Zopa is responsible for taking all reasonable steps to identify and manage any conflicts of interest in the business that might arise. We are obliged to maintain and operate arrangements to prevent any conflict from giving rise to a material damage to the interests of our customers. We must also establish, implement and maintain an effective conflicts of interest policy. This is a summary of the policy, as relevant to our customers.
We are committed to maintaining the highest ethical standards and complying fully with our regulatory and legal obligations. Compliance with this Conflicts Policy is a requirement of the employment contract of every employee and any breach may lead to disciplinary proceedings, up to and including dismissal.
2. Identification of potential or actual conflicts
A conflict of interest may arise where either Zopa, or any of our employees, directors, outsourced service providers or any person linked by control to us ("relevant person") is providing a service to a Zopa customer, or engaging in activities on their own account, which may entail a material risk of damage to Zopa customers’ interests, for example where we or any relevant person:
- could make a financial gain, or avoid a financial loss, at the expense of a Zopa customer;
- has an interest in the outcome of a service provided to the Zopa customer or of a transaction carried out an behalf of the Zopa customer, which is distinct from the Zopa customer's interest in that outcome;
- has a financial or other incentive to favour the interest of one Zopa customer, or group of Zopa customers, over the interests of another Zopa customer;
- receives or will receive from a person other than the Zopa customer, an inducement in relation to a service provided to the Zopa customer, in the form of monies, goods or services, other than the standard commission or fee for that service.
3. Gifts and entertainment
Gifts and hospitality can lead to potential conflicts of interest. We have a strict policy regarding such issues.
A conflict of interest may arise where an employee has a direct or indirect interest in a transaction. This may include where the employee has a connection with the other party to the transaction or where the employee's family has such a connection -- in particular a connection with a Zopa customer. A connection may include being a director or having a significant shareholding or being an employee or consultant to any Zopa customer. Employees are required to disclose any connection which could, or could be seen to have the effect of compromising the judgment of any employees. Employees are required to notify us of any material interests of this kind that they may have.
5. Managing conflicts of interest and disclosure
We shall use all reasonable efforts to manage any conflict of interest.
If we believe there is still a significant risk of damage to Zopa customers we will consider appropriate disclosure.
We will maintain appropriate policies and procedures as well as training to ensure employees identify circumstances which give rise to a potential conflict of interest and to enable them to manage such conflicts.
We will monitor conflicts which arise.
6. Further information
We will review and update this Conflicts Policy as necessary. Questions regarding this policy should be emailed to firstname.lastname@example.org.