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This should be read in conjunction with the Bank’s Terms of Business for Retail Clients.


As a financial services provider, the Alpha Bank London Limited (hereinafter the ‘Bank’) faces actual and potential Conflicts of Interest periodically.

The Bank has commercial interests and at times there is always the risk that it may have interests which conflict with the duty owed to the client. FCA Principle 8 requires firms to manage conflicts of interest fairly, both between itself and its customers and between a customer and another client. FCA rules require a firm to act in a customer’s best interests and also in accordance with the requirements under SYSC 10.

Additionally, under MIFID II firms must endeavor to prevent and avoid conflicts and only where this is not possible may they mitigate the risk through other means e.g. through disclosure. The Bank’s policy is to take all necessary steps to maintain and operate effective organisational and administrative arrangements to identify, mitigate and manage relevant conflicts. Senior management within the Bank are responsible for ensuring that the Bank’s systems, controls and procedures are sufficient to identify, mitigate and manage Conflicts of Interest. Employees of the Bank are responsible for identifying and escalating potential conflicts of interest and are obliged to act in a manner that is not detrimental to the interest of the Bank’s clients. This policy takes into account any circumstance of which we are, or should be aware, that may give rise to a conflict of interest that poses a risk of damage to our clients. This could also arise as a result of the structure and activities of Alpha Services and Holdings S.A  Group (“The Group”)

The Bank does not operate a ‘Trading Book’ but operates an ‘Execution Only’ dealing service for its clients.  The Bank does not produce independent research material and our exposure to possible conflicts of interest is therefore reduced.  The Bank does have arrangements with certain product providers whereby it may receive a trail commission or other remuneration when it executes client orders in products available from those product providers. Where this arises, the bank abides by the rules on inducements to which it is subject under the regulatory regime and will not pay or accept a commission or other inducement unless it is satisfied that it can do so in accordance with those rules and that the service provided to you under these terms is enhanced. Please refer to Clauses 4.5 and 4.6 of your Terms of Business, for specific information on mutual fund rebates.


The Bank is required at all times to consider whether it has interest anywhere within its entities, which could conflict with the interest of its clients.  This could apply to any client we provide or intend to provide, a service and whether the separate interests of two or more of our clients or potential clients are in conflict.  In this context, provision of service can include any regulated or ancillary activity, including investment services, ancillary services, other designated investment business, deposit taking, and activities carried out in connection with them.


Due to the nature of the Bank’s business we endeavor to identify any form of conflict at any part of a business transaction cycle.

a. Conflict Types

For the purpose of identification, the types of conflict of interest that arise or may arise (in the course of providing a service and whose existence may entail a material risk of damage to the interests of a client) include conflicts between:

  • The Bank and a Client;
  • A Relevant Person(see description overleaf) and a Client:
  • Two or more Clients of the Bank in the context of the provision of services by the Bank to those Clients; • A Bank Vendor and a Client.
  • A supplier of services or goods to the Bank or its Clients

b. Clients

For the purposes of this policy, Clients include:

  • existing Clients of the Bank;
  • potential Clients (where the Bank is seeking individually to enter into a contractual relationship in respect of Regulated Business services); and
  • past Clients where fiduciary or other duties remain in place

c. Relevant Person

For the purposes of this policy, “Relevant Person” means any of the following:

  • a director, partner or equivalent, manager or appointed representative (or where applicable, tied agent) of the Bank;
  • a director, partner or equivalent, or manager of any appointed representative (or where applicable, tied agent) of the Bank;
  • an employee of the Bank or of an appointed representative (or where applicable, tied agent) of the Bank; as well as any other natural person whose services are placed at the disposal and under the control of the Bank or a tied agent of the Bank and who is involved in the provision by the Bank of regulated activities;
  • an individual or company engaged by the Bank (directly or indirectly) under a contract for services, including contractors regardless of the duration of their contract.

In identifying Conflicts of Interest, the Bank will consider all of the factual circumstances and the Bank will take into account, inter alia, whether the Bank, Vendor or a Relevant Person:

  • is likely to make a financial gain, or avoid a financial loss, at the expense of the Client;
  • has an interest in the outcome of a service provided to the Client or of a transaction carried-out on behalf of the Client, which is distinct from the Client’s interest in that outcome;
  • has a financial or other incentive to favour the interest of a Client or group of Clients over the interests of another Client;
  • carries on the same business as the Client; and/or
  • receives or will receive from a person other than the Client an inducement in relation to a service provided to the Client, in the form of monies, goods or services, other than the standard commission or fee for that service;
  • is conducting any activity likely to cause adverse reputation risk to either the bank or its clients.
  • Is carrying out any business activity with a client or has done in the past or intends to in the future (i.e this should be declared

Managing Conflicts of Interest: 

Conflict mitigation arrangements

Should a Conflict of Interest arise the Bank will endeavour to eliminate the conflict or if that is not possible mitigate the risk with the conflict issue being managed promptly and fairly. As a minimum standard the Bank has in place arrangements designed to ensure that:

  • divisions and legal entities operate with appropriate independence from one another;
  • there are effective procedures in place to control the flow of information where, otherwise, the risk of a Conflict of Interest may harm the interests of a Client;
  • effective supervisory arrangements, operational procedures and record keeping operate for the identification, escalation and fair management of Conflicts of Interest;
  • there are appropriate controls in place to identify and manage cross-board memberships and outside business interests of Relevant Persons;
  • in certain situations, appropriate disclosure may be made to the Client in a clear, fair and not misleading manner to enable the Client to make an informed decision;
  • where necessary, Relevant Persons may be asked to step aside from working on a specific transaction or participating in the management of a potential Conflict of Interest;
  • where necessary, Relevant Persons are subject to personal account transaction rules; and other reporting and disclosure arrangements.

In managing a Conflict of Interest, it may be appropriate to use additional measures in the event that existing ongoing conflicts management measures are not sufficient to adequately manage the potential conflict including the following:

  • implementation of ad hoc transaction specific Chinese Walls or other additional information segregation methods following consideration of all of the facts available to relevant management;
  • escalation to senior management who have responsibility for the strategy of the Bank and an appreciation of the relationship and reputation risks that may arise;
  • declining to act.

December 2021