This is a template for Conflicts Management. The template gives you best practice and a steer for recording conflicts of interest in your business. There are two templates in this document:
- A template for individuals to notify about individual conflicts, with sections for line manager and compliance review
- A template to log all the individual notifications
It is designed for those organisations that do not have a conflicts management system. Providing Excel based templates which cover all the areas that a conflicts management system might otherwise capture.
It enables you to meet the FCA expectation that you have documented all your conflicts of interest under Principles 3 and 8, and SYSC 10. Although designed for FCA regulated firms the approach taken is global best practice which we’ve seen used in conflicts management systems used by global banks and so it should work for most jurisdictions.
The template is designed to be completed by anyone working in your organisation, and has been carefully drafted such that someone with limited prior experience of conflicts of interest as it includes multiple examples of conflicts, decisions, and actions. There are drop down menu’s based on industry standards, with notes for more complex firms needing to customise them. The log could be locked or held centrally by a function such as Compliance so that the content cannot be altered or deleted once logged.
This Conflicts Management Template provides comprehensive coverage of both personal and business areas of conflicts of interest. For example, transactional conflicts, outside business interests, fund manager conflicts.
The template gives you:
- The areas you must cover under FCA rules
- Explanations for what to record under each column heading
- Worked examples for every type of conflict
- Best practice for recording conflicts of interest
We also provide a template for a conflicts register which enables you to record business conflicts and so meet regulatory expectations that you have a conflicts register.
The spreadsheet is completely customisable, free of any macro’s or coding, so you can just download and start recording.
Conflicts Management Templates
This document is in Microsoft Excel (*.xlsx)