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