The Money Platform Conflicts Policy

Introduction

Capitalised terms used in this policy have meaning given to them in The Money Platform Service Terms, unless otherwise defined where they first appear.

We are responsible for taking all reasonable steps to identify and manage any conflicts of interest in relation to the operation of the Platform. We are obliged to maintain and operate arrangements to prevent any conflict from giving rise to a material damage to the interests of our Clients. We must also establish, implement and maintain an effective conflicts of interest policy. This document is our conflicts of interest policy in so far as it applies to the operation of the Platform (“Conflicts Policy”).

We are committed to maintaining the highest of 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, including dismissal.

Identification of Potential or Actual Conflicts

A conflict of interest may arise where either of us, or any of our employees, directors, outsource service providers or any person linked by control to either of us ("relevant person") is providing a service to our Clients, or engaging in activities on their own account, which may entail a material risk of damage to the Clients’ interests, for example where either of us or any relevant person:

• could make a financial gain, or avoid a financial loss, at the expense of a Client;
• has an interest in the outcome of a service provided to a Client or of a transaction carried out an 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 one Client, or group of Clients, over the interests of another Client;
• 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.

Actual or potential conflicts of interest we have identified

Because of the nature of the Platform, we may be regarded as providing services to both Borrowers and Lenders. We will charge a Loan Administration Fee to Borrowers for enabling them to borrow on the Platform, as specified in their Loan Contract (if agreed). Our rights and obligations in relation to that fee are set out in The Money Platform Service Terms. [We may also share payments received or make payments to third parties for introducing Clients to us. We will make appropriate disclosure of such arrangements in the rules applicable to any related promotions or otherwise on request.]

Gifts and Entertainment

Gifts and hospitality can lead to potential conflicts of interest. We have a strict policy regarding such issues.

Employees

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 Client. A connection may include being a director or having a significant shareholding or being an employee or consultant to any Client. 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.

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 Clients 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.