Description of the possible situation of
conflicts of interest
Measures for managing the conflicts of
interest
Corporate Finance
The functions that have or get into a conflict of
interests are as a rule located in different units in
the structure of the Bank and also physically
separated from each other. Also internal rules
have been established in the Bank prohibiting the
exchange of confidential information between
such functions.
A conflict of interest may arise if Swedbank AS
(hereinafter: Bank), acting as creditor to a client,
could have a business interest in gaining access
to information held by a corporate finance
department within Swedbank Group on the said
client or if an Entity acts as an issuing agent for
two different competitors.
Trading in Financial Instruments
A conflict of interest may arise when the Bank
plays a double role – carrying out a client
transaction with itself or another entity belonging
to Swedbank Group as the counterparty; or
carrying out a transaction between clients with
differing interests.
Investment research
A conflict of interest may arise when the Bank – or
whoever undertakes investment research – could
have a business interest that goes against the
interests of the potential investor.
Financial advice
A conflict of interest may arise if the Bank only
recommends its own, or the Swedbank Group's
own products.
Asset management (portfolio management)
A conflict of interest may arise between various
asset management assignments and as a result
of different types of remuneration models
(incentive agreements).
Granting credit
A conflict of interest may arise if the Bank takes
on several different roles – as a credit institution,
as adviser and/or as underwriter.
Inducements
A client’s transaction in financial instruments will
be carried out according to the rules of best
execution of the Bank, according to which the
Bank will take all reasonable steps based on the
resources available to deliver best execution of
the clients’ orders.
The Bank’s internal rules on identification,
management and prevention of conflicts of
interest lay down requirements to the employees
preparing investment research for disclosing
potential conflicts of interest and limitations on
carrying out transactions in financial instruments
that investment research is related to.
The Bank’s employees are not separately
remunerated (by means of additional bonuses)
for recommending or selling the Bank’s or
Swedbank Group's products.
In rendering portfolio management service, the
Bank assesses the suitability of the service and
financial instrument to the client. A client’s
transaction in financial instruments will be carried
out according to the rules of best execution of the
Bank, according to which the Bank will take all
reasonable steps based on the resources
available to deliver best execution of the clients’
orders.
The Bank’s remunerating principles have been
prepared on the principle that recognition is given
to the results of a longer period (quarter, year),
not single transactions.
The functions that have or get into a conflict of
interests are as a rule located in different units in
the structure of the Bank and also physically
separated from each other. Also internal rules
have been established in the Bank prohibiting the
exchange of confidential information between
such functions.
Receipt and/or payment of such benefit, its
nature and amount (or the method for its
A conflict of interest may arise when the Bank, in
relation to the provision of an investment or
ancillary service to the client, receives payment or
non-monetary benefit from or provides payment or
non-monetary benefit to a third party.
calculation) is disclosed to the client before
providing the respective service. The Bank
accepts the receipt or payment of such benefit
only if it improves the quality of the service
provided to the client and does not damage the
client's interests.
Remuneration
The Bank’s remunerating principles have been
prepared on the principle that recognition is given
to the results of a longer period (quarter, year),
not single transactions.
A conflict of interest may arise when an
employee's remuneration is such that could entail
damage to the interests of a client or a group of
clients when carrying out a transaction on behalf
of a client/group of clients.
Confidentiality
A conflict of interest may arise if confidential
information is given to an unauthorized party.
Vested interest
A conflict of interest may arise if the Bank’s
employee involved in a client assignment has a
vested interest in, or is not impartial in any other
way to, the said assignment (e.g. due to a
personal relationship – family, relative, friend or
similar – or economic connection to a client,
service provider or colleague).
Fringe benefits and bribes
A conflict of interest may arise if the Bank’s
employee involved in a client assignment behaves
improperly by receiving or demanding from or
giving gifts or other benefits to a client or service
provider of the Bank.
Employees’ personal transactions
A conflict of interest may arise if the Bank’s
employees conduct transactions with financial
instruments or currencies on their own account
using the knowledge they have on client deals or
at the expense of the client.
Assignments outside employment
A conflict of interest may arise if the Bank’s
employees undertake assignments outside
employment or secondary assignments which
could jeopardize their impartiality in a client
assignment.
There are internal rules laid down in the Bank for
keeping and protecting confidential information
and for identifying and monitoring the movement
of inside information.
According to the ethics rules of the Bank, an
employee of the Bank may not handle
assignments that could call into question his/her
impartiality and professionalism due to the fact
that the employee has a family relationship with
the client or service provider or has other direct
or indirect interest in the assignment.
The ethics rules of the Bank set forth which
benefits and gifts are proper. The principle of
transparency an moderation apply in provision or
receival of benefits and gifts.
According to the Bank’s internal rules on
identification, management and prevention of
conflicts of interest, the Bank’s employees are
prohibited from carrying out transactions through
the Bank’s systems in relation to the employee’s
own accounts and in relation to the accounts of
persons related to the employee. Carrying out
transactions on the basis of inside information is
prohibited under the Bank’s internal rules.
The Bank’s employees are obliged to declare
their economic interests to the Bank. For
performing assignments outside employment, a
Bank’s employee must inform the Bank and
receive respective approval.