between then MA and the company, which lie in particular in the good conduct of dealing with the work equipment provided by the company.

  • Duty of loyalty to asset

Measures

In order to avoid conflicts of interest, the following principles apply:

  • -Careful selection of employees with regard to personal reliability. Where necessary, commitment to absolute secrecy in dealing with information. Ongoing monitoring and disclosure of personal transactions.
  • -Identification of all donations (analysis within the meaning of § 70 WpHG). Work instruction for the acceptance of benefits that are exclusively related to the financial service offered (commission income).
  • -Introduction of an internal bonus model.
  • -Introduction of an employee handbook with binding standards for dealing with business trips, gifts and hospitality.
  • -Eurobond-Sales AG always assumes that supply and demand prices are compared by our customers, i.e. we are in direct competition with other market participants. And our customers, for their part, are obliged to carry out a market fairness test. Therefore: "we always tell our customers the best achievable price"
  • In the case of multiple offers or demands, the following applies: "The former counterparty always wins the contract"
  • Introduction of an employee handbook with binding standards for dealing with the assets transferred by the institution.

Monitoring compliance

Pursuant to MaComp BT 1.2., the Compliance Officer of the institute is responsible for this and regularly discloses and presents this to the controlling bodies of the institute.