§
Framework for
addressing conflicts
o
Identification: analyzing relationship between the
firm, clients and employees
o
Resolution: disclosure, management or avoidance
§
Employee
conflicts
o
Personal account dealing
o
External directorships
o
Outside business activities
o
Charitable and political activities
o
Gifts & entertainment
o
Use of Firm systems and facilities
o
Investment alongside the firm or clients
§
Organizational
conflicts
o
Independence of control and back
office functions
o
Information barriers / Chinese walls
o
Hedging activities / front running
o
Compensation and incentives
o
Reporting lines and organizational structure
o
Business internalization / cross-divisional
referrals
o
Proprietary trading
o
Multiple roles in a single transaction
§
Client
conflicts
o
Large position accumulation
o
Financing activist hedge fund positions
o
Key client programs
§
Case studies
and practical examples